Alpha CCO Software Inc. (“AlphaCCO”, “we”, “us”) provides compliance technology solutions to Canadian asset management firms. This Privacy Notice explains how we collect, use, disclose and protect personal information in the course of providing our services.
This Notice applies to:
- visitors of our website;
- users of the AlphaCCO platform; and
- employees, contractors, or representatives of AlphaCCO’s clients who interact with our services.
Personal information we collect
We collect only the information necessary to provide and support our services, including:
- contact information (name, email, role);
- platform login information;
- information entered into the AlphaCCO platform by your firm (e.g., compliance workflows, personal trading data, attestations, requests for approvals); and
- technical information (IP address, browser type, device information).
AlphaCCO does not sell personal information.
How we use personal information
We use personal information to:
- operate and provide our compliance platform;
- authenticate users and manage accounts;
- support, troubleshoot and improve our services;
- meet contractual and legal obligations; and
- secure our systems.
We only use personal information for the purposes for which it was collected unless consent is obtained or the law allows otherwise.
Sharing personal information
We may share personal information with:
- service providers acting on our behalf (e.g., hosting, support, infrastructure security);
- regulatory authorities when required by law;
- IT and data analytics providers;
- law enforcement when required by law;
- law firms, accounting firms and consultants; and
- your firm, which remains responsible for managing its compliance program.
We require all service providers to protect personal information with safeguards equivalent to ours.
Cookies
We use cookies on our website. By using our website, you agree to our use of cookies.
These cookies are necessary for the website to function and cannot be switched off in our systems. These cookies do not store any personally identifiable information.
Personal information retention & destruction
We keep your personal information only as long as needed for business or legal reasons. After that, we destroy it permanently.
Transfers outside Quebec
Personal information processed by AlphaCCO is hosted exclusively on servers located in Quebec.
No transfer of personal information outside Quebec is carried out in the normal course of our activities.
Should transfers outside Quebec become required in the future, AlphaCCO will conduct a Privacy Impact Assessment in accordance with Law 25 and will inform the affected clients accordingly.
After conducting a Privacy Impact Assessment, the information may only be transferred if (1) our assessment establishes that it would receive an adequate level of protection in the new province/country as afforded under applicable privacy laws and (2) we enter into a written agreement with the entity to which the information is disclosed or transferred to ensure accountability.
Security measures
We protect personal information using administrative, physical, and technical safeguards appropriate to its sensitivity.
Sensitive personal information benefits from enhanced protection measures.
Online storage and communication are never completely secure. We encourage you to provide only (a) the personal information you are comfortable with providing a third party, (b) keep watch for communications that are suspicious, and (c) report any suspicious activity to us as soon as possible. As a community, we can all help keep personal information safe.
Your rights
Subject to certain limitations and depending on the privacy laws applicable to you, you may have the following legal rights to your personal information:
- Right to openness about our collection, use and disclosure of your personal information. You have the right to be informed in a manner that is clear, transparent, and accessible.
- Right to access or rectify your personal information held by us.
- Right to be forgotten, i.e., have certain personal information that is held by us destroyed or removed, with certain exceptions and limitations as allowed under law.
- Right to request that we restrict the processing of your personal information.
- Right to object to certain processing of your personal information and request that your personal information be moved to a third-party.
- Right to obtain your personal information in an accessible and transferable format so that you can re-use it for your own purposes with other service providers.
- Where we rely on your consent to process personal information, you may have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.
- Right to receive non-discriminatory treatment for choosing to exercise your rights under applicable privacy legislation.
- Right to file a complaint: you have the right to file a complaint about the way we use or process your information with the applicable data protection authority in your jurisdiction.
Requests may be made by contacting our Privacy Officer.
We will respond to your request within 30 days, subject to some exceptions.
If we refuse an access request in whole or in part, we will provide the reasons for the refusal, indicate the provisions of the applicable law that the refusal is based on, outline remedies that are available to you as a result of the refusal, and tell you the time limit you have to exercise your rights. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
Privacy rights of children
We therefore do not knowingly collect personal information from individuals under the age of eighteen (18). In the event that we learn that we have collected personal information from a child under the age of eighteen (18) we will take the appropriate steps to delete this information. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of eighteen (18).
Changes to this Privacy Notice
We may update this Privacy Notice at any time. If we make significant changes, we will post the new version on our website with the date of the update. By continuing to use this website after changes are posted, you agree to the new terms. If we need to use your information for new purposes, we will ask for your consent.
Addressing your inquiries and concerns
We are happy to provide you with a copy of this Privacy Notice and to discuss any of its content with you.
Privacy incidents
If a privacy incident presents a risk of serious injury, AlphaCCO will notify:
- affected individuals; and
- the Commission d’accès à l’information du Québec (CAI).
AlphaCCO maintains a register of all incidents as required by law.
Contact – Privacy Officer
Attention: Jessica Gendron, COO and General Counsel
Email: jessica.gendron@alphacco.com
Alpha CCO Software Inc.
1 Place Ville-Marie, Suite 3130
Montréal, QC
H3B 3Y2
Last updated: 2026