Moira Rose Financials Ltd Privacy Policy

Last Updated: April 23, 2025.

Your privacy is important to Moira Rose Financials Ltd. (“Moira Rose Financials Ltd”, “we”, “us” or “our”). We manage your Personal Information in accordance with Alberta’s Personal Information Protection Act (“PIPA”) and other applicable laws. This Privacy Policy explains how we collect, use, disclose, retain, and manage your Personal Information, as defined below, in connection with your access to and use of our products and services. This includes information collected by us through websites, including www.moirarosefinancials.com (the “Website”) and the “Moira Rose Financials” Instagram page (“IG”), emails and telephone calls when providing products or services. This Privacy Policy applies to Moira Rose Financials Ltd. and its subsidiaries, and any person providing services on our behalf. 

A copy of this Privacy Policy is provided to any client, prospective client or visitor to our Website or IG on request.

1. Personal Information

In this Privacy Policy, “Personal Information” means information about an identifiable individual, such as an individual’s name,  email address, and financial information. “Business Contact Information” is not considered Personal Information under PIPA. 

2. Your Consent

We ask for consent to collect, use or disclose client or prospective client Personal Information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.

We ask for your express consent for some purposes and may not be able to provide certain products or services if you are unwilling to provide consent to the collection, use or disclosure of certain Personal Information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in writing (by signing a consent form, by checking a box on a form), or electronically (by clicking a button).

We may collect, use or disclose client Personal Information without consent only as authorized by applicable law. For example, we may not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.

You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to us, by emailing our Privacy Officer using the contact information noted below. If you do not provide us with certain Personal Information, then you might not be able to proceed with your intended interactions or transactions with us or otherwise receive the full benefit of our products and services. We will explain the impact to you at the time to help you with your decision.

If we want to use your Personal Information for any purpose that was not disclosed to you at the time you provided your initial consent, we will seek out your consent at the time of this new purpose.

If you do not agree with any term in this Privacy Policy, do not provide us with any of your Personal Information or use our Website, IG, products or services.

3. Information That Moira Rose Financials Ltd Collects

We collect only the Personal Information that we need for the purposes of providing products or services to our clients or prospective clients. The Personal Information we collect may include, but is not limited to:


We use different methods to collect your Personal Information. We normally collect client Personal Information directly from our clients, for example, by the client filling in forms or corresponding with us through phone, email or otherwise. We also collect Personal Information through automated technologies or interactions, as you navigate through the Website or IG, as further detailed in this Privacy Policy. We may collect your Personal Information from other persons with your consent or as authorized by law. 

We inform our clients, before or at the time of collecting Personal Information, of the purposes for which we are collecting the Personal Information. However, we don’t provide this notification when a client or prospective client volunteers Personal Information for an obvious purpose (for example, providing an email address to subscribe to our newsletter). 

(a) Information You Provide

You may be asked to voluntarily give your Personal Information to us orally, in writing, or by electronic transmission, when you interact with us, including when you apply for an account, subscribe to a newsletter, register to receive information, and apply, register, order or use the products or services we offer. In those circumstances, you can choose not to provide certain requested Personal Information, but then you might not be able to proceed with your intended interaction or transaction with us or otherwise receive the full benefit of the desired product or service.

When you communicate with us, we may monitor and record our telephone and chat conversations (including text/SMS messages) with you for accuracy, quality assurance, and to resolve any concerns. Such records may be disclosed to third parties to verify we are compliant with our contractual obligations with such third parties. You will be provided with a notice at the beginning of our initial call with you that it is being recorded. You can choose not to have the telephone call recorded, and can communicate this to us in writing, by e-mail, or during a call with us.

If you choose to contact us by e-mail or mail, we may retain the content of your communication and our responses. You may also give us other Personal Information when you contact us with questions, inquiries, complaints or suggestions and we may deal with such Personal Information in the same manner as the telephone and chat conversations outlined above.

You also consent to us obtaining additional Personal Information about you from third parties who have been identified to you before we receive such Personal Information, to whom we have provided certain basic Personal Information (eg. Moira Rose Financials Ltd sending identification information to a third party to receive additional comments and or Personal Information regarding the same). In the scenario where you provide your Personal Information to a third party, who then forwards such Personal Information to us, then we will not be liable to you with respect to any consent you may not have provided to such third party for the forwarding of your Personal Information. You are fully responsible for understanding the terms and conditions of the submission of your Personal Information to such third party. Our relationship with you only starts when you engage with our Website, IG, products or services.

(b) Automated Collection
We may automatically collect certain information regarding your use of our Website, IG or other online service, such as the dates and times that you access our Website, IG or online service, including the full Uniform Resource Locaters (URL), the browsers, operating systems, software and devices that you use to access the Website, IG or online service and details of your use of the Website, IG or online service. These details can include products you viewed and searched for, aggregate data about download efficiencies, page interaction information, including scrolling, clicks and other mouse movement data. Further we may collect other technical information such as the IP address, operating system and platform, browser type and version, time zone settings, and location information to estimate your general location.

Our Website, IG, online services, email messages and advertisements may use technologies (e.g. cookies, browser web storage, web beacons, tokens, session recording, session replay, pixels or tags) to collect information that assists us in improving our products and services, customer communications and advertising, and to prevent fraud. We may use information that we collect through technological means to recognize you as a user of our Website, IG or online services, to facilitate and improve your use of our Website, IG or online services, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of our Website, IG or online service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website or IG. More information about cookies used for interest-based advertising is set out in section 4(c) below.

Much of the information that is automatically collected by technological means is non-personal information (because the information does not identify you), and we will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

(c) Financial Information

You acknowledge and agree that any provider of financing or other persons or organizations to which we have disclosed your Personal Information in accordance with this Privacy Policy, may request a credit report for any legitimate purpose associated with your application for credit, extending credit, making product offers, modifying the terms of your credit agreement, collection on your account, or similar services or products. You acknowledge that we may collect information from third party data providers or from publicly available sources for anti-money laundering, background checks, identifying any sanctions that may be applicable to you, identifying whether you are or may become a politically exposed person, to protect our business and comply with our or our partners’ legal and regulatory obligations.

(d) Bank Information

When you use the bank account verification system (“Bank Verification System”) from within our Website, we may, in accordance with this Privacy Policy retrieve your bank account information, including your transaction history (the “Bank Account Information") for purposes set out in this Privacy Policy. We will not be able to view, store, access, or in any way deal with your banking username, password, and multi-factor authentication information (collectively, the “Banking Information") that you input into the Bank Verification System. The Banking Information you input and the Bank Verification System are managed by one of our financial technology partners. We may use the Bank Verification System to periodically obtain your updated Bank Account Information in order to update your confidential profile for use by us for purposes as set out in this Privacy Policy.

Further, you acknowledge and agree that we may periodically retrieve your Bank Account Information and disclose the Bank Account Information to independent businesses, including Moira Rose Financials Ltd, or Moira Rose Financials Ltd’s suppliers or service providers, for purposes as set out in this Privacy Policy.

You must carefully review any agreements you have entered into with your financial institution to confirm whether you are permitted to provide us with your Banking Information, and whether your use of the Bank Verification System may result in any negative consequences for you. We are not liable for any breach of contract or any other liabilities that may result from your use of the Bank Verification System and your disclosure of your Banking Information to us. At this time, we do not provide a service by which we retrieve your Bank Account Information. If and when that changes, we will advise you in writing and obtain your consent.

(e) Information Regarding Referred Transactions

If we refer you to an independent business (e.g. a financial institution) for a proposed transaction (e.g. an investment), then we may collect from that independent business information regarding the transaction to update your confidential profile for use by us as set out in this Privacy Policy.

4. How Moira Rose Financials Ltd Uses Personal Information 

(a) General

We use your Personal Information for purposes relating to or arising from your relationship and transactions with us and as otherwise set out in this Privacy Policy or permitted by applicable law, including to:

(b) Disclosure by Moira Rose Financials Ltd

We may share your Personal Information with Snap Projections Inc and/or their affiliates and subsidiaries (“Snap Projections”), and we may develop, maintain and share a confidential profile for you for use by Moira Rose Financials Ltd and Snap Projections to provide information, products and services to you, to facilitate your dealings with Moira Rose Financials Ltd and as otherwise set out in this Privacy Policy. Snap Projections’ Privacy Policy can be found on their website and may change from time to time. We are not liable for any breach of contract or any other liabilities that may result from our use of Snap Projections’ software and your disclosure of your Personal Information to us. We may also share your Personal Information with our partners for the purposes of providing you with the products and services and any related matters pursuant to this Privacy Policy. We also use a variety of Google programs including gmail, calendar, drive and more. We are not liable for any breach of contract or any other liabilities that may result from our use of any programs we use with Google and your disclosure of your Personal Information to us. Google’s Privacy Policy can be found on their website and may change from time to time. 

(c) Interest-Based Advertising

We may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by third party vendors (such as Google and Facebook) to display advertisements on third party websites and social media sites visited by users of our Website. Advertising vendors (such as Google and Facebook) use technologies, including but not limited to, cookies, pixels, and tokens– unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses our Website – to display ads based on the computer’s past access to our Website. You can opt-out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page. We may also use advertising services provided by third party vendors, whereby we may share general information about preferred customer profiles with such third party vendors, to obtain specific types of customers. Such preferred customer profiles would be created through the aggregation of data from previous customers we obtained through the advertising services of such third party vendors. We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

5. How Moira Rose Financials Ltd Discloses Personal Information 

(a) General

We disclose your Personal Information for purposes relating to or arising from your relationship and transactions with us and as otherwise set out in this Privacy Policy or permitted by applicable law.

(b) Specific Consents

We may disclose your Personal Information in accordance with express or implied consents that you give during your interactions and transactions with us.

(c) Affiliates and Subsidiaries

We may disclose your Personal Information to our affiliates and subsidiaries to assist us in the provision of information, products and services to you, to assist us in using your Personal Information as set out in this Privacy Policy and as otherwise permitted by applicable law.

(d) Referred Transactions

If we refer you to an independent business (e.g. a financial institution) for a proposed transaction (e.g. an investment), then we may disclose your Personal Information (including your credit score that you provided to us, Bank Account Information, and related information) to the independent business to facilitate the proposed transaction. We have no responsibility or liability for the use, disclosure or retention of your Personal Information by the independent business, and the use, disclosure and retention of the disclosed information by the independent business is not subject to this Privacy Policy.

(e) Suppliers and Service Providers

We may disclose your Personal Information to our suppliers and service providers (including fraud prevention services and payment processors) to assist us in the provision of information, products and services to you, to assist us in using your Personal Information as set out in this Privacy Policy and as otherwise permitted by applicable law.

(f) Law Enforcement/Legal Disclosures

We may disclose your Personal Information without your consent as required or authorized by applicable law, including to comply with a subpoena, warrant, court or arbitral order, or litigation disclosure obligation. We have no responsibility or liability for the use, disclosure or retention of your Personal Information by the agencies, independent organizations or other persons to whom we disclose the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy. 

(g) Business Transactions

Subject to applicable law, we may disclose your Personal Information in connection with a proposed or actual business transaction in which we are involved (such as a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of our business or assets), but we will require the information recipient agree to protect the privacy of your Personal Information in a manner that is consistent with this Privacy Policy and applicable law.

6. Location of Personal Information

We and our service providers may process, store and use your Personal Information at facilities in various countries, including Canada, the United States of America and one or more countries in Europe, Asia, or South America. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your Personal Information without notice. By providing your Personal Information to us, you consent to the transfer and access of your Personal Information to facilities located in other countries and the processing and storage of your Personal Information at those facilities. You can request further information about our policies and practices with respect to collection, storage and use of Personal Information outside of Canada by writing to [insert email address]. 

7. Retention of Personal Information 

We retain your Personal Information for the period reasonably necessary for the purposes referenced in this Privacy Policy and to comply with our legal obligations or enforce or protect our legal rights, or a longer period required or permitted by applicable law. 

We will delete or dispose of your Personal Information, or render it non-identifying, when we are no longer reasonably required to retain the information for the purposes referenced in this Privacy Policy. We reserve the right to use any anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

We use appropriate security measures when destroying client Personal Information, including shredding paper records and permanently deleting electronic records.

8. Protection of Personal Information

We use reasonable safeguards – including administrative, physical and technical security, and safety measures – appropriate to the sensitivity of the Personal Information in our possession or under our control to help protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. Nevertheless, security risks cannot be entirely eliminated and we cannot guarantee that your Personal Information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy. We will notify the Office of the Information and Privacy Commissioner of Alberta, without delay, of a security breach affecting Personal Information if it creates a real risk of significant harm to individuals.

The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website or IG, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Website, IG or through electronic transmission. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or IG.

9. Accuracy, Access and Deletion of Personal Information 

(a) Accuracy

We rely on you to ensure that the Personal Information you provide to us is as accurate, complete and up to date as necessary for the purposes for which we use the Personal Information. You will promptly notify us of any changes to your Personal Information using the procedures made available for that purpose by us or by contacting our customer service.

(b) Access and Changes to Personal Information

You may reasonably request access to your Personal Information collected by us and information about our use, disclosure and retention of that Personal Information by submitting a written request to our Privacy Officer using the contact information noted below. You must provide sufficient information in your request to allow us to identify the information you are seeking. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes.

Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your Personal Information in our control and you will be entitled to verify the accuracy and completeness of your Personal Information. You may also request a correction of an error or omission in your Personal Information. 

We will respond to your request within 45 calendar days, unless an extension is granted or as otherwise may be set out in the applicable law. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request. 

We may decline to process a request to change or access Personal Information that is unreasonably repetitive, frivolous, vexatious, or for other reasons permitted by applicable law. If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.

(c) Deletion

You may request we delete your Personal Information in our possession by submitting a written request to our Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, we will delete your Personal Information upon such request.

(d) Verification

We will take appropriate steps to verify the identity of anyone requesting changes to, access to or deletion of your Personal Information. 

10. Non-Personal Information

We create and collect non-personal information (information that is not about an identifiable individual), including information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Website or IG feature. We may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with Personal Information, then we will treat the combined non-personal information as Personal Information for the purposes of this Privacy Policy for as long as the non-personal information is combined with Personal Information.

11. Other Websites and Businesses

Our Website, IG and correspondence (including emails and messages) may include advertisements for products and services (e.g. investments, insurance products) offered by independent businesses (that may have a financial relationship with us) or links to websites, plug-ins, social networks or applications operated by independent businesses (e.g. investment managers, insurance companies). Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We have no responsibility or liability for those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your Personal Information. This Privacy Policy does not directly apply to the collection, use, disclosure and retention of your Personal Information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain Personal Information, please contact the owner or operator of the applicable website, service or business.

By accessing or using the IG, you indicate that you understand, accept, and consent to the practices described in Instagram’s Privacy Policy. Instagram’s Privacy Policy may change from time to time. Your continued use of the IG after IG makes changes indicates that you accept and consent to those changes, so please check Instagram’s Privacy Policy periodically for updates.

12. Personal Information of Minors

The Website and IG is not intended for children under eighteen (18) years of age. No one under 18 may provide any information to or on the Website or IG. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on the Website or IG or on or through any of its features, make any purchases through the Website or IG, use any of the interactive or public comment features of the Website or IG, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at moirarosefinancials @gmail.com

13. Other Matters
(a) Disclaimers, Liability Exclusions/Limitations and Disputes:

The agreements (including any subscription agreement or terms of service or use) that you accept when you apply, register for, order or use our products or services contain important provisions, including provisions disclaiming, limiting or excluding our liability and other persons (including Moira Rose Financials Ltd and service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent that such agreement does not set out the applicable law and jurisdiction for resolution of the disputes, the laws of the Province of Alberta shall apply and all disputes shall be adjudicated by the Court of King’s Bench in Alberta. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or our collection, use, disclosure and retention of your Personal Information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

(b) Changes to this Policy:

We may change this Privacy Policy from time to time. Our collection, use, disclosure and retention of your Personal Information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with us after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your Personal Information as set out in the changed Privacy Policy. You are responsible for periodically visiting the Website, IG and this Privacy Policy to check for any changes.

(c) English Language:

You and Moira Rose Financials Ltd have each expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language. Les parties conviennent et exigent expressement que cette Politique de Confidentialité et tous les documents qui s’y rapportent soient rédigés en anglais.

(d) Contacting Moira Rose Financials Ltd’s Privacy Officer:

Our Privacy Officer is responsible for our employees being trained in our privacy policies and for ensuring we fulfill our privacy commitments. If you have any comments or questions about this Privacy Policy or how we deal with your Personal Information, please contact our Privacy Officer by mail or email at: Moira Rose Financials Ltd PO Box 52119, Edmonton, AB, T6G 2T5 and by email: moirarosefinancials @gmail.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Privacy Policy, and with applicable privacy laws.