Privacy Policy

CV Canada Ltd. ("we", “our” or “us”) is strongly committed to protecting any Personal Information that we may Process in accordance with this Privacy Policy (“Policy”) and applicable privacy and data protection laws.

This Policy applies to Personal Information Processed by us about our website visitors and business partners, which may include contractors, subcontractors, agents, vendors and suppliers (“you” or “your”). Business partners, in the course of conducting their duties, for or on our behalf, may also have access to and collect Personal Information. This Policy also applies to you if we have a professional or business relationship or connection with you or if you use our services, sign up for events or participate in seminars, subscribe to our publications, complete a survey or contact us with an inquiry using the forms on our website or by email.

As practicing actuaries and other professionals, we have professional and ethical obligations to maintain information we have received from our clients and others in confidence and this Policy supplements such obligations. Any Personal Information that we collect or is provided to us will be Processed by us in compliance with applicable laws.

We are also committed to providing you with understandable and easily available information about our privacy practices. If there are any changes to our privacy practices or applicable laws which necessitates a change to our Policy, we will update this Policy without notice and post a revised Policy to our website. We will indicate at the top of the Policy the date when it was last updated. You may therefore wish to refer to this Policy periodically to review any such changes.

When we refer to “Process” or “Processing” or “Processed” in this Policy, this means carrying out any operation or set of operations on the Personal Information, including collection, obtaining, accessing, recording, organization, storage, adaptation, alteration, retrieving, consultation, use, transferring, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, restriction, erasure or destruction.

Personal Information

"Personal Information" is any information about an identified or identifiable individual or an individual whose identity may be inferred or determined from such information (for example if it is combined with other available information). However, it generally does not include business contact information when used to contact a person in respect of their business role or function.

Limited Processing

Where possible, we strive to limit the amount of Personal Information we collect to that necessary and appropriate for the identified purposes. Accordingly, we collect Personal Information for specified and legitimate purposes, and we will not further Process such information in a manner that is incompatible with those purposes, except with your consent or as permitted or required by applicable laws.

Consent

By using our website or otherwise interacting with us, you consent to the Processing of your Personal Information by us as described in this Policy. If we wish to Process your Personal Information for any additional purposes, we will obtain your express consent (by verbal, written or electronic agreement).

We assume that you have consented to our reasonable collection and use of Personal Information consistent with the purposes for which the information was given, when you initiate contact with us or voluntarily provide Personal Information to us.

In general, in accordance with applicable laws, we do not require your consent to Process your Personal Information because the Processing is necessary or permitted:

to provide you with the information or services that you’ve requested;
to respond to your inquiry;
to protect your vital interests or those of another person;
for our legitimate interests, which include, among others, performance of a contract for services or products requested by you, direct marketing, business development, IT security and fraud prevention; or
to comply with applicable law, legal or regulatory obligations, or a lawful order.

If you do not agree to the terms of this Policy, you should exit the website or other software platform or portal, and cease use of all of our services immediately, or contact us to withdraw your consent where applicable.

What Personal Information do we Collect?

The following is a non-exhaustive list of some of the Personal Information we may collect about you:

Website visitors, others we interact with or people who contact us with an inquiry: name, organization name, title, contact details, publication and content preferences, preferred location, IP address, information provided in the course of communications with us
Business contacts: name, title/position, address, phone number, email address, billing information, account name, insurance policy number.
Business partners: name, title/position, address, phone number, email address, banking information, tax ID numbers.

We do not collect special categories of Personal Information (also known as “Sensitive Personal Information”), without your agreement. We ask that you refrain from sending us this kind of information.

How do we Collect Personal Information?

We, as well as our website, may collect and store certain types of Personal Information through:

Cookies – These are small text files that are used to store small pieces of information on your device when a website is loaded on your browser in order to track your visit to that website. When cookies are used in ways that could identify users then the information is considered Personal Information. Cookies may be used to distinguish you from other users, customize this site according to your preferences, e.g., preferred language, personalize your experience, analyze website usage, and monitor and improve the website. For more information about cookies and how we use them, please see our Cookies Policy.

Online Forms – In order to provide our website visitors with publications, information or requested products or services, visitors may voluntarily submit Personal Information to us for such purposes as subscribing to or downloading publications or newsletters, participating in a seminar or other event, participating in surveys or asking a question. If a subscriber or visitor has subscribed or attended a seminar or other event in the past, we may combine the information submitted for those purposes with information submitted on this website. We provide an ongoing opportunity to unsubscribe or opt out of contact by us. To do so, please contact us as set out below in the section entitled “Contact us”.

Email Communications – To respond to email requests, we may use your email address and any other information you provide.

Purposes for Processing Personal Information

We use Personal Information for the following purposes, among others:

To develop, perform, and deliver products and services;
To perform and deliver webinars;
To send publications to you;
To process transactions for the purchase of goods and services;
To inform or offer prospective clients products or services;
To improve our products, services, programs and website;
To enter and maintain contractual relationships with you;
To comply with our legal, regulatory, contractual and professional obligations or any lawful order;
To respond to your inquiry;
To assist with business development and sales opportunities;
To inform our research and analysis;
To verify the identify of prospective clients; and
To generate anonymized or statistical data.

We do not use automated decision-making (e.g. making a decision about an individual solely by automated means or processing of that individual’s Personal Information without any human involvement).

Transferring and Sharing Personal Information

To the extent we need to share your Personal Information with third parties, we use contractual and other means to provide a comparable level of privacy protection while the information is being Processed or handled by such third parties. We will take steps to ensure that they keep your Personal Information secure and confidential and use it only for the agreed purposes. These third parties are committed by contractual agreements with us to protect Personal Information from unauthorized access, collection, use or disclosure.

We may share your Personal Information with third parties as follows:

Our subsidiaries for the purposes of providing our products and services, subcontracting business support functions, maintaining security, and facilitating your requests;
Service providers and suppliers, subject to contractual requirements, who support our business including contractors and subcontractors providing products and services on our behalf, IT support and security, cloud computing and back up, data storage and processing, and auditing;
Third parties in the event of a potential merger or acquisition, transfer of assets, or business reorganization; and
Law enforcement bodies, regulatory authorities, or the courts, when required as a matter of law or as necessary to protect our rights.

Some of these third parties may be located outside Canada. Consequently, subject to contractual requirements, Personal Information may also be transferred outside Canada to another country and/or outside Québec to another province or territory, where data protection laws may be different. However, we will comply with applicable laws and this Policy when making any such cross-border transfers (for example, by signing appropriate contracts) to ensure your Personal Information is protected.

Protection of Personal Information

You will find information on our data security policy for the Member Area section of this website in the Club Vita Canada Data Security Policy document distributed to Club Vita Canada members.

We use physical, technical and organizational security controls commensurate with the amount and sensitivity of the Personal Information to prevent unauthorized access, use, loss, destruction and damage. Processing is performed in accordance with applicable laws taking into consideration the nature, scope, context and purposes of Processing and the risks of varying likelihood and severity to the rights and freedoms of individuals. While we endeavour to protect all information, Personal Information receives the highest level of protection. We ensure that our employees receive regular training about privacy, information security and data protection. We regularly review all our systems, policies and technologies to ensure that they continue to work effectively to protect your Personal Information.

Retention

We retain Personal Information only as long as necessary to fulfil the purposes for which it was Processed, unless a longer retention period is required and not prohibited by applicable laws. In addition, we may keep Personal Information to deal with legal claims or disputes or as necessary to comply with legal, accounting or regulatory requirements. This period may extend beyond the end of your relationship with us.

If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Information for any other purpose for which we still have legal grounds for Processing such Personal Information (such as for the purposes of complying with a legal obligation or our legitimate interests).

If you want to opt-out from a specific electronic communication service or marketing offer, you can unsubscribe at any time by using the opt-out link on such communication e-mail or send us an e-mail at: [email protected]. Unsubscribing from a special service or product information may not automatically end the Processing of your Personal Information by us unless we receive a specific e-mail request from you in this respect. Any complaints about un-solicited marketing communications can be sent by e-mail to us at the same e-mail address.

When we delete or destroy Personal Information, we use safeguards to prevent unauthorized third parties from gaining access to the Personal Information or compromising it in any way.

Links

This website may present links to other websites. You should be aware that operators of linked websites may also collect your Personal Information and information generated through the use of cookies when you follow such a link to their websites. We are not responsible for how such third parties Process your Personal Information, so it is important that you review their privacy policies before providing them with your Personal Information.

Your Rights

You have the following rights in relation to your Personal Information:

To request access to your Personal Information;
To request that your Personal Information is corrected if it is out of date, inaccurate or incomplete;
To request that your Personal Information is deleted or removed;
To make a complaint to the applicable privacy commissioner or regulator;
To object to or restrict the Processing of your Personal Information (where we don’t need your consent to Process your Personal Information);
To withdraw consent to the Processing of your Personal Information (where we need your consent for such Processing); and
To obtain an electronic file of your Personal Information or have it transferred to another data controller in limited circumstances.

The Personal Information we retain does not contain contact information of individual plan members. Therefore, if we receive a request from a plan member of a client in relation to the exercise of any of their foregoing rights or inquiries pertaining to your Personal Information that we maintain for that plan member, we will refer such request to the applicable client and cooperate accordingly. Similarly, if we are Processing your Personal Information on behalf of your employer (e.g., a business partner of ours) and we receive such a request from you, we may refer the request to your employer and cooperate accordingly.

Asking us to stop Processing your Personal Information or to delete or destroy your Personal Information will likely mean that you are no longer able to use or reap the benefit of our services, including any webinars, events, publications, and surveys, or at least those aspects of the services which require the Processing of the types of Personal Information you have asked us to delete.

Where you request that we rectify or erase your Personal Information or restrict any Processing of such Personal Information, we may notify third parties to whom such Personal Information has been disclosed of such request. However, such third parties may have the right to retain and continue to Process such Personal Information in their own right or on other lawful grounds without your consent.

If you would like to make a request to access or correct your Personal Information, or to exercise any of your other rights as described above, you can contact us at any time using the details set out below.

Contact Us

We have established policies and procedures with the objective of protecting your Personal Information and we have appointed a Privacy Officer to oversee privacy matters for our company. Privacy-related complaints may be registered by contacting the Privacy Officer, who will explain applicable complaint procedures and investigate all complaints. If you have any questions about our privacy policies, please contact our Privacy Officer at:

Privacy Officer

5140 Yonge St., Suite 1700

Toronto, Ontario

M2N 6L7, Canada

Email: [email protected]