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Privacy Policy

Last updated: March 10, 2026

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Introduction

With the development of new communication tools, it is necessary to pay particular attention to the protection of privacy. That is why we are committed to respecting the confidentiality of the personal information we collect and to complying with applicable laws in Quebec and Canada. In the event of a discrepancy, the rule providing the greatest protection applies.

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Who We Are and Who Is Responsible

Raphaël Guérette (hereinafter referred to as “we”) provides financial services in Quebec and operates this website.

By default, the person with the highest authority within the organization is responsible for the protection of personal information. This responsibility may be delegated in accordance with the rules applicable in Quebec.

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For any questions, access requests, rectification requests, withdrawal of consent, or complaints, you may contact:

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  • Person in charge of personal information protection: Raphaël Guérette​

  • Address: 2540 Daniel-Johnson Blvd., Suite 710, Laval, Quebec H7T 2S3

  • Phone: 450-686-8880, Ext. 6270

  • Toll-free: 1-800-361-7423

  • Fax: 450-686-7778

  • Email: raphael.guerette@sfl.ca

  • Form: contact form available on the website

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Scope of This Policy

This policy applies to personal information we collect in the course of our activities, including through the website, the contact form, appointment requests, our communications by email or phone, and, where applicable, certain informational communications. It does not apply to information about employees, which is covered by other internal policies or notices.

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Types of Information We Collect

Depending on the context, we may collect the following information:

  • first and last name;

  • contact details, such as email address, phone number, and mailing address;

  • information related to your request, your situation, and our communications;

  • information submitted through a contact form or an appointment request;

  • technical information related to the use of the website, such as IP address, device type, browser, pages visited, and date and time of visits;

  • consent preferences regarding cookies and communications.

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Some information may be considered sensitive and may require a higher level of protection as well as explicit consent, including certain financial or health information when required as part of a specific service.

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How We Collect Your Information

We may collect your personal information through the following means:

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  • web forms, including the “Contact Me” form;

  • communications by email or phone;

  • appointment requests;

  • cookies, similar technologies, and audience measurement tools, when used;

  • server logs and security tools.

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Important notice regarding the contact form: please do not submit sensitive, confidential, financial, or medical personal information through the website contact form. If necessary, contact us directly by phone or email.

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Purposes of Collection and Legal Bases

We use your personal information, in particular, to:

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  • respond to your requests;

  • communicate with you;

  • schedule a meeting;

  • provide the requested services;

  • ensure the security, performance, and improvement of the website;

  • comply with our legal, regulatory, and professional obligations;

  • manage, where applicable, your communication preferences.

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In Quebec, we rely in particular on consent, the performance of pre-contractual or contractual measures, and applicable legal obligations, as the case may be. In Canada, certain business activities may also be governed by PIPEDA (Personal Information Protection and Electronic Documents Act).

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Cadre légal applicable au Québec

Au Québec, nous traitons les renseignements personnels conformément à la Loi sur la protection des renseignements personnels dans le secteur privé, telle que modifiée notamment par la Loi 25. Cette loi prévoit notamment des obligations liées à la responsabilité organisationnelle, au consentement, aux incidents de confidentialité, à la portabilité et à certaines demandes de désindexation ou de cessation de diffusion.

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Legal Framework Applicable in Quebec

In Quebec, we process personal information in accordance with the Act respecting the protection of personal information in the private sector, as amended, notably by Law 25. This law includes obligations relating to organizational accountability, consent, confidentiality incidents, portability, and certain requests for de-indexing or cessation of dissemination.

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Consent and Transparency

When required, consent must be clear, free, informed, and given for specific purposes, in plain and clear language. For certain sensitive information, explicit consent may be required depending on the context. At the time of collection, we strive to provide the required information, including the purposes of collection, the methods used, and your rights.

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Communication of Information Outside Quebec

Before communicating personal information outside Quebec, we may carry out, where required, a privacy impact assessment. Such communication may occur only if the assessment demonstrates that the information will receive adequate protection and that an appropriate agreement governs, where necessary, such communication.

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Right to Data Portability

Upon request, and where required by law, we may communicate certain computerized personal information collected from you in a structured and commonly used technological format, or to an authorized person or organization, where applicable.​

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De-Indexing and Cessation of Dissemination

In certain cases provided by law, you may request that the dissemination of personal information be ceased or that a hyperlink attached to your name be de-indexed, where the legal conditions are met.

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Governance

We maintain reasonable personal information governance practices, including practices relating to retention, destruction, security, roles and responsibilities, and the handling of requests or complaints. The contact information for the person responsible appears in this policy.

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Right to Object, Withdraw, Access, and Rectification

Subject to the limits provided by law, you may:

  • object to certain uses of your personal information;

  • withdraw your consent where consent is the applicable legal basis;

  • request access to the personal information we hold about you;

  • request the correction of inaccurate, incomplete, or ambiguous information.

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To exercise any of these rights, please contact the person responsible indicated in the “Who We Are and Who Is Responsible” section. In Quebec and federally, these rights are recognized under the applicable legal frameworks.

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Disclosure to Third Parties

We may disclose certain personal information to service providers when necessary for the purposes described in this policy, for example for website hosting, communication tools, security, technical maintenance, or certain audience measurement tools. In such cases, we require reasonable protective measures.

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We do not sell your personal information.

The website may also contain links to third-party websites, including LinkedIn, SFL Wealth Management, or a portfolio access portal. When you leave our website, the privacy policies of those third-party websites apply.

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Retention and Security

We retain personal information only for as long as necessary for the purposes for which it was collected, subject to applicable legal, regulatory, tax, professional, or ethical obligations. We implement reasonable administrative, technical, and physical security measures to protect personal information against unauthorized access, disclosure, loss, theft, or misuse.

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Cookies

The website may use cookies or similar technologies in order to:

  • ensure proper operation;

  • improve the user experience;

  • analyze traffic and website usage;

  • support certain security or performance features.

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You can configure your browser to refuse certain cookies. However, this choice may affect certain website functionalities.

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Changes to This Policy

We reserve the right to modify this policy at any time to reflect changes in our practices, our services, or applicable legal requirements. The date of the last update appears at the top of the document.

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