Introduction

This privacy policy has been developed to meet the compliance standards established by Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

Background

Personal Information Protection and Electronic Documents Act (PIPEDA)

PIPEDA is essentially about balance. On one hand, it respects an individual's right to privacy while on the other, recognizing the need for industry and organizations to collect, use and disclose personal information. This law as its name suggests, encompasses two primary objectives. The first objective is to establish rules that govern the collection, use and disclosure of personal information by private sector organizations. The second objective is to acknowledge the validity and legality of electronic documents.

PIPEDA significantly impacts the way we handle the personal information with which we are entrusted. At the same time, it clearly establishes a code of privacy practices that provide Canadians from coast to coast with a mechanism to ensure their personal information is handled respectfully.

PIPEDA is based on the Ten Principles established by the Canadian Securities Administrator's Model Code for the Protection of Personal Information. These principles were recognized as a Canadian standard in 1996 and address the ways in which organizations should collect, use and disclose personal information. They also address an individual's right to access his/her personal information in addition to his/her right to have it amended where appropriate.

In order to govern the commercial information-handling practices within provincial jurisdictions, each province has been encouraged to enact legislation that is substantially similar to the federal law. Quebec enacted comparable legislation in 1994 called an Act Respecting the Protection of Personal Information in the Private Sector. As other provinces enact similar legislation, organizations conducting commercial activity within a province will be subject to the provisions of their provincial laws rather than the federal Act. However, PIPEDA will continue to regulate cross-border, inter-provincial and international trade and commerce.

Policy                                                                                  TOP

Knowledge First Financial Companies
:

For purposes of this policy, a Knowledge First Financial Company or Knowledge First Financial refers, individually and collectively, to Knowledge First Foundation, Knowledge First Financial Inc. and any and all subsidiary and affiliated companies.

The Key Privacy Principles:

Accountability

Knowledge First Financial is responsible for maintaining and protecting the information under its control. In fulfilling this mandate, we have designated a Chief Privacy Officer who is accountable for Knowledge First Financial compliance with these Privacy Principles.

Identifying Purposes

The purposes for which subscriber information is collected shall be identified to the person providing it before or at the time the information is collected.

Consent

The knowledge and consent of the subscriber are both required for the collection, use or disclosure of customer information except where required or permitted by law.

Limiting Collection

The customer information collected must be limited to only those details necessary for the purposes identified. Information must be collected by fair and lawful means.

Limiting Use, Disclosure and Retention

Subscriber information may only be used or disclosed for the purpose for which it was collected unless the subscriber has otherwise consented, or when it is required or permitted by law. Subscriber information may only be retained for the period of time required to fulfill the purpose for which it was collected.

Accuracy

Subscriber information must be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

Safeguarding Customer Information

Subscriber information will be protected by security safeguards that are sensitive to the level of information.

Openness

Knowledge First Financial Companies are required to make information available to their subscribers and/or customers concerning the policies and practices that apply to the management of their information.

Subscriber Access

Upon request, a subscriber shall be informed of the existence, use and disclosure of their information, and shall be given access to it. Subscribers may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.

Handling Subscriber Complaints and Suggestions

Click here for Comments and Complaints.

What Information Is Collected                                            TOP

At Knowledge First Financial, we collect two types of information from our subscribers. With their consent, we collect personal information. We may also collect anonymous/non-personal information.

Type 1: Personal Information

Personal information is information that refers to the Subscriber specifically. With their consent, we may gather personal information from them in person, over the telephone or by corresponding with them via mail or the Internet.

The type of information we usually collect and maintain in our subscriber file includes:

Name
Mailing Address
E-mail Address
Telephone Number
Social Insurance Number
Date of Birth
Place of Employment
Annual Income
Know Your Client Information
Transaction History
Health Information
Bank account information
Residency
Credit card information (name, number, expiry date)

The choice to provide us with personal and financial information is always that of the Subscriber. In financial dealings, however, their decision to withhold particular details may limit the services we are able to provide and make it more difficult for us to advise them or suggest appropriate alternatives.

If we are unable to accommodate their request based on the information that has been provided, we may ask for additional details in order to identify other ways to be of assistance. In some instances,Knowledge First Financial may also maintain a file containing contact history that is used for subscriber inquiry purposes.

Respecting and Responding to Subscribers’ Privacy Concerns

A Subscriber can refuse or withdraw consent to the collection, use and release of their information and when they do so, we will record and respect their choices. We will investigate and respond to their concerns about any aspect of our handling of their information. All inquiries or concerns should be directed to Darrell Bartlett, Chief Compliance Officer, for handling. Note that if Subscribers opt to withdraw their consent, Knowledge First Financial may be required to terminate their contract with the Subscriber.

Type 2: Anonymous/Non-Personal Information

At Knowledge First Financial, we routinely collect anonymous/non-personal information. Anonymous/non-personal information is information that cannot be associated with or traced back to a specific individual. For example, our web servers collect some anonymous/non-personal information automatically when someone visits the Knowledge First Financial Web sites. Gathered electronically, this information may include the pages they visited, the type of web browser they are using, the level of encryption their browser supports and their Internet Protocol address. The anonymous/non-personal information collected may be used for research and analytical purposes. For example, we are able to determine how many times our online privacy policy has been visited but we do not know any specific information about those visitors.

To help us better understand our markets, we may also gather information for analytical purposes by conducting anonymous customer surveys or by extracting demographic information from existing files and from Statistics Canada.

When Information May be Disclosed to Outside Parties

At Knowledge First Financial, we are obliged to keep our Subscriber's personal and financial information confidential except under the following special circumstances:

When Authorized by Them

Client Agreement

A Client Agreement outlines the terms and conditions associated with acquiring specific products or services from Knowledge First Financial. In general, it establishes the rights and obligations of both parties as they relate to the provision of that product or service.

With respect to the matter of privacy, the Client Agreement authorizes us:

  • To collect credit and related financial information (including information related to transactions) from them, from Knowledge First Financial businesses, affiliates and subsidiaries, from credit agencies, from other financial institutions, and from references provided by them.
  • To use personal or business information to determine their financial situation, to provide the services they have requested, to share with other Knowledge First Financial businesses, affiliates and subsidiaries, and to offer additional products and services that might benefit them.
  • To share their information with credit agencies and other financial institutions.
  • To use their Social Insurance Number for reporting to the Canada Customs & Revenue Agency (CCRA), the Department of Human Resources and Skills Development, which administers the Canada Education Savings Grant and for credit agencies matching purposes only.

In some cases, such as when a Subscriber or Prospect Subscriber request services or purchase products over the telephone, they consent to the use and/or disclosure of your information will be obtained verbally. Their consent will be obtained electronically when they request information over the Internet.

When Required by Law

The type of information we are legally required to disclose most often relates to government tax reporting requirements.

In some instances such as a legal proceeding or court order, we may also be required to disclose certain information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so.

When Permitted by Law

There are some situations where we are legally permitted to disclose personal information such as returning a cheque due to insufficient funds, employing reasonable and legal methods to collect a delinquent account, a medical emergency or suspicion of illegal activities.

With Whom We May Share Information                             TOP


Knowledge First Financial businesses, affiliates, and subsidiaries, their employees and service suppliers are all governed by strict standards and policies to ensure our Subscriber information is secure and treated with the utmost care and respect.

At Knowledge First Financial, client information is strictly confidential. With their consent, we will share information with other Knowledge First Financial businesses or suppliers who perform services on our behalf. Unless they authorize us to release it, or release is required or permitted by law, we never sell, lease or trade information about them or their accounts to other parties.


Knowledge First Financial Businesses, Affiliates and Subsidiaries

To ensure our Subscribers benefit from our full range of products and services and as permitted by law, client information is sometimes shared with other Knowledge First Financial businesses, affiliates and subsidiaries. This is done only when the proposed services are available through another member, and only with their consent.

If a Subscriber would prefer not to receive special offers promoting products and services, or that we not share their information, they should let us know by following the instructions in our Opt-Out policy.

Our Employees

In the course of daily operations, access to private, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it. For example, when a Subscriber calls us, visits a branch, or e-mails us, our designated employees will access their information to verify that they are the account-holder and to assist them in fulfilling their financial requests.

As a condition of their employment, all employees of Knowledge First Financial are required to abide by the privacy standards we have established. They are also required to work within the principles of ethical behavior as set out in our internal Compliance & Procedures Manual and must follow all applicable laws and regulations. Employees are informed about the importance of privacy and they are required to sign either a code of conduct or a confidentiality agreement that prohibits the disclosure of any client information to unauthorized individuals or parties.

To reinforce their understanding and commitment to upholding client privacy and confidentiality, employees periodically receive up-to-date literature about our privacy policies, principles and standards.

Unauthorized access to and/or disclosure of client information by an employee of Knowledge First Financial is strictly prohibited. All employees are expected to maintain the confidentiality of customer information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

Sales Representatives

Knowledge First Financial collects client information from Sales Representatives who are associated with an individual independent Agency. These Sales Representatives and associated Agency have signed individual agreements with Knowledge First Financial. These agreements include Confidentiality Statements which prohibits the Sales Representative and those associated with the Agency from sharing any and all information that they receive as part of selling Knowledge First Financial products.

Outside Service Suppliers

At Knowledge First Financial, we sometimes contract outside organizations to perform specialized services such as market research or data processing. Our trusted service suppliers may at times be responsible for processing and handling some of the information we receive from our Subscribers. For example, we supply our printers with the information found on their annual statements.

When we contract our suppliers to provide specialized services, they are given only the information necessary to perform those services. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide. In fact, our suppliers are bound by strict contractual obligations that have been designed to protect the privacy and security of our Subscriber's information. Furthermore, as part of our contract agreements, our suppliers and their employees are required to protect Subscriber information in a manner that is consistent with the privacy policies and practices that we have established.

How Subscribers Can Protect Their Information               TOP

At Knowledge First Financial, we do our utmost to protect and safeguard our Subscriber's personal and financial information. We believe there are measures Subscribers should take as well. The following is a list of things they can do to protect themselves against fraud and uninvited intrusion.

Personal Information

Subscribers should not share personal or financial information such as their Agreement Number, Social Insurance Number or credit card number with others unless they clearly understand the purpose of their request and they know with whom they are dealing.

Suspicious Solicitation

From time to time,Knowledge First Financial will engage in promotional campaigns via telephone, mail and e-mail. If you are unsure of the information you receive from us, please contact us at 1-800-363-7377 to verify that the campaign is a legitimate Knowledge First Financial activity.

If you suspect fraudulent activity is occurring in your neighborhood, contact your local policing authorities.

Accessing and Amending Information                               TOP

At Knowledge First Financial, decisions are often made based on the information we have. Therefore, it is important that our Subscriber's personal and financial information is accurate, complete and up-to-date. As a subscriber, they have the right to access, verify and amend the information held in their personal and financial files.

Accessing Information

A Subscriber may access and verify any of their regular plan or transactional information whenever they wish. Most of this information is available in the form of transaction records. Account statements are generally the best source for this type of information. Additional transactional details about their accounts may be acquired through our Contact Centre staff.

Should a Subscriber have questions concerning a decision we have made, we will inform them of the reasons for those decisions if we are permitted to do so by law. We will also provide them with the name(s) and address (es) of any organizations that provided information to us on their behalf if it was relevant to our final decision.

If for some reason, they are refused access to factual information held in their file, they may challenge this refusal by contacting us.

Amending Their Information

To help us keep your personal information up-to-date, we encourage our Subscribers to amend inaccuracies and make corrections as often as necessary. Despite our best efforts, errors sometimes do occur. Should they identify any incorrect or out-of-date information in their file(s), we will make the proper changes and provide them with a copy of the corrected information. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us.

To Make a Change

To make a change to the personal contact information contained in a Subscriber's file, they should call us at 1-800-363-7377.

Cookies and Knowledge First Financial

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How Cookies are Used

Cookies may be used by Knowledge First Financial Web sites to improve functionality and in some cases, to provide visitors with a customized online experience. The following section describes how Knowledge First Financial Web sites may use cookies.

To Improve Functionality

Knowledge First Financial Web sites may use non-persistent cookies to improve operations and functionality. For example, these cookies improve navigation, maintain connectivity and ensure online service sessions are secured. They do not contain personal or financial information and they are not permanently stored for future use.

Site Personalization
Some Knowledge First Financial web sites use persistent cookies as a means of offering visitors with a personalized experience.

How Cookies are Not Used

Although cookies have the capability of accomplishing a variety of undertakings, Knowledge First Financial Web sites only use cookies when they provide an obvious benefit to you. The following describes how Knowledge First Financial web sites do not use cookies.

Web Site Tracking (What sites you go to)

Cookies or other information tracking technologies is not used to follow the surfing behavior of visitors once they leave Knowledge First Financial Web site. Additionally, tracking information that may be gathered during a visit to an Knowledge First Financial Web site will not be used for promotional purposes.

User IDs and Passwords

For added security; cookies are not used to remember usernames and passwords when accessing highly secured pages. You will be required to provide this information each time you log-on to a secured online service page.

Aggregated Analysis Attributable to an Individual Account Knowledge First Financial does not associate any of the information collected via cookies with your personal or financial information.

Maintaining Personal Information in a Cookie

Cookies cannot be used to gather sensitive information about you or data residing on your computer. These cookies are not designed to identify you personally; rather they are intended to enhance navigation and the security of your session.

We will only ask that you provide personal information if it is required to provide you with the service you have requested. This type of information is collected only with your consent and it is not used for any purpose other than what was originally disclosed to you.

What are Your Choices in Relation to Cookies?

If you would like to browse Knowledge First Financial Web sites, you may do so without accepting cookies. However, you should understand that if you choose not to accept cookies, some Knowledge First Financial Web sites may not function properly or optimally and you will not be permitted to access certain secured sites.

Cookies are widely used and most web browsers are configured initially to accept cookies automatically. If you prefer not to accept cookies, you may adjust your browser settings to alert you when a cookie is about to be sent, or you may configure your browser to refuse cookies automatically. If you would like to learn more about how to set your cookie options, please refer to your browser's documentation or online help for instructions.

Comments and Complaints                                                                 TOP

While we welcome any positive comments you may have, it is equally important for us to know when you have a problem so we can resolve it and retain your confidence.

At the same time, we use your feedback to continuously improve the quality of the products and services we provide to you and other customers.

There are a variety of ways for you to provide positive feedback or express your concerns about your experiences with a member of Knowledge First Financial. We encourage you to get in touch with us in person, by telephone, mail, and fax or via the Internet.

Click here to register a complaint.

Click here  to be added to Knowledge First Financial Do Not Call List

 Click here  to be added to Knowledge First Financial do not Email list

Updating This Policy                                                                             TOP

Any changes to our privacy policy and information handling practices shall be acknowledged in this policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of this document.

Last updated 2011/09/06

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