Privacy Policy
Effective May 1, 2026
Eterna Financial Group, its subsidiaries, including Eterna Trust, Eterna Insurance, Eterna Investment Management, and Eterna Financial Services, as well as Fondation Frontenac (hereinafter collectively referred to as the "Company"), recognize the importance of protecting the personal information of their clients (hereinafter collectively or individually referred to as the "Clients" or the "Client") and are committed to doing so in compliance with applicable laws.
1. Scope and application
This policy applies to all activities of Eterna Financial Group and the following subsidiaries:
- Eterna Trust
- Eterna Insurance
- Eterna Investment Management
- Eterna Financial Services
It applies to any individual whose personal information is collected, used, or disclosed by the Company, whether in the context of a client relationship, a visit to our website, or any other interaction.
2. Methods of collection
In most cases, the Company collects the Client's personal information directly from them. However, personal information may be collected from other individuals associated with the Client, such as family members, a designated trusted contact, or professional representatives, as well as from other financial institutions or companies offering financial products and services. The Company may collect the Client's personal information in various ways. For example:
- By phone
- In person
- Using forms
- Using technologies that identify, locate, or profile the Client, such as cookies.
3. Personal information collected
The Company limits the collection of personal information to what is essential. Only the personal information necessary to achieve the stated purposes is collected. The following are some non-exhaustive examples of information that the Company may collect, use, or disclose:
- Identification information: full name, date of birth, mailing or email address, phone number, age
- Authentication information: passwords, answers to authentication questions, government identifiers, and other information appearing on your identity documents (e.g., social insurance number, driver's license number, health insurance number, passport number)
- Health information: health status, lifestyle habits
- Financial information: income, salary, balances and debts, products and investments, financial statement, investment profile, tax identification number, banking details
- Information about financial products and services: holdings and a comprehensive view of your situation, including profile, needs and objectives, transaction and interaction history, and investment knowledge level
- Digital information (via the website, portal, and mobile application): IP address, location data, information related to the device used, operating system, or browser
- Information about your interactions and communications with the Company and its representatives: meeting recordings, notes, and communication summaries
- Other information: information about other individuals (e.g., agent, guardian, temporary representative, assistant, beneficiary, spouse, dependent, or joint account holder), information about professional status (e.g., your education, occupation, association, or professional order).
4. Purposes for the collection, use, and disclosure of personal information
The Company collects, uses, and discloses the Client's personal information for the following purposes, depending on the nature of the products and services offered by each of its subsidiaries:
- Establish and maintain the Client's file;
- Understand your needs and profile;
- Comply with regulatory Know Your Client obligations (KYC);
- Provide and manage financial products and services;
- Manage and administer insurance products;
- Provide services complementary to wealth management and private banking;
- Provide fiduciary and financial concierge services;
- Manage the custody of assets, where applicable;
- Provide services related to account maintenance, administration, data processing, statements, and claims;
- Prevent fraud and ensure security;
- Comply with legal, regulatory, and tax requirements;
- Conduct marketing activities, subject to the Client's consent.
The Company ensures that it uses personal information that is up-to-date and accurate at the time of use. However, it is the Client's responsibility to inform the Company of any changes to their information.
This information may be disclosed to third parties, such as consultants, agents, subcontractors, service providers, affiliates, and other financial institutions, but only to the extent necessary to fulfill the aforementioned purposes and in the normal course of business. This information may also be disclosed outside of Quebec, particularly when the Company uses technology service providers based elsewhere. These providers are subject to the same security and personal information protection requirements.
5. Consent
By providing personal information to the Company or using its services, the Client consents to the collection, use, and disclosure of their personal information for the purposes set out in this policy. This consent is valid for the duration necessary to achieve the intended objectives but may be withdrawn at any time.
However, to the extent that this information is essential for operations, the withdrawal of consent could result in the Company being unable to provide certain products and services to the Client.
6. Cookies and similar technologies
Our website uses cookies and similar technologies to ensure its proper functioning and to improve your browsing experience. The types of cookies that may be used are as follows:
- Essential cookies: they are necessary for the proper functioning of the site (e.g., language preferences, security). They are installed automatically and do not require your consent.
- Analytical cookies: they allow us to measure traffic and improve our content (e.g., Google Analytics or equivalent).
- Third-party cookies: certain service providers integrated into our site may place cookies. These are subject to the privacy policies of those providers.
You can configure your browser to refuse cookies or to be notified when they are being used. Please note that disabling certain cookies may affect the proper functioning of the site or our client portal.
7. Security measures
The Company implements reasonable administrative, technical, and physical security measures to protect personal information against loss, theft, and unauthorized access, use, or disclosure.
8. Retention and destruction
Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected, including to meet applicable legal requirements. Once these purposes have been fulfilled, the Company ensures its secure and permanent destruction.
9. Rights of data subjects
In accordance with applicable law, the Client has the following rights, subject to certain limitations:
- Right of access: obtain access to the personal information the Company holds about them;
- Right to rectification: request the correction of incomplete or inaccurate information;
- Right to a copy: obtain a copy of the personal information held;
- Right to withdraw consent: withdraw consent for the collection, use, or disclosure of their information;
- Right to data portability: receive the computerized personal information provided to the Company in a structured, commonly used technological format, and, where applicable, request that it be transferred to a designated third party.
These requests may be sent in writing to the Company's Privacy Officer. The Company commits to responding within the timeframes prescribed by law.
10. Privacy Officer
The Company has appointed a Privacy Officer. This person ensures compliance with the requirements of this policy and the law within the organization. For any questions, requests for access, rectification, or portability, or for any comments regarding personal information, the Client may contact the Privacy Officer:
Privacy Officer
801 Grande Allée West, Suite 210
Quebec City, Quebec G1S 1C1
Email: conformité@eterna.ca
Phone: 418 692-9292
11. Use of Artificial Intelligence
In the course of providing its services, the Company may use artificial intelligence tools to optimize the efficiency of the services rendered, particularly to support certain activities related to the analysis, processing, and storage of information, risk management, compliance, and record-keeping. Artificial intelligence may also be used during meetings or interactions with clients, for example, to facilitate note-taking, transcription, summarization, and the structuring of information provided, including through voice recording, in accordance with this Privacy Policy and applicable laws.
To mitigate risks associated with the use of such tools, any document, note, communication, or other content generated or assisted by artificial intelligence is subject to review and validation by employees, officers, and relevant registered individuals, as applicable, before being used, filed, or communicated.
The Company monitors artificial intelligence solution providers to ensure compliance with privacy, security, and personal information protection requirements.