# DEBOSKI & CO. Privacy & Cookie Policy

**Last Updated: February 2025**

DEBOSKI & CO. is committed to protecting the privacy and confidentiality of your personal information. This Privacy & Cookie Policy sets out how DEBOSKI & CO. collects, uses, discloses, and retains personal information concerning current and prospective clients, employment applicants and employees who are residents of Canada, as well as visitors to DEBOSKI & CO. websites (collectively, “Individuals” or “you”). This Privacy & Cookie Policy also explains how DEBOSKI & CO. uses cookies and similar technologies on its websites .

## Your Consent

By providing (or authorising another person or organisation to provide) your personal information to DEBOSKI & CO., including when you use DEBOSKI & CO. websites, you consent to the collection, use, disclosure, and retention of your personal information by and on behalf of DEBOSKI & CO. as described in this Privacy & Cookie Policy and as otherwise permitted by applicable law .

If you give DEBOSKI & CO. the personal information of another Individual, then you are solely responsible for complying with all applicable laws, including obtaining the Individual’s valid consent to your collection and disclosure of the personal information to DEBOSKI & CO. and to DEBOSKI & CO.’s collection, use, disclosure, and retention of the personal information as described in this Privacy & Cookie Policy .

DEBOSKI & CO. may also seek additional consents from Individuals for the collection, use, or disclosure of their personal information through account opening documentation and other written agreements. In some circumstances, you may choose not to provide certain requested personal information, but then you might not be able to establish or maintain a relationship with DEBOSKI & CO. or receive some or all of DEBOSKI & CO.’s services .

## What Personal Information DEBOSKI & CO. Collects

When used in this Privacy & Cookie Policy, “personal information” means information about an identifiable individual (i.e., a natural person), but does not include information that is anonymised, business contact information, or information not subject to regulation by Canadian personal information protection laws .

DEBOSKI & CO. may collect the following personal information concerning Individuals:

– DEBOSKI & CO. requires that Individuals who request informational materials supply personal information, including name, address, telephone number and email address prior to receiving such materials
– DEBOSKI & CO. collects relevant personal information on applications and CVs from prospective employees via a careers website
– DEBOSKI & CO. collects other personal information that a prospective client, client, prospective employee, or employee may provide, such as financial statements or other information necessary to analyse a prospective client’s financial situation
– DEBOSKI & CO. websites use cookies and other tracking technologies to collect technical information, such as IP address, browser information, operating system, and clickstream data

With consent, DEBOSKI & CO. may also collect additional personal information including birth date, gender, education, employment history, financial situation, and other relevant details .

## Why DEBOSKI & CO. Uses Personal Information

DEBOSKI & CO. may use personal information for the following purposes:

– To provide investment advisory and portfolio management services for clients and prospective clients
– To meet legal and regulatory requirements and contractual obligations
– For internal record keeping purposes
– To provide informational materials expressly requested by Individuals
– To improve DEBOSKI & CO.’s websites and services
– To authenticate identity and preserve privacy of Individuals contacting DEBOSKI & CO.
– For direct marketing and recruitment purposes where permitted by law
– To monitor and manage employment relationships

## How DEBOSKI & CO. Discloses Personal Information

DEBOSKI & CO. will not sell or lease personal information to third parties. However, DEBOSKI & CO. may disclose your personal information:

– In accordance with your specific consents
– As permitted or required by law, including in response to court orders, subpoenas, or government investigations
– In connection with business transactions such as sales or transfers of business assets

## Transfers of Personal Information Outside of Canada

DEBOSKI & CO. may process and store information collected in Canada at facilities in the United States of America and may transfer personal information to service providers in foreign jurisdictions, including the United States and Costa Rica. The personal information protection laws of these countries may differ from Canadian laws .

## Retention and Withdrawal of Consent

DEBOSKI & CO. retains your personal information for as long as reasonably necessary for the purposes outlined in this Privacy & Cookie Policy, to comply with legal obligations, and to protect legal rights .

You may withdraw your consent to DEBOSKI & CO.’s collection, use, and disclosure of your personal information at any time on reasonable written notice, subject to legal or contractual restrictions .

## Changes to This Privacy & Cookie Policy

DEBOSKI & CO. may change this Privacy & Cookie Policy from time to time. All changes will be effective when the revised Privacy & Cookie Policy is posted on the website, and your continued use of DEBOSKI & CO.’s services confirms your acceptance of the changes .

## Contact Us

If you have any questions or complaints about how DEBOSKI & CO. handles your personal information, please contact DEBOSKI & CO.’s Data Protection Officer:

**DEBOSKI & CO.**
Attention: Data Protection Officer
6500 International Parkway, Suite 2050
Plano, Texas 75093, USA
[email protected]
1 (888) 291-0675

## AI Literacy Statement

**LAST UPDATED: FEBRUARY 2025**

The Company may make available to its employees and contractors AI-powered tools and solutions that are designed to facilitate business functions and related activities. Employees and contractors are encouraged to regularly review the list of AI-powered tools and solutions relevant to their role .
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