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Privacy Policy/Legal Notice

The use of personal information in Canadian commercial activities was protected by new federal legislation under the Personal Information Protection and Electronic Documents Act (PIPEDA), as of January 1, 2014.

The Act is based on the ten privacy principles developed by the Canadian Standards Association (CSA). It is overseen by the Privacy Commissioner of Ontario and the federal court. These ten principles form the ground rules for the collection, use and disclosure of personal information. The Act also addresses the right of individuals to have access to their personal information and to have it corrected if necessary.

Educators Financial Group (“Educators”) is committed to maintaining the accuracy, confidentiality and security of your personal information. As part of our commitment, we follow the Ten Privacy Principles established by the Canadian Standards Association’s Model Code as outlined below.

Principle 1 – Accountability

Educators Financial Group is accountable for all personal information in its possession including any personal information transferred to third parties for processing. We have a designated individual who is responsible for Educators Financial Group’s compliance with the Ten Privacy Principles.

Principle 2 – Identifying Purposes

Educators Financial Group will inform individuals of the purposes for which personal information is collected at or before the time the information is collected.

Principle 3 – Consent

An individual’s knowledge and consent are required for the collection, use or disclosure of personal information except where inappropriate.

Principle 4 – Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by Educators Financial Group. The information shall be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention

Educators Financial Group will only use or disclose personal information for the purposes for which it was collected, unless an individual gives consent to use or disclose it for other reasons. Educators Financial Group may have a legal duty or right to disclose personal information without consent. Personal information may only be retained for the period of time required to fulfill the purpose for which it was collected.

Principle 6 – Accuracy

Educators Financial Group will ensure that the personal information we have on file is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 – Safeguards

Educators Financial Group has security safeguards in place that are appropriate to the sensitivity level of the information.

Principle 8 – Openness

Educators Financial Group will make information available to individuals specific information about its policies and practices relating to the management of their personal information.

Principle 9 – Individual Access

Upon request, Educators Financial Group will inform an individual of the existence, use and disclosure of his or her personal information, and will give the individual access to the information. An individual will be able to verify the accuracy and completeness of their information and have it amended as appropriate.

Principle 10 – Challenging Compliance

Clients may direct any questions or enquiries with respect to the privacy principles outlined above by contacting the Privacy Officer at 1-800-263-9541.

To ensure that Educators Financial Group is abiding to Principle 1 – Accountability, the appointed individual responsible for privacy compliance will implement policies and practices to ensure that:

  • Procedures are established to protect the privacy of personal information
  • Procedures are established to receive and respond to complaints and inquires
  • Educators Financial Group staff are trained and understand the policies and practices

What is Personal Information?

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. In layman’s terms, personal information is information that we collect with your consent that specifically identifies you as an individual.

Obtaining Consent

Educators Financial Group will inform and obtain permission from an individual before or when it collects, uses or discloses personal information.

Educators Financial Group may collect, use or disclose personal information without the knowledge or consent of an individual only in limited circumstances as permitted by law if:

  • It is clearly in the best interests of the individual and consent cannot be obtained in a timely manner( i.e. in an emergency situation where the individual’s life, health or security is threatened)
  • The information is publicly available

What personal information do we collect?

Educators Financial Group will collect only the amount and type of information needed for the purposes documented by Educators Financial Group and identified to the individual. The information we ask for depends on the nature of your request and is limited to that which is required to process your request. The information collected is gathered primarily through our Client Account Application forms. Examples of information collected and maintained in your client file is as follows:

  • Name
  • Age
  • Address
  • Social Insurance Number
  • Date of Birth
  • Name, Address, Social Insurance Number and Date of Birth of your Spouse/Partner, and/or Beneficiary, if applicable
  • Telephone Number(s)
  • School Board / Affiliation
  • E-mail Address
  • Investment Knowledge
  • Investment Income
  • Risk Tolerance
  • Gross Annual Income
  • Net Worth
  • Bank Information (void cheque)

Although we need this information to properly meet your needs, you may at any time, refuse to provide or withhold certain personal information. However, in that case, we will not always be able to deliver a complete range of services, advise you properly or meet some of your needs.

Under certain circumstances, Educators Financial Group may disclose personal information without consent when required or permitted by law. Some examples are: subpoenas, search warrants

  • Bankruptcy – collection of debts
  • Disclosure to a lawyer who represents Educators Financial Group
  • CCRA(Canada Customs and Revenue Agency) – for registration of new accounts and for income tax reporting

Why do we ask for your personal information?

We only collect, use and disclose personal information for the following purposes:

  • To offer and provide access to mutual funds, mortgages and other related products and services;
  • To verify your identity and to ensure the accuracy of information contained in your client record;
  • To establish and maintain an investment account for you;
  • To fully understand your investment needs, objectives and tolerance for risk so that Educators may determine appropriate investment strategies for you;
  • To establish and maintain services that you have requested such as PAC’s (Pre-Authorized Chequing) and/or Group Payroll Deduction Plans;
  • To execute transactions for you such as transferring funds electronically or other means;
  • To establish and maintain print/electronic communications with you through mediums including newsletters, quarterly statements, eNews, special mailings, transaction confirmations, tax receipts and other information as needed to service your account;
  • To verify information previously given by you with any other organization when necessary for the purposes provided in this Notice;
  • To occasionally conduct research to determine how better to serve our clients;
  • To meet legal and regulatory requirements; and
  • To provide you with information about Educators Financial Group products and services.

On request, Educators Financial Group will inform individuals of the existence, use and disclosure of their personal information and provide access to that information to ensure its accuracy and completeness.

Educators Financial Group will update personal information only if it is necessary for the purpose for which it was collected.

Educators Financial Group also relies on individuals to inform us if there are any changes to their personal information. To amend or make a change to your information please contact our office at 1-800-263-9541. While some changes (i.e. address, telephone number, etc.) may be changed verbally over the phone or via our website, other changes require written authorization.

Once notified, we will revise the personal information indicated and if necessary, notify any third parties to whom the incorrect or outdated information was disclosed.

Individuals may access and verify their information (transactional or personal) by reviewing your quarterly account statements, by viewing your account information online or by speaking or meeting with one of our Client Advisory team members.

How do we safeguard your personal information?

At Educators Financial Group we maintain current security standards to ensure that personal and financial information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. All safety and security measures are appropriate to the sensitivity of the information.

Educators may transfer your personal information for the purposes identified in this Notice to our service providers, such as account statement preparation and mailing companies, courier companies and document storage companies. When Educators transfers personal information to our service providers, we ensure by contractual means that the transferred personal information is used only for the purposes for which the service provider is retained and is protected to the same degree as it is when in our possession.

Educators may disclose your personal information to third parties when permitted or required by law, such as disclosure for tax purposes to the Canada Revenue Agency.

Some of our service providers may be located in the United States, and to the extent your personal information is located outside of Canada, it will be subject to any legal requirements in the US applicable to these service providers. For example, there could be lawful requirements imposed on our US service providers to disclose personal information to various US government authorities.

Educators Financial Group may disclose personal information to credit bureaus and mortgage insurers with the individual’s consent.

Educators uses the DocuShare system to scan and maintain client documentation. Only authorized users can access client information on DocuShare.

Access to your confidential information is restricted to and may only be accessed by employees whose professional duties require them to do so.

All Educators Financial Group employees must respect and adhere to our internal privacy policy. As well, employees are required to adhere to IFIC’s Privacy Code and sign a confidentiality agreement prohibiting the disclosure of client information to outside parties.

Educators Financial Group will use professional shredding services when disposing of or destroying personal information in order to prevent unauthorized access to the information.

Online Security

Educators Financial Group uses the R Digital system, designed and maintained by RPM Technologies, which enables investors to access their fund data via the internet, 24 hours a day, 7 days a week. R Digital is equipped with the latest and most sophisticated security mechanisms to ensure unauthorized users cannot access your account information. Data transmitted over this site is secure and private.

Our server environment is managed appropriately and our firewall infrastructure is strictly adhered to. All security practices are reviewed on a regular basis.

Communicating openly

Educators Financial Group will openly communicate to individuals our policies and procedures for the management of personal information. Educators Financial Group will provide the information to individuals in a format that is easy to understand.

Providing access

On request, Educators Financial Group will advise individuals as to the type of personal information Educators Financial Group has in its possession or control, provide individuals with access to that information and inform them as to which third parties the information has been disclosed.

Educators Financial Group will require individuals to be specific about the personal information they are requesting to permit Educators Financial Group, to provide an accurate account of the existence, use and disclosure of the individuals personal information.

Educators Financial Group will respond to an individual’s request not later than 30 days after receiving the request. Educators Financial Group will provide the requested information in a format that is easy to understand.

In certain situations, Educators Financial Group may not be able to provide access to personal information in its possession or control. Some examples are:

  • The information may contain references to other individuals that that could result in a threat to the security of those individuals
  • The information is protected by solicitor-client privilege
  • The information has been collected for the purposes of a legal investigation
  • By providing access to the information, it may reveal personal information about a third party

If Educators Financial Group refuses the individual’s request to access personal information, Educators Financial Group will inform the individual in writing of the refusal and the reasons why.

Links

Our site includes links to other web sites whose privacy policies we don’t control. Once you leave our servers (you can check where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the site you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these sites via a link from the site’s homepage, you should contact the site directly for more information. Educators Financial Group is not responsible for the privacy practices or the content of such web sites.

Cookies

Educators Financial Group collects information through cookies and other similar technologies to give our visitors the best possible experience. Cookies are small files, consisting of letters and numbers, that are stored on your computer, tablet, phone or similar device when you use this device to visit a website. When you visit the website again within a specified period of time, the cookie allows that site to recognize you as a return visitor.

Our site uses remarketing services (including, but not limited to Google AdWords) to advertise on third party websites to previous visitors of our site. This could be in the form of an advertisement on the Google search results page, or a site in the given display networks. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Educators Financial Group website. Of course, any data collected will be used in accordance with our own privacy policy and the privacy policies of the service providers. It is important to note that no personal identifying information is gathered or transmitted with this cookie.

You can set preferences for how Google advertises to you using their respective Ad Preferences pages. You can opt out of interest-based advertising entirely via cookie settings or permanently using a browser plugin. To do this visit the Google Ad Preferences page at  http://www.google.com/settings/ads

Our site also uses web analytics services, which include Google Analytics, ClickDimensions, and Crazy Egg, to be able to create the optimal user experience for our clients and website visitors.

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google Analytics collects first-party cookies, data related to the device/browser, IP address and website activities. The information generated, including your shortened IP address, is transmitted to Google. This information is used to evaluate users’ interactions on our website, compile statistical reports on domain activity, and provide other services related to the site and internet use.

For more information about Google Analytics, please visit https://policies.google.com/technologies/partner-sites. Those wishing to opt out of Google Analytics data collection should use the Google Analytics Opt-out Browser Add-on.

ClickDimensions is a marketing and analysis software provided by ClickDimensions LLC. ClickDimensions allows us to track user activity on our website via cookies. The information about your use of this website collected by ClickDimensions (e.g. pages visited) is transmitted to a ClickDimensions server in the USA, where it is saved and analyzed, with the results being provided to us.

For more information about ClickDimensions’ privacy policy, visit https://clickdimensions.com/about/privacy-policy/. If you wish to opt out of this type of tracking, click the opt-out button below:

Opt-out of ClickDimensions tracking

Crazy Egg is a technology service that helps us understand the most popular user activities on our website (e.g. what links users tends to be interested in and click, what pages users spend the most time on etc.) and this helps us maintain and improve our website and content within it. Crazy Egg collects, stores, and analyzes this information on Crazy Egg’s servers. Any visitor information is transmitted in encrypted form, and pursuant to applicable data transfer provisions further described below. Crazy Egg may process visitor information on behalf of Educators Financial Group, in order to perform analyses and produce reports on our website usage. The interactions that may be recorded or analyzed (“Recorded Interactions”) may include mouse scrolls and clicks by site visitors; keystrokes entered by site visitors; and/or pages viewed or visited by site visitors, including the duration of such visits. Recorded Interactions may also include images of the website that are recorded during the site visitors’ interactions with the website, such as images of forms displayed or populated by site visitors on the website or other multimedia content that may be posted by site visitors. Such site visitor information may also include device information and/or referral information from the site visitors.

If you wish to opt out of this type of tracking, please go to https://www.crazyegg.com/opt-out and follow the instructions on opting out.

Users can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible. If you decide to opt out, you will need to do this for each browser you use.

If we alter our privacy policy in any way, we will post those changes here. If you have questions, want more information or would like to provide us with suggestions, please don’t hesitate to contact us at 416.752.6843, or email: info@educatorsfinancialgroup.ca.

Questions, Concerns and Complaints

As a client of Educators Financial Group you have the right to inquire about any aspect of our company’s privacy policy as it relates to the protection of your personal information. The privacy and confidentiality of your personal information is our highest priority. If you have any questions or concerns please do not hesitate to contact our Privacy Officer at privacyofficer@educatorsfinancialgroup.ca. If you are not completely satisfied with our response, you may file a formal complaint with the Federal Privacy Commissioner.

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