Effective June 26, 2017
OUR COMMITTMENT
MacMillan Estate Planning Corp. (“MacMillan Estate Planning”) is committed to safeguarding your personal information.
Our Privacy Policy sets out our standards for collecting, using, disclosing and storing your personal information. Our Privacy Policy also explains how we protect your personal information and your right to access that information. This Policy should be read in conjunction with our Online Privacy Policy.
All MacMillan Estate Planning representatives are required to comply with this Policy and to ensure that MacMillan Estate Planning’s collection, use, retention and disclosure of Personal Information is in accordance with this Policy and applicable privacy legislation.
PERSONAL INFORMATION
“Personal information” means information about an identifiable individual, which does not include information of an aggregate or anonymous nature where a specific individual or individuals cannot be identified. Personal information includes information about an individual such as financial, family, and health information.
Personal information will be protected regardless of its characteristics or its form, whether written, graphic, audio, visual, computerized, or in any other form.
PURPOSE OF INFORMATION COLLECTION
Collecting information about you is necessary in order for us to provide you with high quality services. The nature and sensitivity of the information we collect about you varies according to the services we provide you and the legal requirements imposed on us.
The purposes for which we collect personal information about you are identified at or before the time of collection.
Generally, we collect, use, and disclose your personal information to:
Any questions and concerns you may have regarding the purposes for collecting information may be directed to us at the time the request for information is made or at the address provided below.
CONSENT
When we collect personal information from you, we obtain your consent to use the information for the purposes collected. We will obtain your consent for any additional use or collection, or if the purpose of using the information is changed. For less sensitive information, we may accept your verbal consent. Occasionally, we may imply consent where we can infer consent from your action or inaction.
We will not disclose your personal information without express written consent.
You may withdraw your consent at any time. We will inform you of the consequences of such withdrawal, including the possibility that we may not be able to provide a service to you. If you choose not to consent, we will record the decision in our file.
TELEPHONE CALLS
If your information is being collected by telephone, the call may be recorded or monitored for the following reasons:
If you are not comfortable with having your telephone calls recorded, please contact us to book an in-person consultation.
LIMITS TO USE, COLLECTION, AND DISCLOSURE
We limit the collection of your personal information to what we need in relation to the purposes identified to you.
We collect the information directly from you unless you allow us to collect information from a third party or in accordance with the law.
We limit the use of your personal information to the purposes we have identified to you. This means that we cannot use your personal information for other purposes without your consent, except as required by law.
We cannot disclose your personal information to anyone except with your consent or as required by law.
Your personal information is only accessible to certain authorized persons, and only to the extent necessary to perform their duties.
You have the right to know, on request, to whom the information was disclosed. We maintain accurate records, recording to whom we disclose personal information and in what circumstances it was disclosed.
We will occasionally share your personal information with service providers or agents to ensure the effective provision of services to you. These service providers or agents must agree to comply with privacy legislation before receiving any personal information.
If necessary to properly prepare your estate plan or to provide other services, we may use service providers outside Canada, including the United States. Such a situation might include the use of legal counsel resident in the United States should you own property within the United States. We are responsible for the service provider’s compliance with our Privacy Policy and will ensure that the level of protection of personal information is comparable to that provided by us. Any questions concerning the collection, transfer or use of personal information outside Canada can be forwarded to the Privacy Officer at the address provided below.
RETENTION
We only retain your personal information for as long as needed for the purpose it was collected. When we destroy your personal information, we make sure that confidentially is secured and that no unauthorized person can access the information during the destruction process.
CLIENT LIST
We maintain a list of clients (names, addresses and telephone numbers) and may use this to contact you and to provide information which may assist you to consider legal and other developments which may impact your estate plan or that of your friends and family. The purpose of this list is to allow us to better serve you. You may request that your name be removed from such a list by writing to the Privacy Officer at the address provided below.
We do not distribute or sell client lists or your personal information to third parties.
ACCURACY
We make every possible effort to ensure that your personal information is as accurate and complete as necessary for the purposes it is collected, used, or disclosed.
ACCOUNTABILITY
We are accountable for your personal information.
We adhere to privacy legislation, our policies and the procedures developed to support our policy.
All MacMillan Estate Planning representatives are trained on these processes and are provided with information about privacy laws.
SAFEGUARDS
We have implemented and continue to implement rigorous safeguards so that your personal information remains strictly confident and is protected against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
Protection methods include organizational measures such as requiring security clearances and limiting access to a “need-to-know'' basis, physical measures (e.g. building access cards for employees, off-site backups, and archiving), and technological measures such as the use of password and encryption (e.g. the use of routinely changing passwords and firewalls).
REQUESTS FOR ACCESS TO INFORMATION AND AMENDMENTS
You have the right to be informed whether we hold personal information about you. You also have the right to enquire as to how we collected your information, how we used it, and to whom it may have been disclosed.
This information will be provided to you within a reasonable time from the date we receive your written request.
In certain limited and specific circumstances, we may refuse to provide to you the requested information. Exceptions to your access right can include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that has been obtained during an investigation of a potential breach of contract or fraud, and information that is subject to solicitor-client or litigation privilege.
You may challenge the accuracy and completeness of your personal information. We will respond to an amendment request within a reasonable time.
Any request for access to information or request for amendment must be sent to inquiry@macmillanestate.com
OUTSOURCING AND DATA HOSTING OUTSIDE OF CANADA
MacMillan uses "cloud computing" third party service providers, and those providers are in the United States of America. Company data, including personal information and email sent and received on Company IT infrastructure, is transmitted through, backed up, and stored in the United States of America. This data is subject to the laws of the United States of America and MacMillan cannot guarantee that this data will not be disclosed to law enforcement and other government agencies. Questions concerning the transfer of data outside of Canada should be directed to the MacMillan Privacy Officer.
CASL COMPLIANCE
Canada has implemented stringent legislation (generally referred to as Canadian Anti-Spam Legislation, or "CASL") prohibiting commercial electronic communications without adequate consent and without an adequate unsubscribe mechanism. Commercial electronic communications ("CEM's") are defined as emails and text messages. Please contact us at the address above if you wish to be removed from our distribution lists.
COMPLAINTS AND CONCERNS
Our employees and representatives are trained to respond to your questions or concerns about personal information. Should you be dissatisfied with our employee's or representative’s response, you may contact the Privacy Officer at the address mentioned above.
Complaints concerning the protection of personal information should be addressed to the Privacy Officer at the address provided above.
PRIVACY AND THE MACMILLAN ESTATE PLANNING WEBSITE
MacMillan Estate Planning is committed to safeguard your personal information.
MacMillan Estate Planning does not collect any Personal Information from visitors to its website. However, visitors should be aware that most web servers do collect information such as the browser and version used, operating system and "IP" or internet address, which information may identify a visitor’s Internet Service Provider or computer, but typically not the person using it.
If Personal Information is voluntarily submitted to MacMillan Estate Planning by email or other electronic means for purposes of obtaining information, MacMillan Estate Planning will consider your consent to be deemed for purposes reasonably related to the provision of the information. As the internet and email are inherently insecure media, MacMillan Estate Planning cannot take responsibility for the security or privacy of personal information in transit over same.
The MacMillan Estate Planning website may contain links to other websites which are provided as a convenience for visitors. Any third party websites will have their own privacy policies and practices, and MacMillan Estate Planning cannot be responsible for such third parties or their websites.
Some pages on our website may use a technology called "cookies". A cookie is a small file that a server provides to a browser when a website is accessed. Cookies can provide additional functionality to our website and help us to analyze and understand website usage more fully and accurately. Cookies may enhance user experiences, such as avoiding the necessity to enter a password or other identifier on return visits, or customizing the way the website displays to provide similar information to what was previously required. In all cases in which cookies are used, MacMillan Estate Planning will not collect Personal Information except with the permission of the visitor. The visitor’s web browser may permit erasure of MacMillan Estate Planning cookies from the visitor’s computer's hard drive, blocking of all cookies, or receiving of a warning before a cookie is accepted and stored. It is the responsibility of the visitor to refer to his or her own browser's instructions to learn more about cookies and how they operate.
Most browsers are initially set to accept cookies. If you would prefer, you can set your browser to disable cookies or to inform you when they are set. You also have the ability to delete cookies that you have accepted. If you delete or disable cookies, you may not be able to take full advantage of our website.
Links to other websites
Some of our websites may contain links to other websites that are not affiliated with us. We do not monitor nor maintain the privacy practices of these websites, and do not have authority over them. We do not assume any responsibility for their privacy policies and procedures.