Privacy Policy

1. Information We Collect

We may collect and process the following data about you:

  • Personal Information: This includes information you provide to us, such as your name, email address, telephone number, mailing address, date of birth, Social Insurance Number (SIN), employment history, income information, beneficiary information, and other information that can be used to personally identify you.
  • Order Information: Personal information related to purchases or attempted purchases made through our website, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
  • Device Information: Technical data, such as your IP address, browser type and version, time zone setting, and other information about your device and your usage of our services or website. We refer to this automatically-collected information as "Device Information."
  • Usage Information: Details about your visits to our website, including the pages you view and the resources you access, what websites or search terms referred you to the Site, and information about how you interact with the Site.

We collect Device Information using the following technologies:

  • Cookies: Data files placed on your device or computer, often including an anonymous unique identifier. For more information about cookies and how to disable them, visit http://www.allaboutcookies.org.
  • Log files: Track actions occurring on the Site and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • Web beacons, tags, and pixels: Electronic files used to record information about how you browse the Site.

When we talk about "Personal Information" in this Privacy Policy, we are referring to both Device Information and Order Information, as well as any other information that can be used to personally identify you.

2. How We Use Your Personal Information

We use your personal information to:

  • Administer pension plans and provide retirement benefits.
  • Communicate with plan members and beneficiaries, including sending you updates, promotional offers, and other information that may be of interest to you.
  • Monitor and analyze usage and trends to improve your experience with our services.
  • Comply with applicable laws, regulations, and legal obligations.

3. Consent

We obtain your consent for the collection, use, and disclosure of your personal information unless an exception applies under Canadian privacy laws. By submitting your personal information, you consent to its collection, use, and disclosure as described in this Privacy Policy. You may withdraw your consent at any time by contacting our Privacy Officer, as detailed in the "Contact Us" section below.

4. Disclosure of Your Information

We may share your personal information with selected third parties, including:

  • Service providers involved in the administration and management of pension plans, such as investment managers, custodians, actuaries, auditors, and other relevant service providers.
  • Law enforcement agencies, government authorities, or other third parties if required by law or if we believe that such action is necessary to protect our rights, property, or safety, or that of our users or others.

5. Access and Correction of Personal Information

You have the right to request access to your personal information held by us and request corrections if necessary. To exercise this right, please contact our Privacy Officer, as detailed in the "Contact Us" section below.

6. Sharing Your Personal Information

We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

7. Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative's ("NAI") educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at: http://optout.aboutads.info/.

8. Do Not Track

Please note that we do not alter our Site's data collection and use practices when we see a Do Not Track signal from your browser.

9. Your Rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident, we note that we are processing your information to fulfill contracts we might have with you (for example, if you make an order through the Site) or otherwise to pursue our legitimate business interests listed above. Please note that your information will be transferred outside of Europe, including to Canada and the United States.

10. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and resolve disputes. When your personal information is no longer needed, we take appropriate steps to securely destroy or anonymize it.

11. Changes

We may update this privacy policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons.

12. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than Canada, specifically on servers located in the United States. By submitting your personal information, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

13. Data Security

We are committed to protecting the security of your personal information. We use appropriate technical and organizational measures to protect your personal information against unauthorized access, use, disclosure, or destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee the absolute security of your personal information.

14. Use of Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to help us understand how users interact with our website. Google Analytics uses cookies, which are small text files placed on your device, to collect information about your use of our website, including your IP address, browser type, pages visited, and time spent on our website. This information is transmitted to and stored by Google on servers in the United States.

Google uses this information to evaluate your use of our website, compile reports on website activity, and provide us with other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can learn more about how Google Analytics collects and processes data by visiting their privacy policy: https://www.google.com/policies/privacy/partners/. If you wish to opt-out of Google Analytics, you can use the Google Analytics opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout.

15. Privacy Officer

We have appointed a Privacy Officer responsible for ensuring compliance with Canadian privacy laws. If you have any questions, concerns, or complaints about this Privacy Policy, our privacy practices, or would like to withdraw your consent, please contact our Privacy Officer as detailed below.

16. Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail using the details provided below:

10 Four Seasons Place, Suite 500, ON, M9B 6H7, Canada

This revised privacy policy is structured with clear headings and sections to improve legibility and comprehension. It covers all necessary aspects of data collection, usage, storage, and user rights while also addressing international data transfers and compliance with various regional laws.