Privacy Policy
Scope and Application of this Privacy Policy
This Privacy Policy and the nine accompanying principles are observed by Cashflow for Life Inc. when collecting and disclosing the personal information of its clientele. The information, including these nine principles, contained in this Privacy Policy must be read and understood as a whole. This Privacy Policy has been customized to personal information issues specifically related to Cashflow for Life Inc.
The general scope and application of the Privacy Policy for Cashflow for Life Inc. is as follows:
1. This Privacy Policy applies to personal information about clients of Cashflow for Life Inc. that is collected, used or disclosed by Cashflow for Life Inc. and which is protected by privacy legislation in Canada.
2. This Privacy Policy does not apply to personal information, such as:
- A client’s name, title, business address, including the business e-mail address, or business telephone or fax number.
- Other information that is not protected by privacy legislation in Canada.
- Other information about a client that is publicly available.
Definitions
Cashflow for Life Inc. – includes Cashflow for Life Inc. and its affiliated companies.
Client – a client is any individual, in their capacity as an individual either personally or through a business carried on as a sole proprietorship or partnership, who uses or applies to use the products and services of Cashflow for Life Inc. The term ‘client’ includes a prospective client who has provided Cashflow for Life Inc. with personal information.
Collection – the act of gathering, acquiring, recording and/or obtaining personal information.
Consent – the voluntary agreement with respect to the collection, use and disclosure of personal information for defined purposes. Consent can either be expressed, implied or deemed and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Cashflow for Life Inc. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction. ‘Deemed consent’ is consent that is deemed to be given pursuant to applicable legislation or other regulations.
Personal Information – information about an identifiable individual, but does not include aggregated information that cannot be associated with a specific individual. ‘Personal information’ also excludes certain information that is excluded pursuant to applicable legislation or regulations, such as publicly available information or business contact information, as and when applicable.
Cashflow for Life Inc.’s Privacy Principles
Cashflow for Life Inc.’s management team is ultimately responsible for ensuring compliance with this Privacy Policy and related privacy legislation in Canada. Cashflow for Life Inc. is responsible for the personal information under its control and shall designate up to two persons to act as privacy officers accountable for Cashflow for Life Inc.’s compliance with the following principles:
Cashflow for Life Inc. is responsible for the personal information in its possession or under its control and shall use appropriate means to protect this personal information while being processed by a third party.
Cashflow for Life Inc. collects personal information for the following identified purposes:
- To establish and maintain a responsible relationship with clients and to provide ongoing service.
- To understand the needs and preferences of its clients and to then provide information related to these needs and preferences to these clients
- To develop, enhance and market its products and services to clients.
- To provide these products and services to clients.
- To manage and develop the business and related operations of Cashflow for Life Inc.
- To meet legal and/or regulatory requirements.
Consent for the Collection, Use or Disclosure of Personal Information
Generally, the knowledge and consent of an individual are required for the collection, use or disclosure of personal information. When obtaining this consent, Cashflow for Life Inc. will use reasonable efforts to ensure the individual is advised of the purpose for using or disclosing this personal information, and this purpose shall be expressed in a way that is reasonably understood by the individual.
Personal information may be collected, used or disclosed without the knowledge or consent of the individual by Cashflow for Life Inc. under certain circumstances in the case of an emergency where the life, health or security of an individual is threatened.
An individual may withdraw their consent at any time, subject to legal or obligations and reasonable notice. Individuals should contact Cashflow for Life Inc. for more information regarding the implications of withdrawing consent.
Limiting the Use, Disclosure and Retention of Personal Information
Except with the expressed consent of the individual or as required by law, Cashflow for Life Inc. will not use or disclose personal information for purposes other than those for which this information was collected.
Personal information may be disclosed by Cashflow for Life Inc. to:
1. A person who in the reasonable judgment of Cashflow for Life Inc. is seeking the information as an agent of the individual.
2. A company or individual employed to perform functions on behalf of Cashflow for Life Inc., such as research or data processing.
3. Another company or individual for the development, enhancement, marketing or provision of any of Cashflow for Life Inc.’s products and services.
4. An agent used by Cashflow for Life Inc. to evaluate the client’s creditworthiness or to collect the client’s account.
5. A credit reporting agency.
6. A public authority or agent of a public authority, if in the reasonable judgment of Cashflow for Life Inc., it appears that there is imminent danger to life or property that could be avoided or minimized by disclosure of the information.
7. A third party or parties where the client consents to such disclosure, where disclosure is permitted by the privacy legislation of Canada or where disclosure is required by other laws.
Furthermore, personal information will be kept by Cashflow for Life Inc. only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the particular circumstance, where personal information has been used to make a decision about a client, Cashflow for Life Inc. will retain, for a period of time that is reasonably sufficient to allow access by the individual, either the actual information or the rationale for making the decision.
Accuracy of Personal Information
Reasonable steps will be taken by Cashflow for Life Inc. to ensure the personal information of its clients is as accurate, complete and up-to-date as is appropriate and reasonable for its purposes.
Compliance Challenges and Inquiries
Procedures for addressing and responding to all inquiries or complaints from individuals about the handling of their personal information shall be maintained by Cashflow for Life Inc.. The designated Privacy Officer will be responsible for addressing these inquiries or complaints. This officer may seek external advice, where appropriate, before providing a final response.
Individuals protected by this Privacy Policy may seek advice from the Office of the Privacy Commissioner in British Columbia by calling 1-250-387-5629, or file a written complaint with this office. All individuals are, however, encouraged to follow Cashflow for Life Inc.’s internal processes and procedures for addressing their concerns.
Please contact our Privacy Officer with any questions or concerns you may have about this Privacy Policy or practices.
Email: info@CashflowForLife.ca
Cashflow for Life Inc. © 2010. All rights reserved.
