XY Planning Network (“XYPN” or “we”) has created this Privacy Policy to demonstrate our firm commitment to privacy. We are committed to safeguarding your privacy and protecting your personal information. At www.xyplanningnetwork.ca, we offer an online network of fee-only financial planners across Canada who serve clients 50 years of age or greater. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website www.xyplanningnetwork.ca (the “Site”) and the services available through our Site (collectively, the “Services”).
By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy is subject to this Policy, available below, including its applicable limitations on damages and the resolution of disputes. This Policy will notify you of the following:
- What personally identifiable information is collected from you through the website, how it is used and with whom it may be shared.
- What choices are available to you regarding the use of your data.
- The security procedures in place to protect the misuse of your information.
- How you can correct any inaccuracies in the information.
1. Commitment To Privacy
Protecting our users’ personal information is fundamental to the way we do business. This describes XY Planning Networks’ current information management practices and confirms our commitment to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and any applicable provincial/territorial legislation, in order to meet your specific needs and expectations as one of our users. We make every effort to protect the information we collect while delivering insightful, relevant and integrated Services in ways that advance your financial and personal success.
2. Scope
This Policy applies to XY Planning Network. This Policy governs the management of all personal information, including user information that has been and will be collected, maintained, used and disclosed by XYPN in accordance with this Policy.
3. What Information Do We Collect, Use, and Share?
We are the sole owners of the information collected on this site. We only have access to and/or collect information that you voluntarily give us via email or other direct contact from you, as well as automatically through your use of our Site or Services. We will not give, sell or rent this information to anyone. We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request, e.g. to add your membership information.
4. Information We Collect From You Directly
Certain areas and features of our Site and Services may require Membership registration. We only collect your personal information with your consent. To register, you must provide your email address, first name, last name, and a password. We also may collect additional optional information from you, including your location, phone number, and other information entered by you at will; however, you are not required to provide us with this information. XYPN uses this information to contact the user regarding memberships and administrative matters.
Depending on the situation and the sensitivity of the information, you give us consent in different ways. Your consent is express when you actively say yes, such as when you sign a form permitting the collection. Implied consent is usually inferred by the use of our Service.
We may use this information in aggregated form or we may associate it with your username and other personal information that we collect about you.
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Forms
Most of the information we collect about you is provided to us directly from you. The most common way we have of gathering information about you is when you fill in forms at membership registration or when you sign an agreement to access a particular service.
Memberships: If you purchase a membership from us, we request information from you securely. To buy from us, you must provide contact information (like name and email) and financial information (like credit card number, expiration date). This information is used for billing purposes and to fill your membership order. If we have trouble processing an order, we’ll use this information to contact you.
Registration: Access to some of our online content may be restricted. To gain access to it, a user must first complete a registration form to become a member. During registration, a user is required to give contact information (such as name and email address).
Email Newsletters & Alerts: If a user wishes to subscribe to our alerts, updates, newsletters, article digests, etc. we ask for contact and delivery information such as name and email address. All of these email lists provide opt-out facilities online and in the footer of each email broadcast. In some cases, the user is asked to provide optional demographic and personal interest information that is used to keep our content as relevant as possible.
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Electronically
When you deal with us in an online environment we collect certain information, such as your log-in information.
5. Information We Collect Automatically
We may automatically collect the following information about your use of our Site or Services through cookies, third-party analytics, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and or use our Services; and the referring URL, or the webpage that led you to our Site, and the following: access time, browser type, domain name, IP address, page views and referring URL. All of this information is anonymous and not associated with your name or email. Please see the section “What About Cookies and Other Tracking Mechanisms?” below for more information about our use of cookies and other tracking mechanisms.
6. How We Use Your Information
We use the information that we gather about you for the following purposes:
To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill your membership application, and for other customer service purposes. To tailor the content and information that we may send or display to you to personalize your experiences while using the Site or our Services. For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about Sevices or information we think may interest you.
We also may use the information that we learn about you to assist us in advertising our Services on third party websites. To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.
7. How We Share Your Information
We do not sell, lease, or trade client lists or personal information to others. However, we may release your personal information to parties outside XYPN in certain circumstances, which include:
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When Authorized By You:
We may share your personal information as described in this Policy and when you specifically request it.
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Business Transfers:
If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
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In Response to Legal Process:
We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.
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To Protect Us and Others:
We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which XYPN is involved.
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Aggregate and De-Identified Information:
We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
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Our Use of Cookies and Other Tracking Mechanisms:
We use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies: Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
- Persistent cookies: Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
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Third Party Cookies:
We may also engage third parties to track and analyze Site data. We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze Site usage. Such third parties may combine the information that we provide you with other information that they have collected. This Policy does not cover such third parties’ use of the data. This website uses the following cookies:
- Google Analytics: This cookie allows us to see information on user website activities including, but not limited to page views, source, and time spent on the website. The information is depersonalized and is displayed as numbers, meaning it cannot be tracked back to individuals. This will help to protect your privacy. Using Google Analytics, we can see what content is popular on our website, and strive to give you more of the things you enjoy reading and watching.
- Google AdWords: Using Google AdWords code, we are able to see which pages helped lead to form submissions. This allows us to make better use of our paid search budget. We also use remarketing codes to log when users view specific pages, allowing us to provide targeted advertising in the future. Read more about it here: http://www.google.com/policies/technologies/ads/
- Facebook: We use retargeting codes (pixel) to log when users view specific pages, allowing us to provide targeted advertising in the future.
- Hotjar Analytics: We may use this tracking cookie to track and visualize page interactions and user sessions to help improve the overall user experience and layout in the future.
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Third Party Analytics:
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means, such as Hotjar and Facebook Insights, to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. We do not share your personal information with these third parties.
8. Disabling Cookies
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
9. Links To Other Websites
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. XYPN is not responsible for the privacy practices, security practices or the content of any third-party website.
10. Site Intended For Use By Adults
XYPN’s website is intended for use by adults. XYPN does not knowingly collect or publish any information personally identifying any child under age 13. Children under age 13 should not access XYPN’s websites and should not post any information personally identifying themselves anywhere on the websites.
11. Security of Your Personal Information
The security of XYPN’s website and your information is of great importance to XYPN. XYPN has reasonable security measures in place to protect the loss, misuse and alteration of your information under BGPN’s control, but we make no assurances about our ability to prevent any such loss, misuse or alteration, and we shall have no liability to you or any third party from any loss, misuse or alteration. We do not warrant that your access to XYPN’s websites is completely secure.
We have implemented commercially reasonable precautions, including, where appropriate, password protection, data encryption, SSL, firewalls, and internal restrictions on who may access data to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.
You should promptly notify XYPN if your account, user name or password have been lost or stolen. Take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. XYPN will never ask you for your password. If you need a new user name and/or password, XYPN will generate a new password automatically through its content management system and send it to your email.
Administratively, our Policy forms a part of our Code of Conduct. Each employee is required to annually state their continued awareness of our Code of Conduct and their agreement to abide by it. Unauthorized access to, use or disclosure of users’ personal information by an employee is strictly prohibited. All employees are expected to maintain the confidentiality of user information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.
We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain the information varies depending on the product or service and the nature of the personal information.
12. Accessing Your Personal Information
You have the right to access and verify any of your personal information whenever you wish. Please submit a request in writing to Client Services – clientservices@xyplanning.ca. We will advise you in advance if there will be a cost, for example, for requests that require archival or other retrieval costs. We will respond to your request within thirty days. You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
If we are unable to provide access to certain information, we will inform you of the reasons for the decision if we are permitted to do so by law. If you wish further clarification, you may contact Client Services.
13. What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 7 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us. You can do the following at any time by contacting us via the email address shown on our website:
- See what data we have about you, if any.
- Change/correct any data we have about you.
- Have us delete any data we have about you.
- Express any concern you have about our use of your data.
14. Anti-Spam Policy / Opt-Out Choice
We are committed to providing users of XYPN with the choice to receive or not receive emails and/or other communications from XYPN. We strive to comply with the CAN-SPAM Act. We only send commercial emails to new users who have requested or consented to receive emails about our Services. We do not send unsolicited commercial emails (“spam”), buy or sell email lists, or use purchased or harvested email lists. We offer commercial email recipients the opportunity to opt-out of further communications in every email. If you would like to opt-out of receiving further communications, please click the ‘Unsubscribe’ link from a previous email. You may also contact us using one of the following addresses:
Email:
clientservices@xyplanning.ca
Postal mail:
XY Planning Network
39 Lakeshore Rd. E.
Suite 100A
Mississauga, ON
L5G 1C9
Please note that we may not include the opt-out information in non-commercial emails (i.e., emails concerning your membership, system emails, etc.). If you have questions or concerns regarding a non-commercial email, please contact us using the information under “Addressing Your Concerns” below.
15. Online Privacy Policy Only
This online privacy policy applies only to information collected through our website and not to information collected offline.
16. Your Consent
By using our site, you consent to our online privacy policy.
17. Addressing Your Concerns
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at clientservices@xyplanning.ca. You may also mail written notification to the address below:
XY Planning Network
39 Lakeshore Rd. E.
Suite 100A
Mississauga, ON
L5G 1C9
18. Changes To The Privacy Policy
XYPN may change this Policy from time to time in its sole and absolute discretion. Please check regularly for changes. Substantive revisions to this Policy shall apply only prospectively. Contact XYPN if you have any questions about this Policy, the practices of XYPN or your dealings with this website, please contact our client services department using one of the following modes:
XY Planning Network
39 Lakeshore Rd. E.
Suite 100A
Mississauga, ON
L5G 1C9
This policy was last modified on January 24, 2017.