Privacy Policy
OBJECTIVE & SCOPE OF PRIVACY POLICY
Wan Financials Ltd. (“Wan Financials”) is committed to providing reliable, timely, and accurate financial planning, tax planning, investment management, estate planning, retirement planning, and related services to its customers across Canada. Consistent with the Canada Standards Act Privacy code, the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other applicable law, Wan Financials is dedicated to maintaining high standards of confidentiality with respect to the personal information it collects from its customers.
This Privacy Policy governs personal information collected from our customers for the purposes of providing financial planning, tax preparation, investment management, and other services requested by customers. It does not cover aggregated data from which the identity of an individual cannot be determined, or information that is available from a public source or any information that is specifically excluded by applicable privacy legislation. If a question arises regarding access to your personal information held by Wan Financials, or there is a concern about the manner in which Wan Financials collects, uses, retains and discloses your personal information as one of Wan Financials’s customers, please contact:
DEFINITIONS
“CRA” means the Canada Revenue Agency.
“Consent” means voluntary agreement with the collection, use, retention and disclosure of information for the purposes for which Wan Financials’s services have been retained. When appropriate, express consent is obtained explicitly, in writing, from the Customer.
“Collection” means any and all information obtained from the Customer for the purpose of providing financial planning, tax planning, investment management, estate planning, retirement planning, and related services of Wan Financials and any other information collected for the purpose of providing services requested by a Customer. Collection also means any and all information obtained about the Customer from other third party sources such as Canada Revenue Agency for the purpose of providing these services.
“Customer” means any individual that has retained Wan Financials’s services.
“Disclosure” means making available Personal Information and business information about the Customer to third party government agencies or organizations outside of Wan Financials.
“Organization” means a business, association, partnership, person, or trade union.
“Personal Information” means any information about the Customer, recorded in any form, that is identifiable to that individual either directly or by inference from the information, but does not include the name, title or address, or other information relating to the Customer’s business or place of employment.
“Transfer” means filing or otherwise transferring Personal Information and business information to or from Wan Financials, Canada Revenue Agency or other third parties for the purposes consented to by the Customer.
COLLECTION, USE & TRANSFER OF PERSONAL INFORMATION
Purpose: The purpose for the collection, use and transfer of a Customer’s Personal Information by Wan Financials, its employees, and affiliates, is to obtain all pertinent and necessary information for the preparation and filing of the Customer’s tax returns as required by CRA pursuant to the Income Tax Act, for providing financial planning, investment management, estate planning, retirement planning, and related services, for billing and payment for such services, for the provision of other services requested by a Customer and for legal and regulatory requirements. Wan Financials may also collect and use a Customer’s Personal Information to attempt to understand Customer preferences so that it can offer targeted products or services.
Collection: Personal Information will be collected, to the extent possible, directly from the Customer. Where Personal Information is not available from the Customer, but may be obtained from a financial institution, government agency, or other third party source, Personal Information will be collected from those sources.
Use & Transfer: Personal Information that is collected in the preparation of a Customer’s tax returns or other financial documents may be transferred to Wan Financials’s head office for final review, and will be transferred to CRA where applicable. Wan Financials may disclose to affiliates and third parties to provide the services requested by the Customer. Wan Financials may disclose Personal Information to regulatory authorities as required by law. Wan Financials does not disclose personal information to third parties, except as necessary to perform the services that are requested by a Customer, to comply with regulatory requirements and to manage business functions.
Personal Information is not otherwise used or disclosed to any third party organizations for any reason outside the purpose stipulated above except to the extent authorized by the Customer. Any data that is aggregated for statistical or business monitoring purposes will be rendered anonymous so as not to be identifiable to the Customer.
CONSENT
Wan Financials will request written consent as appropriate and legally necessary. When a Customer signs authorization forms and service agreements, the Customer consents and agrees to the following:
- Wan Financials may collect, use, retain, disclose and/or transfer all Personal Information about the Customer for the purpose and in the manner set out herein;
- The Customer has a right to access or correct data collected by Wan Financials;
- The Customer accepts the risks that may be associated with electronic transmission of their documents and returns;
- Wan Financials has the right to disclose Personal Information about the Customer to government or legal enforcement agencies if Wan Financials determines that the Customer has provided false, misleading, or otherwise incorrect information for fraudulent or illegal purposes; and
- Wan Financials may disclose Personal Information about the Customer if requested by an organization in the midst of any criminal investigation.
You may refuse or withdraw consent to the collection, use or disclosure of information, though doing so may mean that Wan Financials is unable to provide you with products or services that you requested.
ACCURACY
Wan Financials endeavours to ensure that any Personal Information provided by its Customers, and in its possession, is accurate, current and complete as is necessary for the purposes for which the Personal Information is used and transferred. Upon notification by a Customer that the Personal Information collected and used by Wan Financials requires correction or updating, Wan Financials will endeavour to make the necessary corrections promptly.
RETENTION
Wan Financials retains Personal Information as long as Wan Financials believes it is required to retain such information for the purpose of providing financial services, filing completed returns and having such information available in the event that such information is required by Customer to respond to a request by CRA or other regulatory bodies. All Personal Information is stored securely at Wan Financials’s main databases in Canada.
SECURITY
Wan Financials endeavours to maintain physical, procedural and technological security at its offices and information storage facilities to prevent any loss, misuse, unauthorized access, inadvertent disclosure or modification of Personal Information. Wan Financials further protects Personal Information by restricting access to Personal Information to those employees and third parties that have authorized access in order for Wan Financials to provide its services to its Customers. Wan Financials has a policy under which employee misuse of Personal Information is treated as a serious offence for which disciplinary action may be taken.
Regarding electronic transmission of Personal Information, there is no method of transmitting or storing data that is completely secure. Although Wan Financials uses all available technological security in the transmission of Customer documents, all Internet transmissions are susceptible to possible loss, misrouting, interception and misuse.
ACCESS TO PERSONAL INFORMATION
Wan Financials permits a Customer to access and review the Personal Information it holds about the Customer upon receipt of a written request. Wan Financials reserves the right to refuse access to Personal Information about a Customer where the information requested:
- Concerns another individual or Customer of Wan Financials and no consent has been granted by that Customer for such access;
- May harm or interfere with law enforcement activities and other investigative functions of a body authorized by statute to perform such functions;
- Is subject to solicitor-client or litigation privilege; or
- Does not exist, is not held, or cannot be found by Wan Financials.
Where Personal Information will not or cannot be disclosed, the Customer making the request will be provided with reasons for the non-disclosure.
Wan Financials reserves the right to decline to respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, it will consider such factors as the purpose for which the Personal Information was collected and used, the nature of the information being requested by the Customer, and the frequency with which the Customer repeats the same or similar access request.
To protect against fraudulent requests for access, Wan Financials will require sufficient information or proof of identification from the Customer before granting access or making corrections to the Customer’s Personal Information.
Where a request for access to a Customer’s Personal Information is granted, Wan Financials will endeavour to provide the information in question within a reasonable time and no later than 60 days following receipt of the written request and confirmation of the Customer’s identity. Wan Financials may charge a nominal cost to the Customer making the access request to cover photocopying or mailing costs, if necessary.
Where a Customer requests deletion of Personal Information held by Wan Financials, Wan Financials reserves the right to refuse such a request to the extent that its retention of Personal Information is subject to CRA regulations and the Income Tax Act or other regulations.
MARKETING PREFERENCES
Customers may choose how Wan Financials contacts them. Changes should be sent to info@wanwealthmanagement.com. If Customers choose to use the Wan Financials website (wanfinancials.com), Wan Financials and vendors may collect information through the use of cookies or similar technologies. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about the Wan Financials user base as a whole. Wan Financials may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. Wan Financials uses cookies for online customer support and analytics service providers. Users can control the use of cookies at the individual browser level. If a Customer rejects cookies, the Customer may still use the Wan Financials site, but the ability to use some features or areas of the site may be limited.
Wan Financials may partner with a third party ad network to either display advertising on its website or to manage advertising on other sites. Ad network partners may use cookies and web beacons to collect non-personal information about Customers’ activities on Wan Financials related websites to provide targeted advertising based upon Customer interests. If a Customer does not wish to have this information used for the purpose of serving targeted ads, the Customer may opt out. Please note this is an opt out for generic ads, but does not opt a Customer out of being served advertising. Deleting browser cookies and web beacons can assist with removing a Customer’s opt out preferences.
As is true of most websites, Wan Financials gathers certain information automatically and stores it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about Customers.
AMENDMENT TO WAN FINANCIALS PRIVACY POLICY AND PROCEDURE
This Privacy Policy may be amended at any time. Wan Financials recognizes that legal interpretation of PIPEDA and other regulations may impact its privacy policies and procedures.
COMPLAINT PROCESS
Any concern or complaint by a Customer about Wan Financials’s management of the Customer’s Personal Information should be directed to info@wanwealthmanagement.com in writing. All complaints received will be investigated promptly and the Customer will be advised of the results of the investigation. Where corrective or disciplinary action is indicated, Wan Financials will undertake to take such corrective and/or disciplinary action promptly.
If you have any questions about the Wan Financials Privacy Policy, please contact: