Personal Information Policy
About this document:
This Personal Information Policy spells out the responsibility of Cremasco Financial Inc. and Cremasco Partners Inc. and your rights as our applicant, customer or former customer ("you" or "your"), regarding the collection, use and disclosure of your personal information. This Personal Information Policy is subject to any amendments that will be kept on file at Cremasco Financial Inc. and Cremasco Partners Inc. and will also be available from Cremasco Financial Inc. and Cremasco Partners Inc.'s Privacy Officer by calling 519-836-1791.
Our privacy promise describes in clear language how Cremasco Financial Inc. and Cremasco Partners Inc. ensures the protection of the personal information you entrust to us.
Please read this document carefully. We want you to know how Cremasco Financial Inc. and Cremasco Partners Inc. protect your personal information.
We view our Privacy Promise as more than just a legal obligation:
As a Cremasco Financial Inc. and/or a Cremasco Partners Inc. client, you share important personal information with us. You do this so we can serve you better, knowing we would honour and respect your privacy. Your trust is not misplaced.
What is "personal information"?
"Personal information" is information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.
Why do we collect, use and disclose your personal information?
We collect, use and disclose personal information for one reason: to serve you better. Knowing you better helps us understand your financial needs, communicate effectively with you, and provide you with the services and products you want.
Let's be specific. We collect, use and disclose your personal information to:
- Verify your identity;
- Determine your eligibility and suitability for financial products and services;
- Assess and underwrite insurance and reinsurance risks;
- Determine prices, fees and premiums;
- Determine the suitability of your investments;
- Comply with the law; or
- Comply with tax requirements
Personal information may be collected, used or disclosed for any of theses "Identified Purposes" set out above. If your personal information is not needed for one of the Identified Purposes, we will not use or disclose it without obtaining additional consent from you.
How do we gather your personal information?
- From you, on applications for insurance and investment products or on other forms filled out through telephone, e-mail, face-to-face interviews; for example your name, address, telephone number, e-mail address, occupation, financial and banking information, and health information;
- From your interactions with us; for example through your payment history and underwriting;
- From government and other entities, that have information on your driving records;
- From consumer reporting agencies; for example your credit history
Your consent:
Your knowledge and consent are required before we may collect, use or disclose your personal information. If any of the personal information that we collect is sensitive, such as health information, we will obtain additional written or oral consent from you before collecting, using or disclosing the information.
How do you provide us with your consent?
We accept any of the following as your consent for Cremasco Financial Inc. and Cremasco Partner Inc.'s existing use and future collection use and disclosure of your personal information for the Identified Purposes:
- Your receipt of this Personal Information Policy;
- Your unrestricted provision of information to Cremasco Financial Inc. and Cremasco Partners Inc.;
- Your express written or oral consent as obtained through an application process; or
- Your consent as provided by your authorized representative, such as a legal guardian or power of attorney.
You have the power to say no. How you can withdraw your consent?
You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions. Please note, however, that withdrawing your consent may affect our ability to continue to provide you with the advice, products and services that you have or would like to receive.
To withdraw your consent, you should contact our Privacy Officer, Susan Cremasco, 585 Scottsdale Drive, Guelph, ON N1G 3A7. Unless we hear otherwise from you, you are giving to us your consent for the collection, use and disclosure of personal information as provided in this Policy for the Identified Purposes.
How long do we keep your personal information?
Your personal information is retained only as long as we need it to effectively provide products and services to you and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. Cremasco Financial Inc. and Cremasco Partners Inc. shall use care when storing or destroying your personal information in order to prevent unauthorized access.
How do we protect your personal information?
Whether in electronic or paper-based format, Cremasco Financial Inc. and Cremasco Partners Inc. maintain strict security systems to safeguard your personal information from unauthorized access, disclosure or misuse. As well, when we no longer need your personal information, we take as much care to destroy it as we do when storing it.
In the event that we transfer your personal information to a third party for processing, we contractually require any person or organization providing products or services on our behalf to protect our customers' confidentiality in a manner consistent with our own internal measures, or as required by law.
Your right to access your personal information.
You have a right to access your personal information that we have in our possession or control.
How do you access your personal information?
Please make your request in writing to Susan Cremasco, Cremasco Financial Inc. and Cremasco Partner Inc.'s Privacy Officer, stating as specifically as possible which personal information you are requesting.
We will try to respond to such requests as soon as possible, and will advise you if for some reason we cannot respond right away. Cremasco Financial Inc. and Cremasco Partner Inc. may charge you a reasonable fee for providing access to your personal information, but only after first advising you of the approximate cost.
Keeping your information accurate. A priority.
Cremasco Financial Inc. and Cremasco Partner Inc. strive to ensure that the personal information we have on file about you is as accurate and up-to-date as necessary for the Identified Purposes for which it is to be used. If any information needs to be updated or amended to reflect a change in your situation, we make every effort to update our records. Cremasco Financial Inc. and Cremasco Partners Inc. shall amend personal information that is materially inaccurate or incomplete and, where appropriate, shall endeavour to advise other parties having access to the information in question.
How to contact us? Easy.
Updated versions of this Personal Information Policy are kept on file at Cremasco Financial Inc. and Cremasco Partners Inc. You can direct any queries about this Policy to Cremasco Financial Inc. and Cremasco Partner Inc.'s Privacy Officer at the telephone, e-mail address, or mailing address listed below.
For more information, to file a complaint, to make enquiries, or to opt out of all or parts of this Policy, please contact Cremasco Financial Inc. and Cremasco Partner Inc.'s Privacy Officer:
Cremasco Financial & Cremasco Partner's Privacy Officer
Name: Susan Cremasco
Address: 585 Scottsdale Drive Guelph, ON N1G 3A7
Telephone: 519-836-1791
Fax No: 519-836-8099
E-mail address: privacy@cremasco.com
If you have a complaint, we want to know about it.
If you have a complaint related to this Personal Information Policy or any of our procedures, contact our Privacy Officer. If your complaint is justified, we will take the steps necessary to resolve the issue, including amending our Policy and practices, if necessary.
If we are not able to resolve your concern, or if you have any other concerns about Cremasco Financial Inc. and Cremasco Partner Inc.'s Personal Information Policy and procedures, you may contact the Office of the Privacy Commissioner of Canada or, if applicable, the provincial Privacy Commissioner. Cremasco Financial Inc. and Cremasco Partner Inc.'s Privacy Officer will provide you with the contact information upon request.
