Last Updated: February 26, 2014
This privacy policy (the “Policy”) is intended to inform you of the types of information, including information about you (“Personal Information”), Charter Wealth Management Inc. (“we” or “us”) collects, as well as our policies and practices regarding the collection, use, and disclosure of that information through the web pages at www.charterwealth.com (the “Site”).
Please read this Policy carefully. BY USING THE SITE, YOU ARE ACKNOWLEDGING THAT YOU UNDERSTAND AND AGREE TO THE TERMS OF THIS POLICY, AND CONSENT TO THE MANNER IN WHICH WE MAY COLLECT, USE AND DISCLOSE YOUR PERSONAL INFORMATION.
IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY, PLEASE DO NOT USE THE SITE.
We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on the Policy the date it was updated. Your continued use of this Site following the posting of changes to this Policy will mean that you accept those changes. We encourage you to review this Policy from time to time to make sure that you understand how any Personal Information you provide will be collected, used and disclosed.
This Policy applies solely to information collected by us through the Site. It notifies you of the following:
What Information Do We Collect?
How Do We Use Personal Information That You Voluntarily Provide?
Do We Share Your Information?
Your Privacy Rights — Access to and Control Over Your Personal Information
How to Opt-Out of Targeted Advertising
Does This Policy Apply to Other Websites Linked To Or From the Site?
Do We Collect Information From Children?
What Steps Do We Take To Protect Your Information?
How Is Your Personal Information Transferred and Stored?
What Information Do We Collect?
- Personal Information You Voluntarily Provide to Us – We only have access to and collect Personal Information (such as your name, mailing or billing address, telephone number, email address, and email preferences) that you voluntarily give us via email or through other direct contact from you, such as when you register to use the Site, when you complete a survey or enter a contest on the Site, or when you use any chat room functionality of the Site. This Personal Information is collected for the purpose of providing you with the services you request and responding to inquiries you make through the Site. We use this Personal Information as described below under the heading “How Do We Use Personal Information That You Voluntarily Provide”. We will use certain information collected from your device that is not Personal Information in order to send you information about our products and those of certain third parties, as explained below. When we collect Personal Information from you, we will provide you with the opportunity to refuse to receive product information from (i) us or (ii) third parties. Should you opt to receive this product information, you may change your mind for the future. For example, each message you receive about a product will contain and easy to use “unsubscribe” hyperlink.
- Information Collected by Automated Means – Whenever you use the Site, we, as well as any of our third-party advertisers and/or service providers, may use a variety of technologies that automatically collect information about how you access and use the Site (“Usage Information”). Usage Information may include, in part, your browser type, your operating system, the time you spend on the Site, how many times you visit the Site, and the website you visited immediately before the Site. This Usage Information is collected for the purpose of providing us with information about the use of the Site by you and other users, such as how many visitors visit a specific page on the Site, how long they stay on that page, and which hyperlinks, if any, they “click” on. We use Usage Information to help us to keep the Site fresh and interesting to visitors like you and to tailor content of the Site to your interests. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Information. By using the Site, you consent to our collection of Usage Information from you.
- Device Identifiers – In the course of collecting Usage Information we may also collect your IP address, MAC Address or other unique identifier (each a “Device Identifier”) for the computer, mobile device, Wi-Fi card, or other technology (collectively, “Devices”) you use to access the Site. A Device Identifier is a number that is automatically assigned to your Device when you access a web site or its servers. Our computers identify your Device by its Device Identifier. When you visit the Sites, we may view your Device Identifier. We use your Device Identifier to identify you when you visit our Site so that we can help ensure you have the best possible experience in using our Site. We also may use your Device Identifier to send you advertisements from third parties targeted to your interests. If you want us to stop using your Device Identifiers to send you targeted advertising, please follow the steps in the section below titled “How to Opt-Out of Targeted Advertising.” We may associate your Device Identifier with your other Personal Information that you voluntarily provide or that is automatically collected when you visit the Site. By using the Site, you consent to our collection of your Device Identifier.
- Site Cookies – The technologies used on the Site, including Device Identifiers, to collect Usage Information may include, without limitation:
Cookies – “Cookies” are data files placed on a Device when it is used to visit the Site. We may use cookies to collect and store certain information about you. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them).
Web Beacons – We may also include web beacons (also known as web bugs, Internet tags, pixel tags, tracking pixels and clear GIFs) with the content and advertisements that we deliver to you, which we will use to collect information regarding your interaction with our content and advertisements appearing on our Site. A “web beacon” is a transparent graphic image placed on a web page or in an email, which indicates that a page or email has been viewed or that an email has been forwarded. In addition, a web beacon allows third parties to obtain information, such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. A web beacon may also tell your browser to get content from another server.
We use cookies and web beacons (together, “Site Cookies”) to gather information about how you use our Site. Information gathered through Site Cookies may be considered Personal Information. We use this information to track your interests in order to enhance your experience on our Site, understand your interests and how you use our Site, and track the effectiveness of advertisements on our Site. By using the Site, you consent to our collection of your Personal Information using Site Cookies.
ReachLocal
We also work with a company called ReachLocal Canada, Inc. and its affiliates and parent company in the United States of America (collectively, “ReachLocal”), which assists us in advertising our products and/or services. One of the products that we may purchase from ReachLocal is a retargeting product, which enables ReachLocal to show you advertisements for our Site when you visit other sites in the ReachLocal network or in third-party networks. ReachLocal is able to do this through the use of cookies that are provided by ReachLocal through its third-party partners (“Advertising Cookies”). The sole use of the Advertising Cookies is to show you advertisements for our Site; they are not being used to target you or collect information from you, including Personal Information, in any other way. Moreover, ReachLocal does not link or otherwise connect the information in the Advertising Cookies to any Personal Information that you may have provided to us. Please note that ReachLocal retains the information on the ReachLocal platform for purposes of quality assurance and campaign assessment.
If you have any questions regarding ReachLocal and/or the Advertising Cookies, you are encouraged to contact ReachLocal at privacy@reachlocal.com.
Analytics
We may use two products to analyze activity on our Site. We use ReachLocal’s tracking technology and/or Google Analytics to understand how you use our Site so that we can enhance your experience on our Site. In each case, we provide your Personal Information to ReachLocal and your Device Identifiers to Google for processing and analysis. By using the Site, you consent to our transfer of your Personal Information and/or Device Identifiers to, and the use of such information by, these third parties. If you wish to opt-out of ReachLocal’s tracking technologies, go to http://www.reachlocal.ca/trackingopt-out, and if you wish to opt-out of Google Analytics, go to https://tools.google.com/dlpage/gaoptout?hl=en-GB.
How Do We Use Personal Information That You Voluntarily Provide?
We will use Personal Information you voluntarily provide to provide you with information requested when you contacted us. We will also use your information as follows:
Registration – You may need to first complete a registration form in order to use the Site. During registration, you may be required to provide us with certain Personal Information (such as your name and email address). This Personal Information is used to contact you about the products/services on our Site in which you have expressed interest and to contact you by email about changes to this Policy.
Surveys and contests – From time to time, our Site may request information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore provide us with Personal Information. Information requested may include contact information (such as your name and shipping address), and demographic information (such as your postal code and age). Contact information will be used to notify the winners and award prizes, while demographic information will be used to confirm your contest and survey eligibility. Information gathered through a survey will be used by us for purposes of monitoring or improving the use and satisfaction of this Site.
Customer Service – With your express consent only, we may contact you via email in the future to tell you about specials, new products or services, or changes to this Policy.
Chat – Our Site may use chat functionality to enable us to directly communicate with you through our Site. We will primarily use such information collected through chat functions to assess your needs regarding our products or services and to collect your contact information so that we may contact you to further discuss our products or services.
Do We Share Your Information?
As described above, we share your Personal Information and Device Identifiers with Google and ReachLocal for processing and analysis so that they can help us understand how you use our Site so that we can enhance your experience on our Site. We may also share your Device Identifiers with third parties which will allow those third parties to send you advertisements targeted to your interests.
Except as described in the paragraph above, unless you ask or provide your consent to do so, we will not share your Personal Information with any third party outside of our organization, other than with our service providers and then only as is necessary to fulfill your request (e.g., to ship an order). Only employees of our organization and our service providers who need access to your Personal Information to perform a specific job (for example, billing or customer service) are granted access to your Personal Information. We make our employee aware of the importance of protecting your Personal Information.
We may share anonymous, aggregated, demographic information about Site users with our partners and advertisers. This is not linked, and cannot be linked, to any Personal Information that can identify any individual person.
We will disclose Personal Information to a third party when we believe in good faith that such disclosures (a) are required by law, including, for example, to allow us comply with a court order or subpoena, or (b) is necessary, in our opinion, to: enforce our policies; enforce contest, sweepstakes, promotions, and/or game rules; protect your safety or security, including the safety and security of property that belongs to you; investigate improper use of the site; and/or, protect the safety and security of our Site or sites of third parties.
In addition, if Charter Wealth Management Inc. is to be sold, merged or amalgamated or is to sell or dispose of substantially all of its assets, your Personal Information may be transferred to a potential purchaser if, and to the extent, necessary for the purposes of deciding whether to proceed with the sale and completing the sale. If such a sale, merger, acquisition or disposal is completed, the purchaser may use and disclose your Personal Information only to the extent described in this Policy if the information relates solely to the carrying on of the business or activity or the carrying out of the objectives for which the sale, merger or acquisition took place.
Your Privacy Rights — Access to and Control Over Your Personal Information
We offer you choices regarding our collection, use, and sharing of your Personal Information.
If you receive promotional electronic communications, including emails, from us, you may indicate a preference to stop receiving further promotional communications from us by contacting us directly at the mailing address or at the email address or phone number provided on the electronic communication, or at the email address or phone number given on our Site or as set out below.
As well, you will have the opportunity to “opt-out” of receiving future electronic messages, including promotional messages, by following the unsubscribe instructions provided in the promotional electronic communication you receive or by contacting us directly as set out in the communication, or at the email address or telephone number given on our Site or as set out below. We do not charge for this service, and your unsubscribe request will be processed within 10 days of the date on which we receive it.
You can do the following at any time by contacting us via the email address or phone number given on our Site or via the contact information provided below:
See what Personal Information we have about you, if any;
Request that we change or correct any Personal Information we have about you;
Request that we delete any Personal Information we have about you;
See what Personal Information, if any, has been made available by us to our affiliates, subsidiaries, related organizations, ReachLocal, Google, or any other third parties;
Tell us to stop using your Device Identifiers to send you advertisements targeted to your interests;
Notify us if you do not want us to contact you for marketing and promotional purposes or for any purposes; or
Opt-out of allowing the Site to use ReachLocal’s tracking or Google’s analytical technologies.
If you contact us to do any of the things listed above, we may require you to provide sufficient Personal Information to allow us to identify you and tell you about the existence, use, and disclosure of your Personal Information and this Personal Information will only be used for this purpose. If you contact us about your Personal Information, we will respond to your request within a reasonable time and at no cost to you.
How to Opt-Out of Targeted Advertising
You can set most web browsers to notify you if you receive a cookie, or you may choose to block cookies, though either of those actions may affect your use of our Site. If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your information. For example, by visiting the Digital Advertising Alliance (DAA) Opt-Out Page at http://www.aboutads.info/choices/, you can opt-out of some or all of the ads sponsored by some or all of the Alliance members. Please note that even if you choose to remove your information (via opting out), you will still see advertisements while you are browsing online. However the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The DAA Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies’ pages where you can opt-out of receiving targeted advertisements from those companies.
In addition, if you wish to opt out of any of the Advertising Cookies, you can do this simply by navigating to http://www.reachlocal.ca/opt-out, which will take you to a web page where you will be able to opt out of the Advertising Cookies currently used in connection with ReachLocal’s remarketing product and our Site.
Does This Policy Apply to Other Websites Linked To Or From the Site?
The Site may contain links to other websites. Any Personal Information you provide on linked pages or other sites is provided directly to that third party and is subject to that third party’s privacy policy. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or privacy and security practices and policies of these other websites or any other sites that are linked to or from our Site. We encourage you to learn about the privacy and security practices and policies of these other websites before providing them with Personal Information.
Do We Collect Information From Children?
The Site is not intended for use by children under the age of 18. [ Charter Wealth Management Inc.] does not knowingly collect or use any Personal Information from any children under the age of 13. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make commercially reasonable efforts to delete such Personal Information from our database.
What Steps Do We Take To Protect Your Information?
We take measures designed to protect your Personal Information in an effort to prevent loss, theft, misuse, unauthorized access, disclosure, alteration, copying, modification and destruction of your Personal Information. We provide physical, organizational, technological, electronic, and procedural safeguards to protect Personal Information we process and maintain. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. To protect the confidentiality of Personal Information maintained in your account, if any, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Site by any person using your password. Please advise us immediately if you believe your password has been misused.
How Is Your Personal Information Transferred and Stored?
Personal Information collected when you use the Site may be transferred, processed and used outside of Canada, including in the United States of America, although we remain responsible for your Personal Information. The computers and servers in which we store and process your Personal Information are kept in a secure environment. These computers and servers may be located in countries outside of Canada, including the United States, and may therefore be subject to different laws than those applicable in Canada. While we aim to protect your Personal Information when it is transferred outside of Canada, the laws of other jurisdictions may require the disclosure of your Personal Information to governmental authorities under circumstances that are different than those that apply in Canada and are contemplated under this Policy.
We will store and retain your Personal Information only for as a long as is necessary to fulfill the purpose for which it was collected. If we have disclosed your Personal Information to a third party in accordance with this Policy, we will ensure that it is only retained by that third party for as long as is necessary for that third party to complete the purpose for which we provided it to them.
Laws
This Policy and the privacy practices of Charter Wealth Management Inc. will be subject to the laws of the jurisdiction in Canada in which you reside. Charter Wealth Management Inc. makes no representation that this Policy and our practices comply with the laws of any other country or jurisdiction.
Questions?
If you have any questions about this Policy, please contact our Privacy Officer at Suite 301, 28 Mission Avenue, St. Albert, AB T8N 1H4, (587) 772-0959. If you contact us about your Personal Information, we will respond to your request within a reasonable time and at no cost to you.
