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 insuranceservicecenter.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.