The Canadian Financial Wellness (CFW Group) Privacy Policy
The CFW Group recognizes the importance of privacy and the sensitivity of personal information. We are committed to protecting any personal information we hold. This Privacy Policy outlines how we manage your personal information and safeguard your privacy.

Your Privacy Rights:
From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act, and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. The Act gives you rights concerning the privacy of your personal information. The CFW Group is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy, and trained our employees about our policies and practices.

Why Does The CFW Group Need Personal Information:
The CFW Group provides consulting services and products to a wide range of clients. In doing so, it produces direct marketing materials concerning its services and products. We also provide our customers with updates for products purchased and retain contact information for this purpose.

What personal information do we collect?
Personal information is any information that identifies you, or by which your identity could be discovered. If we did not collect and use your personal information we could not provide you with consulting services or updates.

How do we collect your personal information?
We collect information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you, at the start of a retainer and in the course of our consulting services. Sometimes we may obtain information about you from other sources: for example:
your creditors
from a government agency or registry
your employer, if we are acting for you, at its request
your accountant.
through site registration and on-line forms.

Consent:
In most cases, we shall ask you to specifically consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your oral consent. Sometimes, your consent may be implied through your conduct with us.

Use of Your Information:
We use your personal information to provide consulting advice and services to you, to administer our client databases and to include you in any direct marketing activities. If you tell us that you no longer wish to receive information about our services, or about new developments or products, we will not send any further material. The CFW Group does not disclose your personal information to any third party to enable them to market their products and services. For example, we do not provide our client mailing lists to other firms.

Disclosure of your Personal Information:
Under certain circumstances, The CFW Group will disclose your personal information:
when we are required or authorized by law to do so, for example if a court issues a subpoena
when you have consented to the disclosure
when the consulting services we are providing to you requires us give your information to third parties (for example a creditor in facilitating a debt solution) your consent will be requested in writing but can also be implied, unless you tell us otherwise
where it is necessary to establish or collect fees
if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our privacy policy
if we retain other businesses in other jurisdictions, on your behalf, and they are bound by our privacy policy
if the information is already publicly known.

Updating Your Information:
Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date. If during the course of the retainer, any of your information changes, please inform us so that we can make any necessary changes.

Is My Personal Information Secure?
The CFW Group takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
premises security
restricted file access to personal information
deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access
internal password and security policies.

Access to Your Personal Information:
You may ask for access to any personal information we hold about you. Summary information is available on request. More detailed requests that require archive, or other retrieval costs, may be subject to our normal professional and disbursement fees.

Correcting Errors:
If CFW Group holds information about you and you can establish that it is not accurate, complete and up-to-date, The CFW Group will take reasonable steps to correct it.

Can I be Denied Access to My Personal Information?
Your rights to access your personal information are not absolute. We may deny access when:
denial of access is required or authorized by law
when granting you access would have an unreasonable impact on other people's privacy
to protect The CFW Group?s rights and property
where the request is frivolous or vexatious.
If we deny your request for access to, or refuse a request to correct information, we shall explain why. The CFW Group does not use your Social Insurance Number as a way of identifying or organizing the information we hold upon you.

Communicating with Us:
You should be aware that e-mail is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information.

Changes to this Privacy Policy:
Since The CFW Group regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.

Requests for Access:
If you have any questions, or wish to access your personal information, please write to our Privacy Contact at:

The CFW Group, 1 Research Drive, Dartmouth, Nova Scotia, B2Y 4M9

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street,
Ottawa Ontario, K1A 1H3
1 800 282 1376