Privacy Policy
Last updated: Feb 12th, 2024

What this policy covers

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Your privacy and trust are important to FinlyWealth, as is being clear about how we collect, use, and disclose information about you. This policy is intended to help you understand:
 

• The type of personal information we collect

• How we use the personal information we collect

• Other personal information we collect and use

• How we restrict the disclosure of your personal information

• Safeguarding your personal information

• Contacting FinlyWealth Privacy

• Accessing your personal information

• How we collect your personal information online, through our website and app, online advertising and third-party links

• Our Affiliates

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“FinlyWealth,” “we,” “us,” or “our” means collectively FinlyWealth and its affiliates that offer services (collectively referred to as “Affiliates” and listed below) are committed to protecting the privacy and confidentiality of personal information in our possession and control. This Privacy Policy explains the measures we take to fulfill these commitments and describes the manner in which we collect, use, disclose and otherwise treat your personal information through our browser extensions and website, including all subpages and successor pages (collectively referred to as the “Website”) as well as through other interactions with our clients and prospective clients, including our FinlyWealth-branded applications.

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This Privacy Policy will continue to apply for as long as we hold your information, including after the termination of any of your products or services with us. By providing us with your personal information, you are consenting to the collection, use and sharing of your personal information as set out in this Privacy Policy.

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Use of Your Personal Data

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This Privacy Policy may be updated periodically to reflect changes to our privacy practices. Any changes we make to this Privacy Policy will be effective when we post the revised policy on our Website. We strongly encourage you to refer to this Privacy Policy often for the latest information about our privacy practices. By continuing to interact with us after the modified version of the policy has been posted, you are accepting the changes to the policy.

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We collect personal information from our clients and prospective clients for purposes that include the following:

• to better understand our client's financial position, needs, wants, and personal circumstances so that we can provide advice, recommendations or account and product assessments (where applicable);

• to understand how our clients use our Websites and extensions, to help improve our products and services.

• To facilitate cash-back rewards and track rebate eligibility through our extension and website. We use your shopping behaviour, observed via the extension, to personalize offers and ensure you receive the most relevant deals.

• Understanding your financial needs and delivering financial products and services that help meet them

• helping us choose the portfolio that best fits you and your needs

• Verifying your identity and other information you have provided to us

• help manage and assess our risks and operations

• Tailoring your app experience based on the data you provide and the interactions you have with our services is a key part of our commitment to you. This personalization extends to the administration of referral programs, where we use your data to manage and track the effectiveness of these programs, including analyzing how users interact with referred links and the extension itself.

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We continually monitor our data collection practices and encourage you to reach out to us if you have any questions or concerns about these practices.

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Other ways we collect and use personal information.

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Marketing Communications: From time to time, we may send you email, SMS text messages and other communications about FinlyWealth products, services, or events that may be of interest to you, as well as products, services or events of our Affiliates. You can opt out of receiving marketing and promotional emails from us by following the unsubscribe instructions contained in each of our email communications. Please note that you will continue to receive email regarding your account with us. Alternatively, you can unsubscribe from any of our marketing communications by contacting us at admin@FinlyWealth.com.

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Customer Service/Relationship Manager: If you contact a customer service agent or Relationship Manager with a comment, question or complaint by email, text message, web chat, telephone or video chat, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may record the conversation or retain this information to assist you in the future and to improve our customer service and, product and service offerings.

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Employment: If you inquire about or apply for a job with FinlyWealth or any of its Affiliates, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

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Referral programs: we use the personal information we collect to administer our referral programs. This initiative allows our clients and prospective clients to recommend our services, including the rebate extension, to friends, family, and colleagues, thereby enhancing the reach and effectiveness of our financial products and services. We use your personal information to send invitations to individuals you refer to us. This may include using the name and email address you provide for your referral to send them an invitation to join our services. We keep track of your referral activity, such as whom you have referred and whether they have signed up for our services, to appropriately reward you for successful referrals that lead to new client engagements. We may use your personal information to communicate with you about the status of your referrals, including whether a referral has accepted your invitation, signed up for our services, and any benefits you may receive as a result of your successful referral.

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How we collect personal information

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We collect personal information directly from you, the devices you use to access the Websites or browser extensions, and third-party service providers (for example, from credit reporting agencies or from your mobile service provider as part of identity verification or fraud prevention).

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Our data collection practices include, but are not limited to, the following scenarios:

• Website Interactions: Each time you visit our website, we collect information about your visit. This may include the pages you view, the links you click, and other actions taken within our site. We use this information to improve our website's functionality and to understand your preferences and interests better.

• Extension Use: When you use our browser extension, we collect data related to your browsing habits, purchase history, and interactions with the extension's features. This information allows us to provide personalized cash-back offers and financial recommendations.

• Marketing Engagements: Our marketing campaigns are designed to inform you of the latest offers, services, and updates. Interaction with these campaigns, whether through email clicks, social media engagements, or participation in promotions, helps us gather insights into your preferences and the effectiveness of our marketing strategies.

• Direct Submissions: We also collect information that you voluntarily provide to us, such as when you fill out forms on our website, sign up for an account, or contact us for support. This includes personal details like your name, email address, and financial information, which are essential for providing our services to you.

• Automated Technologies or Interactions: As you interact with our website and browser extension, we automatically collect data regarding your equipment, browsing actions, and patterns. This includes information such as your IP address, browser type, device type, operating system, and other technology on the devices you use to access our services. We may collect this data using cookies, server logs, and other similar technologies.

• Participation in Surveys or Research: If you participate in surveys, research studies, or feedback sessions organized by us, we collect the information you provide through these channels. This data is invaluable for improving our services, understanding client satisfaction, and developing new features that meet our users' needs.

• Customer Support Interactions: When you reach out to our customer support team, whether through email, chat, or phone, we collect information you provide to us during the interaction. This may include feedback, questions, or any personal information shared to assist in resolving any issues or inquiries you may have.

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Your data is stored securely. We may use this data for account verification, funding your accounts, fraud prevention, marketing other FinlyWealth products or services, tailoring your app experience, or improving and developing our Website, products and services.

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We have expanded our services to include a rebate extension. When you use our rebate extension, we collect additional information to enhance your experience and provide personalized offers. This information includes details about your transactions through the extension, the stores you visit, and the offers you engage with. This enables us to tailor our services to your preferences.

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Disclosure of Information to Partners

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In line with our commitment to your privacy, and to support the functionality of our rebate extension, we may share limited personal information with trusted third-party partners. This is to facilitate the cash-back process and ensure the accuracy of transaction tracking. Such disclosures are made with your consent and are limited to what is necessary for the execution of the rebate extension services.

 

Legal: We and our Canadian, US and other Affiliates and third-party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law (which may include lawful access requests by Canadian, US or other foreign courts, law enforcement or governmental authorities). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

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Affiliate Partners: "We may share certain personal information with our Affiliate Partners to enable the successful operation of our rebate extension. This includes sharing transaction details, purchase histories, and shopping behaviours to accurately track and provide cash-back rewards. These partnerships help us offer you a wider range of deals and savings. All shared information is strictly limited to what is necessary for these purposes and is handled with the utmost care for your privacy."

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Referral Marketing Partners: "Our collaboration with Referral Marketing Partners allows us to introduce our services, including the rebate extension, to a broader audience. We may share limited personal information, such as contact details, to facilitate these referrals. This process is designed with your privacy in mind, ensuring any shared information is protected and used solely for the purpose of extending our reach and improving your access to our services."

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Financial Partners: "To provide diverse cash-back redemption options, we work closely with Financial Partners. This relationship necessitates sharing certain personal and transactional information to process rewards, manage redemptions, and ensure you benefit from our services fully. This may include sharing your account details with these partners to facilitate the transfer of cash-back rewards. As always, we commit to sharing only the necessary information, safeguarding your privacy at every step."

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Disclosure to Digital Advertising Providers: To enhance the relevance of the advertising content you see, we may share certain information with Digital Advertising Providers. This includes anonymized or pseudonymized data that helps these providers deliver ads that are more likely to be of interest to you, based on your activity on our website, rebate extension, and other online interactions. These providers use various digital marketing technologies, such as cookies and web beacons, to collect data about your online behaviour, including:

• Web pages you visit within our services

• The ads you click on

• Your device type, browser, and operating system for the purpose of targeted advertising

This information helps us ensure that the marketing messages you receive are tailored to your interests and preferences, enhancing your overall experience with our services.

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Security Measures and safeguards in place

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Commitment to Data Security: At FinlyWealth, safeguarding your personal information is a cornerstone of our commitment to you. We employ a comprehensive array of technical, administrative, and physical security measures designed to protect your data against unauthorized access, use, disclosure, alteration, or destruction. These security practices include, but are not limited to, the use of encryption technologies, secure server environments, access control procedures, and rigorous data protection policies.

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Understanding the Limitations: Despite our diligent efforts to secure your data, we recognize that no security system is impenetrable. The digital environment is constantly evolving, and new threats emerge. Therefore, while we strive to employ commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

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Proactive Breach Response Protocol: In alignment with our commitment to transparency and accountability, should we become aware of any security breach that compromises your personal information, we are prepared to act swiftly. Our breach response protocol includes promptly assessing the situation, mitigating any potential harm to our clients, and taking appropriate corrective action.

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Notification Procedures: If a breach occurs that may have compromised the confidentiality, integrity, or availability of your personal information, we will notify you without undue delay, as required by applicable law. Notification will be conducted through the most effective and expedient means available, typically via email, to ensure you are informed and can take necessary protective steps. This notification will include information about the nature of the breach, the data involved, the possible consequences of the breach, and our contact information should you have further questions or require assistance.

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Empowering Our Users: We also encourage you to play an active role in protecting your personal information. This includes using strong, unique passwords for your accounts, being vigilant against phishing attempts, and regularly reviewing your account statements and credit reports for any suspicious activity.

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We maintain reasonable administrative, technical, and physical safeguards in an effort to protect personal information in our custody and control it against unauthorized access, use, modification, and disclosure. We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to sign our privacy document that obliges them to respect and protect clients’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information.

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Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

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We have personal information retention processes designed to retain the personal information of our clients and prospective clients for no longer than necessary for the purposes set out in this Privacy Policy or to otherwise meet legal requirements.

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We limit access to clients’ personal information.

We store personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees and service providers to have access to clients’ personal information only on a “need-to-know” basis in order to fulfill their job requirements.

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We require similar safeguards from our service providers.

Our service providers have transferred the information they need to perform their designated functions and are committed to maintaining your confidentiality. Our service providers are not permitted to use your information for any unauthorized purpose. Your personal information may be maintained and processed by our Affiliates and other third-party service providers outside of Canada, including Quebec, in the US or other jurisdictions. In the event personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with the laws of those jurisdictions.

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We take privacy seriously.

Individuals have the right to access, update, and correct personal information in FinlyWealth custody and control, subject to certain exceptions prescribed by law.

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We collect and use information about your visit to our website or use our apps.

In general, you can visit our Websites without indicating who you are or submitting any personal information. However, we collect and/or maintain the IP (Internet protocol) addresses of all visitors to the Websites and other related information such as page requests, browser type, operating system and average time spent on the Websites. We use this information to help us understand activity and to monitor and improve the Websites.

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Cookies & Similar Technologies: The Websites use a technology called “cookies”. A cookie is a tiny element of data that the Websites can send to your browser, which may then be stored on your hard drive so that you can be recognized when you return. We use cookies on the pages on the Websites where you are prompted to log in or that are customizable. If you have registered with the Websites, these cookies may let us know who you are and identify your browser as one that has visited the Websites before. It may be necessary to access your account information (stored on our computers) in order to deliver products and personalized services.  We also use cookies to provide us and our service providers with information about your use of the Websites that we may use to personalize the Websites or other content in accordance with your interests and preferences (e.g. language preference) and improve your user experience. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Websites, you may not be able to take advantage of all of the features of the Websites.

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Tracer Tags & Web Beacons: The Websites may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on the Websites. These tracer tags are used to help us optimize and tailor the Websites for you and other future visitors to the Websites.

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Analytics: We may use third parties, including Google Analytics, to help us gather and analyze information about the areas visited on the Websites in order to better understand, evaluate and improve the user experience and the convenience of the Websites.

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Social Media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on the Websites or our applications and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.

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Advertising: We use online advertising. We may use third parties such as ad exchanges and data companies to serve our advertisements in the App, on our Websites or other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our App, the Websites and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Websites.

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Your Choices Regarding the Browser Extension

Our browser extension enhances your experience by providing personalized financial advice and rebate opportunities based on your online activities. 

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Enabling or Disabling the Extension: You have the option to enable or disable our browser extension at any time through your browser's extension management settings. Disabling the extension stops the collection of data related to your browsing activities.

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Uninstalling the Extension: If you decide that you no longer wish to use our browser extension, you can uninstall it at any time. Uninstalling the extension removes it from your browser and stops all data collection activities associated with it.