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Privacy Policy

CT Campbell has created this Privacy Policy which explains how and why we collect your data, what that data is, under what circumstances we may disclose or transfer it, and how we store it.

If you have any queries, please contact https://campbellwealth.ca/contacts/

  1. General Information

1.1 Introduction and General Terms

CT Campbell Wealth Management Inc., its subsidiaries and associated businesses (CT Campbell and we) are committed to protecting your Personal Data and your privacy.  We endeavour to ensure that any Personal Data we collect about you will be held and processed strictly in accordance with applicable data protection legislation.

CT Campbell Wealth Management Inc. is headquartered in Ontario Canada, therefore all personal data we process is held in accordance with local laws that implement the Personal Information Protection and Electronic Documents Act (“PIPEDA”) in Canada (“Applicable Local Laws”).

The terms Personal Data, Data Controllerand processinghave the meanings given to them in PIPEDA, unless otherwise indicated.  CT Campbell has created this Privacy Notice which explains how and why we collect Personal Data about you (“Your Data”), what that data is, under what circumstances we may disclose or transfer it, and how long we store it for.

1.2 What does this Notice cover?

At CT Campbell we collect and process Personal Data in a number of ways, so this notice is layered to allow you to find the information that is most relevant to your situation. Please read this general information section then click on the heading below that is most appropriate for your situation, to find out more.

Note that this Privacy Notice does not cover Personal Data, that we may process on behalf of our clients or customers, once business has been placed with Insurers, Fund Companies or other Manufacturers of the products we offer. We cannot erase your Personal Data or provide you with details of the Personal Data held by said Manufacturers without an instruction to do so from our customer so please contact them in the first instance.

Our Privacy Notice also does not cover the information practices of other companies and organizations that advertise our services and that may use cookies, pixel tags and other technologies to serve and offer relevant ads.

1.3 How do I contact CT Campbell?

If you have any queries regarding this notice or complaints about our use of Your Data, please contact us at privacy@campbellwealth.ca or at the address below and we will do our best to deal with your complaint or query as soon as possible.

Chief Privacy Officer
CT Campbell Wealth Management Inc.
Box 77
Ridgeville, ON L0S 1M0

1.4 Will CT Campbell share my Personal Data with anyone else?

Other than as set out below, we hold Personal Data on CT Campbell’s own secure servers & a few safeguarded paper files in Ontario.  In certain limited circumstances, however, it may be necessary for us to share Your Data with the entities set out below. We may also share it with the third parties identified in Section 2 of this Notice.  All third parties with whom we share Your Data are required to protect it strictly in accordance with applicable data protection law and, where the third party is acting as our data processor, they may only use it for specified purposes and in accordance with our instructions.

1.4.1 CT Campbell Group entities

We may share Your Data with entities and their processors, Insurers and Health Insurance providers and their processors. We have adopted an intragroup agreement, which ensures all Personal Data transferred is protected to the same high standards, even if not required by the local data protection legislation.

1.4.2 Where we are required to do so for legal reasons

We will share personal information with companies, organizations or individuals outside CT Campbell if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:

  • meet any applicable law, regulation, legal process or enforceable governmental request.
  • enforce applicable Terms of Service, including investigation of potential violations.
  • detect, prevent or otherwise address fraud, security or technical issues.
  • protect against harm to the rights, property or safety of CT Campbell, our users or the public, as required or permitted by law. 

1.4.3 Where it is necessary in connection with legal proceedings

We may share Your Data with certain third parties where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise our legal rights.

1.4.4 If we sell our business, go out of business, list the company or merge with another company

If CT Campbell is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

1.5 Data Security

We have put in place appropriate security measures to prevent Your Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to Your Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your Data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

1.6 How long will CT Campbell keep my information?

Unless otherwise indicated in Section 2 below, we will hold Your Data on our systems for as long as is necessary for the relevant activity for which it was collected. After this time, we may retain Your Data for a further period of a maximum of 10 years in order to comply with legal record keeping requirements.   In limited circumstances, we may keep Your Data for longer than this if we have identified legal, regulatory or technical reasons why this is necessary.

In the case of marketing communications, your data will be held for as long as is set out in the data receipt you will have received when giving your consent for us to use Your Data.

1.7 How to access, correct or delete Your Data

You can request access to all the Personal Data that CT Campbell has collected from you directly or indirectly, by contacting us using the contact details set out above. You can also request that we correct or delete Your Data in the same way.

1.8 Your duty to inform us of changes

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

1.9 Your choices and opt-outs

You can opt out of receiving marketing emails from us at any time. You can opt out of our marketing emails by clicking the ‘unsubscribe’ link at the bottom of our marketing messages.

Also, all opt out requests can be made by emailing us at privacy@campbellwealth.ca.

Please note that it may take up to 3 days to remove you contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make a request.

1.10 Changes to this Privacy Notice

We keep our privacy notice under regular review. This version was last updated on 28, April 2020.

If material changes are made to the Privacy Notice, for instance affecting how we would like to use Your Data, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes).

  1. How do we collect your data?

At CT Campbell, we collect and process Personal Data in a number of ways.  To help you find the information that is most relevant to your situation, we have separated our policy into a number of sections depending on how you interact with us.

2.1 You are engaging with us as a potential customer or prospect

2.1.1 What does this section cover?

This section of our Privacy Notice sets out information relating to the data we collect from or about you when you interact with us as a prospective customer or if you belong to an organization we have identified as potentially interested in our services.

This includes Personal Data collected in the following ways:

  • when you download our marketing materials through our website or another party’s website;
  • when you use the “Enquiry” form on the website;
  • when you use a live chat function on the website;
  • through our use of cookies;
  • when you request information regarding our services via post, email or telephone;
  • when you contact us or provide Your Data in relation to a marketing event we are running or sponsoring; or
  • when you provide us with your business card.

2.1.2 How do we collect Your Data?

We collect certain Personal Data directly from you at the point at which you interact with us.

We also use public sources, social media, marketing services firms and media publishers to obtain Personal Data relating to people at organizations we believe may be interested in our services. A list of the third party sources we use is available on request.

In some circumstances, we may also obtain your Personal Data as a result of a referral from an existing Client.

Where you have provided your Personal Data to a third party who is collecting it on our behalf, we will collect certain Personal Data about you from that third party.

CT Campbell also collects information about how you use CT Campbell websites or other CT Campbell content online, and the device(s) you use to access these services. This includes collecting unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network device on the internet.

2.1.3 What Personal Data do we collect?

The Personal Data we collect will depend how you are interacting with us but, in general, this will include:

  • First name;
  • Last name;
  • Address;
  • Job Title;
  • Company Name;
  • Email address;
  • Telephone number; and
  • Country

If you voluntarily provide additional Personal Data to us, we will also collect and hold that data in accordance with this Privacy Notice.

2.1.4 What do we use the Personal Data for?

We use Your Data in order to provide you with the information that you have requested, to respond to the request or enquiry you have submitted or to contact you in relation to the event you are attending.  We may also use the Personal Data to contact you about the service in which you have shown an interest or to send you other similar marketing materials. Our legal basis for using Your Data in this way is that it is necessary for the purposes of our legitimate interest of running our business and increasing our customer base.

Where you have indicated your consent to it, we may also use Your Data to send you other online resources or marketing materials which we believe may be of interest to you. Our legal basis for using Your Data in this way is consent. You can unsubscribe from our emails at any time using the “unsubscribe” button at the bottom of the email.

We use the IP addresses and device identifiers we collect through our cookies to identify the location of users, e.g. to deliver a personalized service, block unacceptable use, etc. and for analysis and research purposes so that we may improve the services offered by CT Campbell.  Our legal basis for using Your Data in this way is that it is necessary for the purposes of our legitimate interest of improving our services and our website. For more information, please see our Cookie Policy on CT Campbell’s use of cookies and similar technologies.

2.1.5 Who do we share this Personal Data with?

We use a third party company to support our search engine optimization and website performance and this party may have limited access to the Personal Data you submit through our website or emails as a result.  We also may use a third party automated email provider to send out marketing communications on our behalf.

All third parties with whom we share Your Data are required to protect it in accordance with applicable data protection law and, where the third party is acting as our data processor, they may only use it for specified purposes and in accordance with our instructions.

2.2 You are a customer of CT Campbell

2.2.1 What does this section cover?

This section of our Privacy Notice sets out information relating to the data we collect from or about you when you become, or the organization you work for becomes, a customer of CT Campbell.

2.2.2 How do we collect Your Data

We collect Personal Data about you when you provide such Personal Data to us in order to become a customer of ours. If you work for an organization that has signed up for our services, we may receive Personal Data about you from other members of your organization.

2.2.3 What Personal Data do we collect?

We collect the Personal Data necessary to provide you with the service you have requested or to support the service, which may include the following:

  • First Name;
  • Last Name;
  • Email address;
  • Telephone or mobile number (if voluntarily provided);
  • Access permissions;
  • Whether you are authorized to make changes to our service

If you voluntarily provide additional Personal Data to us, we will also collect and hold that data in accordance with this Privacy Notice.

2.2.4 What do we use the Personal Data for?

We use Your Data to provide you with the services you, or the organization your work for, has requested. This may include using Your Data to manage our relationship with you and for service administration purposes (e.g. to provide you with reports or password reminders, or to notify you that a particular service, activity or online content has been suspended for maintenance). We may also use Your Data to contact you in relation to any support queries you raise. Our legal basis for using Your Data in this way is that it is necessary for the performance of a contract to which you are subject.

We provide regular emails to keep you updated with information about CT Campbell and other services we provide which we think you, or your organization, may be interested in and to let you know about CT Campbell services.  From time to time we may also contact you to ask your views on issues affecting CT Campbell. We may personalize the message content based upon any information you have provided to us and your use of CT Campbell platforms. Our legal basis for using Your Data in this way is that it is necessary for the purposes of our legitimate interest of running and improving our business.

You can opt out from these communications at any time. You may either use the unsubscribe mechanism in any of the communications you receive or contact privacy@campbellwealth.ca

  1. Additional information required under PIPEDA

4.1. Your privacy rights
Under PIPEDA, data subjects have the following rights:

  • Right to access-you have the right to access your personal information held by CT Campbell and how it is used;
  • Right to rectification – if you can successfully demonstrate the inaccuracy or incompleteness of your personal information, we shall amend the information accordingly;
  • Right to withdraw consent – where you have provided your consent to us processing Your Data, you may withdraw your consent at any time. This can be done by emailing privacy@campbellwealth.ca at any time;
  • Right to lodge a complaint – if you feel we have infringed PIPEDA, you may lodge a complaint with the relevant privacy commissioner in Canada as set out below and their websites contain the relevant contact details: