Privacy Policy

1. Who We Are

The name of our company is Services Financiers Devon Anderson Inc. ("Company," "we," "us," "our," or "ourselves"). We are a financial services advisory firm committed to helping individuals and families achieve financial security and peace of mind.

Just so we're clear, whenever we say "we," "us," "our," or "ourselves", we're talking about Services Financiers Devon Anderson Inc. and whenever we say "you" or "your," we're talking about the person or entity that has decided to use our services or visit our website. When we talk about our services, we mean any of our platforms, websites, or apps; or any features, products, and all other forms of data and communications.

Our business address is:

• Quebec, Canada
• Email: sfda@devonanderson.ca
• Phone: 514-467-5494

2. What Is This?

This is a privacy policy and the reason we have it is to tell you how we collect, manage, store, and use your information.

We value and respect your privacy. That is why we strive to only use your information when we think that doing so improves your experience in using our services. If you feel that we could improve in this mission in any way, or if you have a complaint or concern, please let us know by sending us your feedback to the email address above.

Our goal is to be as transparent and open about our use of information and data as possible, so that our clients can benefit from both the way they provide information and how we use it. This privacy policy should be read along with our Terms of Service. That's another big part of what we do, so please review it and follow its process for questions or concerns about what it says there.

3. Information Collection and Use

In using our services, you may be asked to provide us a variety of information, some of which can personally identify you and some that cannot. We may collect, store, and share this personal information with third parties, but only in the ways we explain in this policy.

3.1 Personally Identifiable Information: How We Collect It

Personally identifiable information (also, "PII") is data that can be used to contact or identify a single person. Examples include your name, your phone number, your email, your address, and your IP address. We collect the following categories of information:

• Name and contact information
• Email address
• Phone number
• Mailing address
• Date of birth and age
• Employment information and income details
• Financial information (assets, liabilities, investment goals, insurance needs)
• Family information (marital status, dependents, beneficiaries)
• Social Insurance Number (when required for specific financial services)
• Payment information, including credit card information
• Company information (for business clients)
• IP addresses, browser information, timestamps, page views and load times
• Referrers, device type and browser information
• Information collected through our contact forms and document uploads

3.2 How We Use Your Information

We use your personal information in the following ways:

• To provide you with financial advisory and insurance services
• To assess your financial needs and recommend appropriate solutions
• To process insurance applications, policy renewals, and claims
• To contact you via email or phone to inform you of service issues, new features, updates, offers, and billing issues
• To communicate about your account, policies, and services
• To comply with legal, regulatory, and professional obligations
• To improve our website performance and user experience
• To tailor our services to your needs and the way you use our services
• To process payments
• To determine how to improve our services and product offerings
• To market our services to interested customers (with your consent)
• To maintain records for business, legal, and regulatory purposes
• For advertising purposes

3.3 Who We Share Your Information With and Why

We only share your information with third parties in the following ways and for the following purposes:

• Payment Processors: We share your email, credit cardholder name, and card number and related information to run the initial and subsequent payments for our services. Your credit card information is stored with the payment processor; we do not retain your credit card information internally.
• Insurance Companies and Financial Institutions: We share necessary information to process insurance applications, policies, claims, and financial services on your behalf.
• Professional Advisors: We may share information with accountants, lawyers, or other professionals when necessary to provide comprehensive financial services to you.
• Service Providers: We share data with third-party service providers who assist with website hosting, analytics, email communications, and customer relationship management. These providers are contractually obligated to maintain confidentiality.
• Legal Requirements: We will share all collected information to the extent necessary and as required by law or to comply with any legal obligations, including defense of our company, tax reporting obligations, and regulatory oversight.

3.4 Your Choices in What Information You Share

For users who do not register for our services or a business account, we will not collect that user's personally identifying information unless that personally identifiable information is provided voluntarily through our contact forms or other communication channels. However, to provide comprehensive financial services, certain information is necessary, and the inability to provide such information may limit our ability to serve you effectively.

4. How Long We Keep Your Information

We will retain your personally identifiable information until you request in writing that we delete or otherwise remove your personally identifiable information as part of our normal business processes, subject to legal and regulatory requirements.

As a financial services firm, we are subject to specific retention requirements. Financial and insurance records are typically retained for a minimum of seven (7) years as required by Canadian law and professional regulations. After this period, we will securely destroy or anonymize your information unless we have a legitimate reason to retain it longer.

We may develop or amend a policy for deleting PII on a recurring timeline at some point in the future to comply with evolving regulations, but retention will always meet or exceed minimum legal requirements.

5. Where We Keep and Transfer Your Information

Our business is operated in Canada and our servers are located in Canada. This is where your data and information will be stored. Due to the nature of internet communications, however, such data could pass through other countries as part of the transmission process.

Please be aware if you are a citizen of another country that your information will be stored and processed in Canada. Canada has strong data protection laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Law 25.

Our processing of personal data from individuals is not targeted to reveal race; ethnicity; political, religious, or philosophical beliefs; trade union memberships; health; sexual activity; or sexual orientation. If you would like more information about this, please email us at the address provided above.

6. Your Rights to Information

According to the laws of Canada and Quebec (except for limited exceptions, where applicable), you have the right to:

• Be informed about your data and its processing
• Have access to your data
• Correct any errors in your data
• Erase data from our records (subject to legal retention requirements)
• Restrict processing and use of data
• Data portability
• Object to the use of your data, including for the purpose of automated profiling and direct marketing
• Make decisions about automated decision making and profiling
• Withdraw consent for optional data processing at any time

We respect each of these rights for all of our clients, regardless of location. If you have any questions or concerns about any of these rights, or if you would like to assert any of these rights at any time, please contact us at the email address provided above.

7. Protecting Your Information

7.1 Keeping It Safe

We make reasonable and commercially feasible efforts to keep your information safe. We have appropriate security measures in place to prevent your information from being accidentally lost, used, or accessed in an unauthorized way. We restrict access to your personal information to those who need to know it, are subject to contractual confidentiality obligations in the case of internal personnel and third-party providers, and may be disciplined or terminated if they fail to meet these obligations.

Those processing your information are tasked to do so in an authorized manner and are subject to a duty of confidentiality. We encrypt data during transit via TLS and at rest where appropriate.

That said, no organization or business can guarantee 100% data protection. With that in mind, we also have procedures in place to deal with any suspected data security breach. We will inform both you and any applicable authorities of a suspected data security breach, as and when required by law.

7.2 Third-Party Providers

As articulated in this privacy policy, our services utilize third-party providers, including payment processors and service providers. We do not control those policies and terms. You should visit those providers to acquaint yourself with their policies and terms. If you have any issue or concern with those terms or policies, you should address those concerns with that third-party provider.

7.3 Posting Content

If you share content with another party, including messaging or sharing information, that information may become public through your actions or the actions of the other party. Additionally, if you post any information or content on social media about our services, you are making that information public. You can always ask us to delete information in our possession, but we cannot force anyone else to erase your information.

8. Cookies and Tracking Technologies

Some technologies, such as web browsers or mobile devices, provide a setting that when turned on sends a Do Not Track (DNT) signal when browsing a website or app. There is currently no common standard for responding to DNT Signals or even in the DNT signal itself. We recognize and respect DNT signals.

Our website may use cookies and similar technologies to enhance your browsing experience, analyze website traffic, and understand user preferences. Cookies are small text files stored on your device. You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of our website.

9. Minors' Data

We do not intentionally collect minors' data. Our financial services are directed to adults aged 18 and over.

If you are a parent, and you believe we have accidentally collected your child's data, you have the right to contact us and require that we remove and delete the personal information provided. To do so, upon you contacting us, we must take reasonable steps to confirm you are the parent. You may contact us for such a request at any time at the email address provided above.

10. Compliance with Regulations

We regularly review our privacy policy to do our best to ensure it complies with any applicable laws, including:

• Personal Information Protection and Electronic Documents Act (PIPEDA) — Canada
• Act Respecting the Protection of Personal Information in the Private Sector — Quebec
• Law 25 (An Act to modernize legislative provisions as regards the protection of personal information) — Quebec
• Insurance industry regulations and professional standards

When we receive formal written complaints, we will contact the person who made the complaint to follow up as soon as practicable. We will work with relevant regulatory authorities to resolve any complaints or concerns that we cannot resolve with our clients directly.

You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada or the Commission d'accès à l'information du Québec relating to the processing of any personal data you feel may have violated applicable regulations.

11. General Information

11.1 No Unsolicited Personal Information Requests

We will never ask you for your personal information in an unsolicited letter, call, or email. If you contact us, we will only use your personal information if necessary to fulfill your request.

11.2 Changes

Our business and the services we provide are constantly evolving. We may change our privacy policy at any time. If we change our policy, we will notify you of any updates to our policy by posting the updated policy on our website with a new "Last Updated" date. We will not reduce your rights under this policy without your consent. Your continued use of our services after such changes constitutes acceptance of the updated policy.

11.3 Understanding of Privacy Policy

You acknowledge that you understand the terms and conditions of this Privacy Policy. You also acknowledge that you could discuss these provisions with a lawyer at your own expense prior to using our services and have either done so or chosen not to do so. Regardless of your choice, you intend to be fully bound by this Privacy Policy.

12. Contact Us

If you have any questions about this privacy policy, contact us at:

By accessing any of our services or content, you are affirming that you understand and agree with the terms of our privacy policy.

13. Complaints

We respect the rights of all of our clients. If you have any questions or concerns about any of these rights, or if you would like to assert any of these rights at any time, please contact us first at the email address provided above.

If you are not satisfied with our response, you have the right to file a complaint with: