This privacy policy ("Privacy Policy") applies to Purpose Unlimited and its affiliates ("we", "us", "our") and explains how we collect, use, and disclose personal information in Canada through our website located at www.purpose.ca through services provided to our clients.
In general, "personal information" means information about an identifiable individual, subject to more particular definitions or interpretations under applicable law. Purpose Unlimited collects, uses and discloses personal information about you:
Our portfolio manager and advisor clients (“Clients”); and
Customers of our Clients (“Client Customers”)
This information may include, but is not limited to, an individual’s name, mailing address, e-mail address, financial information, and telephone number. This Privacy Policy does not apply to personal information about employees, partners, or other temporary or permanent staff, consultants, volunteers, or other individuals assigned to Purpose Unlimited, or to any information that is not personal information as defined in or interpreted under applicable law.
How we collect information about you
We typically collect Client personal information directly from Clients or through our interaction with Clients. We always collect Client Customer personal information from our Clients
How we disclose and share your information
Custodian
If you open an account with us, we will share your personal information with a custodian so that they may provide services such as the safekeeping of your securities, trade execution, and clearing. Your personal information will be treated in accordance with the custodian’s privacy policy.
Service Providers
Purpose Unlimited may also transfer Client and Customer Client personal information to our Service Providers used to administer or provide products, services or information on our behalf such as to host the Website and platform, operate certain of its features, send marketing messages or other communications, or manage and analyze data and our advertising effectiveness. We use reasonable measures to require the organizations with whom we share your personal information for these purposes to use your personal information only to perform the services we have contracted them to provide.
Sale of Business
We may also disclose certain personal information to parties connected with the proposed or actual financing, insuring, securitization, assignment, sale or other disposal of all or part of our business or assets (including your loan)or as part of a corporate reorganization, or share sale or other change incorporate control, for purposes connected to evaluating and performing the transaction. These purposes may include determining whether to proceed with the transaction or business relationship, or fulfilling any records or other to those parties. The personal information we may disclose in such circumstances includes financial information obtained in support of your financing application. Where applicable, we will take steps to require that such parties treat your personal information in accordance with this Privacy Policy and use and disclose it only for the purposes for which it was collected, including to provide the services or information that Purpose Unlimited would otherwise provide to you and generally to carry on Purpose Unlimited business. Our successors or assigns may collect, use and disclose personal information for purposes similar to those described in this Privacy Policy or as otherwise permitted or required by applicable law.
Legal/Compliance
We and our Canadian, US and other service providers may provide your Personal Information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud or as otherwise required or permitted by applicable Canadian, US or other law. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.
Recruitment Privacy Policy
1. Scope
This Policy applies to individuals applying for employment, educational institutional partnership opportunities, or contract opportunities with Purpose Unlimited Inc. or any of its affiliates. We collect and process personal information to assess candidates for open positions with us and, if you are successful, to extend an offer of employment or engagement.
If you are applying for a position with Purpose Unlimited, Purpose Unlimited is responsible for your personal information being processed in accordance with this Policy.
Throughout this Policy, Purpose Unlimited Inc. and its affiliates are referred to as "Purpose Unlimited," "we," "us," or "our."
2. Information We Collect, Use, and Why
Most of the personal information we collect is voluntarily provided directly by you during the application process. We may also request to obtain information from external sources, such as professional references, recruitment service providers, or background check providers, when applicable to the position and permitted by law.
Some information is necessary for us to assess your application. If you choose not to provide it – or where we require your consent and you choose not to give or to withdraw it – we may not be able to consider you for the position.
A. General Candidate Information
We may collect, use, and disclose ("Process") the following personal information when you apply:
Name and contact details.
Government-issued identification and social insurance number (when required and in accordance with applicable laws).
Professional and educational background, including credentials.
Any information you include in your application, résumé, or cover letter.
Work permit status.
Any other information you provide as part of the recruitment process.
Why we process it: We process this information for the purpose of assessing and selecting the most suitable candidates for open positions, which constitutes a reasonable purpose within the meaning of applicable Canadian privacy legislation.
We may also process your information to enter into a contract with you, determine benefits eligibility, and comply with equal opportunity and non-discrimination programs when required or permitted by applicable law. When required, we will also process and may share personal information to comply with legal obligations, including record-keeping, audits, government inspections, and legal process compliance.
B. Sensitive Personal Information
We may process certain types of sensitive personal information – such as health or medical information, information about disabilities, race, gender, ethnicity, or creed – when relevant, permitted by applicable law, or only when strictly necessary for a specific identified purpose and only with your explicit and informed consent. We may also process political or religious affiliations if you voluntarily share them, for example as part of an accommodation request. We collect such information only when necessary for a lawful purpose and in compliance with the Canadian Human Rights Act, the Ontario Human Rights Code and equivalent legislation in other provinces.
Why we process it: We collect this information for specific purposes, including to accommodate a disability or illness, and to comply with legal obligations and internal policies relating to health and safety, occupational health, diversity, and non discrimination. We use it only for those stated purposes and as permitted by law.
When required, we process this information only with your consent, or when necessary to comply with legal obligations, in connection with legal claims, or to protect your vital interests when you are unable to provide consent.
C. Criminal History and Background Checks
When appropriate to the nature of the position and permitted by applicable law, we may process information about criminal convictions, offences, and credit history through background or security screening. This information may be collected from authorized third parties or disclosed directly by you.
Why we process it: We use this information when necessary to protect your interests, our interests, and those of our employees, contractors, and the clients and third parties we serve. It may also be used in connection with legal claims, regulatory requests, or legal proceedings, and to comply with our obligation to maintain a safe working environment.
3. Use of Artificial Intelligence in Recruitment
Purpose uses artificial intelligence (“AI”) to support parts of our recruitment process.
In accordance with applicable law, including Ontario legislation, AI is defined as a machine-based system that, for explicit or implicit objectives, infers from the input it receives to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.
In practice, AI may be used to:
Flag potentially fraudulent applications for manual review.
Analyze and summarize materials you submit during the recruitment process.
Summarize interviews and assessment results.
Support the screening, assessment, and selection stages of our hiring process.
Human oversight is central to how we hire
All hiring decisions are made by our recruitment and hiring staff. AI supports that process – it does not replace human judgment, and no candidate will be screened out, assessed, or selected based solely on AI output.
We disclose AI use in all publicly advertised job postings, as required by applicable law.
Your rights regarding AI-assisted decisions
You may request:
Information about the personal data and main factors used in any automated step.
An explanation of how AI was applied in your assessment.
A human review of any AI-assisted decision.
An alternative selection process.
To make any of these requests, contact us at peoplecultureteam@purpose-unlimited.com.
Our AI governance framework is designed to ensure that our use of AI in recruitment is fair, accountable, and transparent. It includes:
Regular assessment and mitigation of risks in AI-enabled recruitment tools.
Ongoing validation of the accuracy and explainability of automated systems.
Documentation and review of AI's impact on candidate selection.
Human oversight at every decision point.
4. Disclosures Within Purpose Unlimited and to Third Parties
For the reasons set out in this Policy, we may transfer or disclose personal information to:
Service providers, including applicant tracking providers, application review tools, and background check providers.
Information technology providers, including IT systems and email providers.
External professional advisors, including accountants, auditors, lawyers, and insurers.
Government bodies, regulatory authorities, and law enforcement, as required by law.
Third parties in connection with corporate transactions, including mergers, acquisitions, reorganizations, financing transactions, or similar proceedings, subject to confidentiality protections.
When recipients process personal information on our behalf, we have data processing agreements in place that limit their access, use, and disclosure; require appropriate safeguarding; and restrict retention to what is necessary for their contractual obligations to us.
Some of our service providers, including applicant tracking, application review, and background check providers, may be located outside Canada, including in the United States, meaning your personal information may be transferred to, stored in, or accessed from foreign jurisdictions. When this occurs, your information becomes subject to the laws of that jurisdiction, and foreign governments, courts, or law enforcement may have the right to access it in ways that Canadian privacy law would not otherwise permit. We contractually require all such providers to protect your information with safeguards consistent with applicable Canadian privacy legislation.
5. Storage, Security, and Retention
We store personal information in secure systems and databases operated by us or our service providers. We retain information for a maximum period of three years for the purposes described in this Policy and securely delete or anonymize it when it is no longer needed.
With your explicit consent, we may retain your information to contact you about future opportunities that align with your skills and experience. You may withdraw this consent at any time by contacting us at peoplecultureteam@purpose-unlimited.com.
Purpose Unlimited uses appropriate technical, physical, and organizational measures to protect personal information in a manner consistent with the sensitivity of that information and in accordance with applicable law.
6. Your Privacy Rights
Depending on where you are located, you may have the following rights under applicable Canadian privacy legislation:
Access to your information: Request copies of your personal information and details about how it is collected, used, and shared.
Rectification: Ask us to correct information that is inaccurate or incomplete.
Erasure: Ask us to delete your personal information, subject to applicable legal requirements.
Restriction of processing: Ask us to limit how we use your personal information.
Objection to processing: Object to certain uses of your personal information.
Withdrawal of consent: Withdrawal will take effect within 30 days of receiving your request, subject only to our legal obligations to retain certain information.
Some exemptions may apply, and we may not be able to fulfill every request in full.
We will take steps to verify your identity before acting on any privacy rights request.
You also have the right to lodge a complaint with the applicable supervisory authority in your jurisdiction.
7. How to Contact Us
If you have questions about how we handle your personal information, or to exercise any of your rights, please contact:
People and Culture Team peoplecultureteam@purpose-unlimited.com
If you have any concerns or believe there has been a breach of privacy during the recruitment process, please contact:
Privacy Officer privacy.officer@purpose.ca
Purpose Unlimited Canada, Inc. 130 Adelaide Street West, Suite 3100 PO Box 83, Toronto, ON M5H 3P5
How We Use AI in Our Hiring Process
At Purpose, we believe in being straightforward about how we work – including how we hire. We use artificial intelligence (AI) to support parts of our recruitment process, and we want you to understand what that means for your application when applying for an open role at Purpose Unlimited and its affiliates.
For the purposes of this Statement, AI is defined in accordance with applicable law, including Ontario legislation, as a machine-based system that, for explicit or implicit objectives, infers from the input it receives to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.
How We Use AI
AI may be used at the screening, assessment, and selection stages of our hiring process. For example, AI may be used to:
Flag potentially fraudulent applications for manual review by our team.
Analyze and summarize the experience and materials you submit.
Summarize interviews and project evaluations.
Support our hiring team in identifying and assessing qualified candidates.
What AI Does Not Do
AI does not make hiring decisions. Every application is reviewed by a member of our team, and all final decisions – including offers, rejections, and advancement – are made by our people. AI informs our process; it does not replace human judgment.
If an application is flagged as potentially fraudulent, it is reviewed manually before any decision is made.
Your Rights
You have the right to:
Know how AI was used in your assessment.
Understand the main factors considered in any AI-assisted step.
Request a human review of any AI-assisted decision.
Request an alternative selection process, when feasible.
To exercise any of these rights, contact us at peoplecultureteam@purpose-unlimited.com.
Data Privacy
All information you provide is handled in accordance with our Recruitment Privacy Policy. Your personal information is used solely for recruitment purposes and is protected in accordance with applicable Canadian and provincial privacy legislation.
Your information is retained for a maximum of three years and deleted or anonymized thereafter, as described in our Recruitment Privacy Policy.
Our Commitment to Fairness
We are committed to fair and equitable hiring. Our use of AI is governed by an internal framework that includes human rights compliance and human oversight. Our recruitment process is designed to comply with the Canadian Human Rights Act, the Ontario Human Rights Code, and equivalent legislation in other provinces.
We may use AI to support, not replace, human decision-making in our hiring process.
If you have questions about how AI is used, or wish to request an alternative selection process, please contact us at peoplecultureteam@purpose-unlimited.com. Where your personal information is processed using AI tools, we do so in accordance with our Recruitment Privacy Policy and applicable Canadian privacy law.
Our Website
In general, you can visit the website without telling us who you are or submitting any personal information. However, as most websites do, we track usage patterns on our website Each time you visit our website, our server records your Internet service provider, the date and time of your visit, the pages you visit and the documents downloaded, the searches you performed, and the referring URLs you came from. We use this information to better understand and optimize our website service.
Cookies, Tracer Tags & Web Beacons
Our Website uses a technology called "cookies”. A cookie is a file containing a unique identification number that our website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our website where you are prompted to log in or that are customizable. If you have registered with our website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers), and (3) will provide us and our service providers with information that we will use to personalize our website in accordance with your preferences. We and our service providers also use cookies to help us understand our website activity, to improve our Website and provide better customer service. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all of the features and functionality of our website.
Analytics
Our Website uses web analytics services such as Google Analytics. They use cookies to help us analyze how visitors use our Website. For example, with Google Analytics, the information generated by the cookie about your use of the Website(including your IP address) will be transmitted to and stored by a Google server. Google uses this information for the purpose of evaluating your use of the Website, compiling reports on Website activity for us, and providing us with other services relating to Website activity and internet usage. You can prevent the storage of data relating to your use of the Website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links
https://policies.google.com/technologies/partner-sites
https://support.google.com/analytics/topic/2919631
Third Party Links
For your convenience, we may offer links from our website to other websites. However, Purpose Unlimited is not responsible for, nor do we accept any liability for, the personal information collection, use, and disclosure practices of other entities to which our website may link. You should consult the privacy policies of these other entities before providing any personal information on their websites.
Your Consent
We collect, use and disclose your personal information with your consent or as permitted or required by law. Your consent may be expressed or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to Purpose Unlimited, we assume that you consent to the collection, use, and disclosure of your personal information as outlined in this Privacy Policy. If you do not consent, please do not provide your personal information or, where applicable, exercise the opt-in or opt-out options offered.
Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use and disclosure of your personal information or you may withdraw your consent to our further collection, use, and disclosure of information about you, by contacting us via email at compliance@purpose.ca. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our services. There are instances where Purpose Unlimited may collect, use, or disclose your personal information without your consent, for example, to comply with a subpoena or court order, or to comply with the rules of court regarding the production of records.
You can opt-out of receiving marketing offers at any time by clicking on the unsubscribe link included in our marketing email communications or by contacting us as set out under Contact Us below.
International Transfer and Storage of Information
Note that some of the Service Providers that process or handle personal information on our behalf may be located outside of Canada, including in the United States. As a result, your personal information may be transferred, stored and/or processed outside Canada in connection with the purposes described in this Privacy Policy. While your personal information is outside of Canada, it is subject to the laws of the jurisdiction in which it is held, and may be accessed by government authorities in that jurisdiction pursuant to those laws. For more information on our policies regarding foreign processing of personal information, contact our Privacy Officer (contact information is at the end of this policy).
Security
Purpose Unlimited has implemented reasonable physical, organizational, and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized Purpose Unlimited Members, agents, and mandatories have access to your personal information. You can generally visit the Purpose Unlimited website without providing any personal information. However, given that electronically submitted data is not one hundred percent(100%) secure, we make no warranties as to the security of any such personal information that you submit, which you do at your own risk.
Access, Correction, Inquiries, and Complaints
If you wish to request access to, or correction of, your personal information in custody or control of Purpose Unlimited, please make your request in writing to us at the address below. We may need to verify your identity before searching for or providing you with personal information. In some circumstances, we may not provide access to your personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information, or if it is otherwise not properly the subject of an access request. It is important that your personal information be accurate and up to date. Please inform us as soon as possible of any changes to your personal information. If you have any questions, requests or complaints about our personal information practices, please contact us via email at compliance@purpose.ca
Changes to This Privacy Policy
Purpose Unlimited reserves the right to change this Privacy Policy at any time, and we will take reasonable steps to advise affected individuals of any material changes, if necessary. However, you should review this Privacy Policy from time to time to ensure that you are aware of and accept any changes made. You may contact us at the address, email address, or telephone number below to obtain a current copy of this Privacy Policy.
Contact Us
Please contact our Privacy Officer if:
you have any questions or comments about this Privacy Policy;
you wish to access, update, and/or correct inaccuracies in your Personal Information, or
you otherwise have a question or complaint about the manner in which we or our service providers treat your Personal Information.
You may contact our Privacy Officer by email at compliance@purpose.ca or by mail at the following address:
130 Adelaide Street West, Suite 3100 PO Box 83, Toronto, ON M5H 3P5