Welcome to Mako Financial Technologies, inc. (“Mako”). This Privacy Policy contains information on how we process personal data as part of our services, but also when you navigate our website or interact with us. It also contains information on some privacy rights that you can exercise. Mako provides a cloud-based financial platform that supports companies in the financial industry (our “Subscribers”) to streamline the communications with and administration of their clients (the “Users”). More specifically, we support our Subscribers with the digital onboarding of their clients, we have developed a mobile-friendly client portal and we have simplified digital agreements and internal workflows so that our Subscribers are more efficient and transparent.
WHEN DOES THIS PRIVACY POLICY APPLY?
This Privacy Policy applies when you visit www.makofintech.com (the “Website”) and/or when you subscribe to, use or access the financial software services that we offer through a Subscriber (the “Financial Software Services”, together, the “Services”).
“Visitor” means any person who visits the Mako Website.
“Subscriber” means any person, organization, independent financial advisor, issuer, portfolio manager, broker or other financial professional who has subscribed to Mako Financial Software Services offered through a paid subscription or a trial.
“User” means any individual and/or employee who creates an account or accesses Mako Financial Software Services through a Subscriber. In this case, a User’s personal data is collected and processed by Mako Subscribers through their use of Mako Financial Software Services.
Under European data protection laws, when we deliver Mako Financial Software Services to our Subscribers, we are a data processor, which means that we only process your personal data on behalf of another entity, our Subscribers. We are a data controller when we collect and process the personal data of Website visitors.
If you have any questions or concerns regarding how we process your personal data or regarding your privacy, please do not hesitate to contact us. You can email us at privacy@makofintech.com or send us a letter to the following address:
Attn: Privacy Officer
Mako Financial Technologies Inc.
4 Place Ville-Marie,
Suite 300
P.O. Box 26
Montreal, Quebec
Canada
H3B 2E7
If you require information about your financial or investment information that is collected and held by one of our Subscribers or how our Subscribers process your personal data, we recommend that you reach out to this Subscriber directly.
WHEN DOES THIS PRIVACY POLICY NOT APPLY?
If you click through to links to third parties’ websites, applications, or services from our Services, this Privacy Policy does not apply to the processing of personal data by such external services. We recommend reading these third parties’ privacy policies.Our Subscribers are responsible for implementing their own Privacy Policy, which describes in further detail how they collect and process your personal data. We do not have full control on how our Subscribers collect, use and disclose your personal data, please refer to their respective Privacy Policy for further information.
WHAT IS PERSONAL DATA?
When we use the term “personal data”, we mean any information that relates to an identified or identifiable natural person. This includes the obvious data such as a name, home address, email address, phone number, birth date, as well as a government identification, banking, financial and investor information, social insurance number, annual income and other economic, cultural or social identity of natural persons.
This Privacy Policy is for transparency purposes and some of the data that we identify in this Privacy Policy as personal data may not be considered as such under the laws that are applicable to you. For instance, business contact information may or may not be considered personal data, depending on the laws that are applicable. If the data is not considered personal under the law, you may not have the same rights over it, and we may not have the same obligations.
WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU AND FOR WHAT PURPOSES?
Website Visits
First, Mako collects and processes some personal data from Visitors to our Website.
Inquiry and Support Data
If you inquire about our Services or career opportunities by e-mail, social media, through our website or otherwise; if you request a demo, a quote, general information, or support from us, we will collect and process the personal data as required to respond to your inquiries, including any attachments and content you include in your communication. We process such personal data based on your implied consent.
We use third parties who are tasked to provide Visitors with help-related inquiries. Service providers may host the personal data you share with them on servers outside of Canada, including the United States. Examples of our service providers include Zendesk’s Integrated Ticketing System
Social Media Data
If you interact with us on social media, we will collect and process the personal data which you make available to us based on your implied consent. We do not perform interest-based advertising through social media platforms.
Cookies
We use session cookies, persistent cookies and analytical cookies to better understand how you interact with our Website, to improve and personalize your experience while visiting our Website, and to provide Mako with some aggregated statistical data about how you use and browse our Website. More specifically:
Session cookies
We use “session” cookies to better understand how you interact with our Website, and to monitor aggregate usage and web traffic information. A session cookie is a cookie which is only installed for the duration of your browsing session.
Persistent cookies
We use “persistent” cookies to recognize you each time you return to our Website. For example, we create a persistent cookie that includes some basic information about you, like your most recent search. A persistent cookie is installed longer than your browsing session and is required for behavioral analysis. They are never installed for more than 2 years.
Analytical Cookies
Analytic cookies are used to generate aggregated statistical data about Website traffic and visitor behaviour. Mako uses Google Analytics to view key metrics such as how many visitors view the website, peak hours of traffic, and key words searches. Google Analytics is Google’s analytical tool that helps us to understand how Users engage with our Website. Data collected includes your Internet Protocol address, geographic location, browser information, device identifiers, what Websites you visited before and after your visit at www.makofintech.com.
You can manage your cookie preferences through your browser using the instructions provided below by clicking on the browser that you are using. Google Chrome, Firefox, Safari, Internet Explorer, Opera However, by blocking some cookies that enable the functions of the Services, parts of the Services may not be available. You can install the Google Analytics opt-out browser add-on, which prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.
Mako Financial Software Services
We process various types of personal data for the purposes of delivering our Financial Software Services to our Subscribers and to you, the Users. We support our Subscribers with products and services such as the digital onboarding of clients, our mobile-friendly client portal, digital agreements and internal workflows.We process such personal data in accordance with the instructions of our Subscribers, who are responsible for determining which lawful basis allows them to process your personal data and, if applicable, to obtain your consent. The section below describes in further detail Mako’s processing activities.
User Account Information and Login Credentials
When you, as a User of our Financial Software Services, sign up for an account through the Subscriber, or when a prospect Subscriber signs up for a demo trial, you will need to provide your first name and surname; your email address and create an Account password.We process this data to set up a trial or regular account for you to access our Financial Software Services, to provide such Financial Software Services, to manage our relationship with our Subscribers and to provide User support.
Transaction Information
For Subscribers who purchase a paid version of Mako Financial Software Services, Mako will process Subscribers’ billing information, including credit card information, email, banking information, location at the time of transaction and/or a billing address.
Usage Information and Technical Log Data
When you use Mako Financial Software Services, our servers automatically collect data regarding when Services are accessed, including your IP address, browser type and configuration, operating system, length of visit, page views, geographical location, language preferences and device information.We collect this information for our Services to function effectively, fix bugs, determine subscriber usage-based pricing, if applicable, as part of the contract agreement with Subscribers and ensure the security of our Services. For instance, we may collect the language of your browser so that we present you with the right linguistic version of the Web Application Service. To ensure the security of our digital infrastructure, we collect and monitor audit logs, namely, to monitor system performance, potential security threats and vulnerabilities, resource utilization and to detect unusual system activity or service requests.
User Support Information
If you request technical support from us, we will collect and process the personal data as required to respond to your inquiries, including any attachments and content you include in your communication. We process such personal data based on your implied consent.
We use third parties who are tasked to provide Users with help-related inquiries. Service providers may host the personal data you share with them on servers outside of Canada, including the United States. Examples of our service providers include Zendesk’s Integrated Ticketing System.
Financial and Investor Information
Mako provides Subscribers with interactive digital forms, investor onboarding automated ID/AML lookups, binding e-signatures, custom client communication software, automated regulatory forms and online subscriptions as well as progress tracking tools. The Financial Software Services contain several functionalities requiring the processing of different types of personal data for different purposes, such as obtaining e-signatures, merging personal information between databases, processing transfers and payments. Operating in the digital financial industry also requires Mako to process your personal data to prevent money-laundering and fraudulent financial activities from occurring.Depending on the Service you use or access, personal data processed by Mako could include your name, address, telephone number, email, Government identification, banking and investment information, Social Insurance Number / Social Security Number, employment information, annual income, risk tolerance, investment knowledge and objectives, investment and securities information and electronic signature.
Service and Maintenance Communications
We may send you emails concerning your account, upgrades, changes related to our Services or policies. These communications are provided to you to inform you of important information relating to our Services as well as when they are necessary to maintain a safe environment.
External Applications
The Financial Software Services may contain features designed to interoperate with external Applications not provided by Mako. These features are available at the Subscriber’s discretion and may require Subscribers to enter into contractual agreements with sub-processors. Subscribers must also inform Users of such external Applications and obtain their consent when applicable. This Privacy Policy does not apply to external Applications.
DO WE SHARE PERSONAL DATA WITH THIRD PARTIES?
We may share personal data with third-parties in some circumstances, including to administer, provide, secure and improve the Financial Software Services; to provide help-related inquiries, to host our Cloud services; to prevent money-laundering and fraudulent financial activities from occurring; or if required by law pursuant to a subpoena or other legal process.
Our categories of third parties are: Hosting/infrastructure/storage providers, Payment processors, including debt collectors, Customer Support tools providers, Credit Score providers, Anti money-laundering service providers, Internal communication tools providers
Maintaining a safe environment
We may release personal data when we believe that doing so is appropriate to comply with applicable laws, regulations or legal requests; to enforce or apply our policies and guidelines; to initiate, render, bill, and collect amounts owed to us; to protect our rights or property; to protect the safety of our Subscribers and Users; to address fraud, security or technical issues; to prevent or stop activity that we consider to be illegal or unethical; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay. We may also be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Sale/Merger Information about our Subscribers is a business asset of Mako. Consequently, information about our Subscribers, including personal data, may be disclosed as part of any merger or acquisition involving Mako, the creation of a separate business to provide some or all the Services, the sale or pledge of Mako assets, as well as in the event of an insolvency, bankruptcy or receivership.
WHAT ARE YOUR PERSONAL DATA RIGHTS?The Personal Information Protection and Electronic Documents Act (PIPEDA) provides you with limited rights concerning your personal data. The Office of the Privacy Commissioner of Canada has published a number of resources to help you understand and take action on your privacy rights.The General Data Protection Regulation also affords European Union (EU) citizens with data rights regarding their personal data. UKs Information Commissioner’s Office has published the following Guide on individual data rights.If you have questions regarding how Mako processes your personal data or you are looking to exercise your personal data rights, please contact us directly at privacy@makofintech.com or:
Attn: Privacy Officer
Mako Financial Technologies Inc.
4 Place Ville-Marie, Suite 300
P.O. Box 26
Montreal, Quebec
Canada H3B 2E7
We will try to help you with your request free of charge. However, we may request that you pay a reasonable fee if you request a transcript, or a reproduction or for us to send a copy of your personal data, if the law allows us to do so. If we need to charge a fee to process your application, we will contact you before addressing your request.For security reasons and to avoid any fraudulent request, we may be required to ask that you provide a proof of identity with your request. We will not use such personal data for any other purposes.We will respond to your request within thirty (30) days, unless agreed otherwise. Please remember that personal data rights are not absolute and could be refused. If your request is denied, we will notify you in writing, and provide you with detailed motives and information on how to contest our decision.If you are in Canada, you can contact the Office of the Privacy Commissioner (OPC). The OPC has published advice to help you access your personal data, as well as exercise your rights when it is held by a business. You can also contact the Office of the Privacy Commissioner of Canada’s Information Center:
Telephone
9:00 am to 4:00 pm EST
Toll-free: 1-800-282-1376
Mailing address
Office of the Privacy Commissioner
30 Victoria Street
Gatineau, Québec
K1A 1H3
You can also use this online form.
If you are in the European Union and you want to learn more about your rights, you can consult this guide published by the Information Commissioner’s Office of the United Kingdom.If you’re not satisfied with how we process your request, you can communicate with your local data protection authorities or privacy commissioners, and lodge a complaint. We will provide you with explanations on how to do so in our response to your request based on your location. To launch a complaint with the OPC, you can fill out this form. You can consult a list of EU data protection authorities here. Finally, your browser may allow you to automatically transmit a “Do Not Track” request to websites you visit. Mako does not currently respond to or change any of its practices when it receives a “Do Not Track” request from your browser.
HOW DO WE PROTECT YOUR PERSONAL DATA?
Mako has established security safeguards to protect your personal data:
Industry-recognized certification.
We are SOC 2, Type 1 certified.
We use a secure Cloud infrastructure.
Our cloud-based platform is hosted on Amazon Web Services (AWS) servers located in Canada, which uses secure-by-design infrastructure and built-in protection.
Access Rights.
Our policies ensure access on a need-to-know basis through access controls and appropriate authentication mechanisms.
Encryption. Personal data is stored behind password-protected systems with encrypted (TLS/SSL) connections. Confidentiality Agreements. Disclosures of personal data to third-parties, affiliates, auditors and consultants as necessary to perform the Services, are made under appropriate confidentiality obligations.
Please be aware, however, that no method of transmitting information over the Internet or of storing information is completely secure. It’s your responsibility to keep your credentials secure and ensure that you’re connected on a safe network.
WHERE DO WE STORE YOUR PERSONAL DATA?
Our cloud-based platform is hosted on Amazon Web Services (AWS) servers located in Canada, unless otherwise specified by a Subscriber.
However, our service providers may process your personal data internationally, including in the United States, depending on where they are located.
The GDPR establishes specific data protection rules governing the transfer of personal data of EU citizens to non-EU countries. When sending personal data to processors established outside of Canada or the EU or EEA, Mako will use appropriate safeguards, for example by using standard data protection clauses, as provided by the European Commission.
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We store your personal data for as long as necessary to provide you with the Services or as required by law, whichever is longer.
When visiting our website, we use both persistent and session cookies. Session cookies are deleted once you close your browser, whereas persistent cookies remain active on your device for some time. For instance, Google Analytics cookies remain installed on your device for two (2) years.
CAN WE UPDATE THIS PRIVACY POLICY?
We may update this Privacy from time to time, please ensure to review it whenever you use our Services. We will also inform Subscribers of significant changes we make to our Privacy Policy in a timely manner.
This Privacy Policy is effective as of March 31, 2021.