Privacy Policy

The Short Version

In plain language: Kenmore Advisor Ltd. collects only the information necessary to respond to your inquiries and deliver consulting services. The firm does not sell, rent, or share personal information with third parties for marketing purposes. Cookies are used to understand how visitors use this website. You may request access to, correction of, or deletion of your personal data at any time by contacting contact@kenadvisorcenter.com.

1. Information We Collect

Kenmore Advisor Ltd. collects personal information through several channels, each with a specific and limited purpose. The firm does not collect data speculatively — every data point serves an identifiable business function tied to delivering consulting services or improving the website experience.

Contact Form Submissions

When you submit an inquiry through our contact page, the firm collects the following information: full name, email address, phone number, firm name, your role or title, approximate assets under management (AUM), number of advisors at your firm, primary area of interest, and any additional details you provide in the message field. This information is used exclusively to respond to your inquiry, scope potential engagements, and ensure that Nathan Brulé — our client relationship manager — can reach you within two business hours.

Website Usage Data

The firm collects anonymized website usage data through cookies and similar technologies, including pages visited, time spent on each page, browser type, device type, referring URL, and geographic region (city/province level only). This data is used to understand how visitors navigate the site and to identify opportunities for improving the user experience. No personally identifiable information is extracted from website analytics data.

Consulting Engagement Data

During active consulting engagements, Kenmore may access and process additional information provided by client firms, including advisor performance data, client segmentation records, compliance documentation, meeting observations, and practice operational metrics. The collection and handling of this data is governed by a separate engagement agreement and mutual non-disclosure agreements executed before any data review commences.

Advisor Portal

Authorized users of the Advisor Login portal provide authentication credentials (email address and password) issued during client onboarding. Portal usage — including login times, documents accessed, and session duration — is logged for security and audit purposes.

2. How We Use Your Information

Kenmore Advisor Ltd. uses the personal information collected for the following specific purposes — and no others:

• Responding to Inquiries: Contact form data is used to understand your practice's needs and to schedule initial discovery conversations. Nathan Brulé coordinates all first-contact responses.
• Delivering Consulting Services: Engagement data — including practice diagnostics, advisor assessments, and compliance reviews — is used exclusively to develop the frameworks, scorecards, and recommendations that form the deliverables of each project. This includes Practice Health Scorecards, due diligence packages, annual reports, term sheets, and other consulting deliverables specified in the statement of work.
• Improving the Website Experience: Analytics data is used to identify navigation patterns, popular content, and areas where the site can better serve prospective clients. No personally identifiable information is used for website optimization.
• Complying with Legal Obligations: Certain data may be retained to comply with securities regulations, tax requirements, or lawful government requests. The firm is registered with the Alberta Securities Commission (Registration No. ASC-2016-04872) and maintains records consistent with National Instrument 31-103 requirements.

Kenmore does not use personal information for automated decision-making, profiling, or any purpose beyond those explicitly described above.

3. Cookies & Tracking Technologies

The Kenmore Advisor Ltd. website uses cookies — small text files stored on your device — to facilitate site functionality and understand usage patterns. The firm categorizes cookies into two types:

Essential Cookies

These cookies are required for basic site functionality, including cookie consent preferences, advisor portal authentication, and session management. They cannot be disabled without impairing the website's core functionality. Essential cookies do not track browsing activity across other websites.

Analytics Cookies

The firm uses Google Analytics to collect anonymized data about website usage, including page views, session duration, traffic sources, and device types. Google Analytics uses cookies to distinguish unique users and sessions. IP addresses are anonymized before processing. Analytics data is retained for 26 months.

What We Do Not Use

Kenmore does not deploy third-party advertising cookies, retargeting pixels, social media tracking scripts, or any technology designed to build behavioral profiles for advertising purposes. The firm has zero advertising technology partnerships — a reflection of the same independence that defines its consulting practice.

4. Data Sharing

Kenmore Advisor Ltd. does not sell, rent, lease, or trade personal information to any third party for any purpose. The firm's revenue comes exclusively from consulting fees paid by advisory firms — never from data monetization. Personal information may be shared only in the following limited circumstances:

• Service Providers: The firm uses third-party providers for website hosting, email delivery, and cloud-based document storage. These providers are contractually bound to process data only on Kenmore's instructions and to implement appropriate security measures. They do not have independent rights to use the data.
• Legal Requirements: Kenmore may disclose personal information if required by law, regulation, court order, or governmental authority. The firm will notify affected individuals of such disclosures unless legally prohibited from doing so.
• With Client Consent: During consulting engagements, certain information may be shared between Kenmore consultants and authorized representatives of the client firm, as specified in the engagement agreement. This sharing is governed by mutual NDAs and confined strictly to the scope of the project.

5. Data Retention

Kenmore retains personal information only as long as necessary to fulfill the purposes for which it was collected, subject to applicable legal retention requirements. Specific retention periods are as follows:

Upon expiration of the applicable retention period, data is securely deleted or anonymized in accordance with the firm's disaster recovery frameworks and data lifecycle management protocols.

6. Your Rights Under PIPEDA and PIPA

As a Canadian privacy law compliant organization, Kenmore Advisor Ltd. respects your rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Alberta Personal Information Protection Act (PIPA). These rights include:

• Right to Access: You may request a copy of the personal information Kenmore holds about you. The firm will respond to access requests within 30 calendar days.
• Right to Correction: If personal information the firm holds about you is inaccurate or incomplete, you may request correction. Kenmore will update its records promptly and notify any third-party service providers who received the corrected data.
• Right to Withdraw Consent: You may withdraw consent for the collection and use of your personal information at any time, subject to legal or contractual restrictions. Withdrawal of consent during an active consulting engagement may limit Kenmore's ability to deliver contracted services — the firm will discuss implications before processing the withdrawal.
• Right to Complain: If you believe Kenmore has not handled your personal information appropriately, you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca or with the Office of the Information and Privacy Commissioner of Alberta (OIPC) at www.oipc.ab.ca.

To exercise any of these rights, contact the firm at contact@kenadvisorcenter.com. Kenmore does not charge a fee for processing access, correction, or deletion requests.

7. Security

Kenmore Advisor Ltd. implements technical and organizational security measures proportionate to the sensitivity of the data processed, consistent with securities industry standards and the firm's own disaster recovery frameworks. These measures include:

• Encryption in Transit: All data transmitted between your browser and Kenmore's servers is encrypted using TLS 1.3 — the current industry standard for transport layer security.
• Secure Cloud Storage: Client engagement data and portal documents are stored on encrypted cloud infrastructure with role-based access controls. Access is restricted to authorized Kenmore team members on a need-to-know basis.
• Regular Security Assessments: The firm conducts periodic security reviews, including vulnerability scanning and access control audits, as part of its broader capability maturity assessment processes.
• On-Site Data Handling: During consulting engagements, client data accessed on-site is never stored on personal devices, transferred via unencrypted channels, or retained beyond the scope and timeline specified in the engagement agreement.
• Professional Liability Insurance: Kenmore carries professional liability and errors & omissions insurance, providing an additional layer of protection for client firms.

No system is perfectly secure — the firm acknowledges this honestly rather than pretending otherwise. However, Kenmore commits to responding to any suspected data breach within 72 hours, notifying affected individuals promptly, and cooperating fully with regulatory authorities as required.

8. Changes to This Policy

Kenmore Advisor Ltd. may update this Privacy Policy from time to time to reflect changes in the firm's practices, technology, legal requirements, or regulatory environment. When changes are made, the "Last Updated" date at the top of this page will be revised accordingly.

For material changes — those that significantly alter how personal information is collected, used, or shared — the firm will take reasonable steps to provide prominent notice. For active consulting clients, this means direct communication via email from Nathan Brulé's desk. For website visitors, material changes will be highlighted via a notice banner on the website for a minimum of 30 days.

Continued use of the website after changes have been posted constitutes acceptance of the revised policy. If you disagree with any changes, you may contact the firm to request deletion of your personal information.

9. Contact Us About Privacy

Questions, concerns, or requests regarding this Privacy Policy or Kenmore's data handling practices should be directed to:

The firm aims to respond to all privacy-related inquiries within 10 business days. For urgent matters — such as suspected unauthorized access to your data — please call directly and ask for Nathan Brulé.