Canadian Consumer Privacy Policy

Respecting Your Privacy

We recognize the importance of your privacy and the sensitivity of personal information. Our Privacy Policy outlines how we manage your personal information and safeguard your privacy.

PRIVACY POLICY

G. D. van Wagenen Financial Services, Inc. (“Company”) recognizes the importance of privacy and the sensitivity of personal information. We are committed to protecting your personal information. This Privacy Policy outlines how we manage your personal information and safeguard your privacy.

Effective January 1, 2004, all businesses engaged in commercial activities within Canada must comply with the Canadian government's Personal Information Protection and Electronic Documents Act ("PIPEDA") and the Canadian Standards Association Model Code for the Protection of Personal Information that PIPEDA incorporates. This obligation extends to all Canadian businesses and foreign companies conducting business in Canada, including Company. PIPEDA gives you rights concerning the privacy of your personal information.

Personal information includes information about an individual, but does not include the name, title, business address, phone number, or email address of an employee of an organization.

Company's privacy policy incorporates the 10 internationally recognized principles on which PIPEDA is based.

1. Accountability

Company is responsible for the personal information under our control and has designated a Privacy Officer who is accountable for compliance with our Privacy Policy. We also require that comparable protection of personal information is in place with any third parties used by us to process such information.

2. Identifying Purposes

The purpose for which we collect personal information will be identified at or before the time the information is collected. These purposes presently include:

  • Providing professional services to our clients and their customers
  • Providing general information (non-client specific) to our clients, their customers, and others by way of mailings, faxes, emails, etc.
  • To respond to your request for a call, referral, quote, or to process transactions you request
  • To tell you about products or services we offer
  • To authenticate registered customers

We use Site visitor data to develop, manage, and improve the website. Sometimes we add Site visitor data to Personal Information from registered customers. We may use that information to:

  • Manage the website
  • Help resolve problems
  • Analyze use of the site
  • Tell you about products or services we offer

Any new purposes will be identified prior to use for those purposes. Your consent will be obtained for the new uses, except where such uses are required by law.

3. Consent

Your knowledge and consent are required for the collection, use, or disclosure of personal information, except where inappropriate.

We will specify the reasons for collection, use, or disclosure. Your consent may be obtained, depending on the particular information and circumstances, orally or in writing, implied or expressed. Where information is sensitive we will obtain express consent.

4. Limiting Collection

The collection of personal information will be limited to the amount and type necessary for our purposes. The information will be collected by fair and lawful means. Wherever possible, we will collect your personal information directly from you in the ordinary course of conducting our business.

5. Limiting Use, Disclosure, and Retention

Your personal information shall not be used or disclosed for purposes other than those for which it was collected, except with your consent. Under certain limited circumstances, however, Company may collect and/or use your personal information without your consent. For example:

  • If it is clearly in the individuals best interest and consent is not available in a timely fashion
  • The organization has reasonable grounds to believe the information could be useful when investigating a contravention of federal, provincial, or foreign law and the information would be useful for that investigation
  • The information is for statistical study or research
  • The information is publicly available
  • Knowledge and consent would compromise the availability or accuracy of the information
  • Collection is required to investigate a breach of an agreement

We use your personal information to provide and market our services to you and to administer your account with us. If you advise us that you no longer wish to receive information about our services we will not send any further material. Company does not disclose your personal information to any third party without your knowledge and consent. Under certain limited circumstances, however, Company may disclose your personal information without your consent. For example:

  • If we engage a third party to provide services to us
  • Where it is necessary to establish or collect payment
  • If the information is already publicly known
  • As required by law

Whenever we disclose your personal information to third parties for the purpose of providing services to us, we require such parties to maintain levels of confidentiality and security that are equivalent to our own practices.

Your personal information shall be retained only for as long as is necessary to complete the purposes for which it was collected, or as long as required by law. Personal information that is no longer required is discarded or destroyed using methods that protect your privacy (e.g. by paper shredding and/or deletion of electronic files).

6. Accuracy

The personal information managed by Company shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is being used. If any of your personal information changes, we require details of those changes for our own uses and for the uses of third parties to whom such information is disclosed.

7. Safeguards

Company takes reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification, or disclosure. Among the steps taken to protect your information are:

  • premises security
  • restricted file access to personal information
  • deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access
  • internal password and security policies

8. Openness

Company will make available specific information about its policies and practices relating to the management of personal information.

Updated versions of Company's Privacy Policy shall be posted on our website at www.insuranceservicecenter.com or www.servicesassurance.com. Any queries about this can be directed to Company's Privacy Officer as indicated below:

G D van Wagenen Financial Services, Inc.
Attention: Privacy Officer
Legal Department
6483 City West Parkway
Eden Prairie, MN 55344
Phone: 800-346-9713
Email: vWcompliance@vanwagenen.com

9. Individual Access

Upon request, Company will provide you with details of the existence, use, and disclosure of your personal information and will provide you with reasonable access to that information.

You will be able to amend any of the information for accuracy and completeness. For access to your personal information contact the Privacy Officer by the means indicated in section 8 above.

10. Challenging Compliance

You will be able to address your concerns regarding Company's compliance with the above principles to our Privacy Officer. We will take the steps necessary to resolve the issue, including amending our Privacy Policy and practices, if necessary.

If we are not able to resolve your concern or if you have any other concerns about Company's Privacy Policy and procedures, you may contact the Officer of The Privacy Commissioner of Canada, or, if applicable, the provincial Privacy Commissioner. Company's Privacy Officer will provide you with this contact information upon request.

About this Document

This Privacy Policy spells out the responsibility of Company with regard to its business activities in Canada and your rights as a client or other individual regarding the collection, use, and disclosure of your personal information.

This Privacy Policy is subject to any amendments which will be posted on Company's website and will also be available from Company's Privacy Officer. Please review this page for updates on a regular basis.


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