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Privacy PolicyAt Justice Financial Group, an important part of our commitment to you involves being a socially responsible company, which includes being sensitive to the ever-changing demands of corporate culture. In recent years, being socially responsible has focused on four main components. Issues related to the environment, to internal labour and workplace ethics, to supplier or affiliate code of conduct, and to information and privacy have become important factors for any business wanting to operate with honesty and integrity. We believe that our strong commitment to these issues is responsible, not just to meet legal obligations or requirements, but also to improve the quality of service that we provide. This policy will help you better understand how JFG collects, uses, protects and discloses your personal information and your right to access your information. What Constitutes Personal InformationPersonal information is any information that is (a) not available in a public forum or location, (b) is uniquely identifiable to a specific individual in a manner that could create potential for misrepresentation of an individual, and (c) is outside of our understanding of fair use. In other words, personal information is something we have to work hard to find or can't obtain publicly, could potentially jeopardize your safety or security such as through identity theft, or has absolutely nothing to do with the services that we provide to you. What do you mean by “public forum?” Information readily accessible in a public location, such as in a phone book, on web sites such as a blog, or another public listing that does not have restricted access is not considered personal information. What do you mean by “misrepresentation of an individual?” This is the level of personal information that goes beyond the basic data that is often easily accessible. For instance, if we look up your name in a phone book to obtain your phone number, it would not be considered “personal information” as it is publicly available. However, information that could create potential for misrepresentation would include things such as Social Insurance Numbers (or Social Security Numbers for U.S. citizens), credit card numbers, security information like your date of birth or mother's maiden name, bank account information, etc. In other words, if that information could be used by another party to masquerade as you, we consider that to be your personal information, and is therefore protected by our policies and principles. What do you mean by “outside of fair use?” Overall, any information that we collect on you will be something that we collect for your benefit or protection, and we will only do so with your consent. There are some cases where the specific information we need to collect might seem out of the ordinary and we will either ask you for the information directly, or obtain your consent to collect the information from another party if needed. For example, you as an individual probably cannot supply us with your own credit report. In such a case, we would need your consent to obtain your credit report from a legitimate source, as a necessary part of our underwriting process. The information in that report would be considered “fair use” on our part. General PrinciplesOverall, we will always respect the Privacy Act or any laws that are in jurisdiction over the areas that we cover. We follow those procedures and guidelines as a minimum. Many of our services have personal value to you, as our client, and are included as a good-will gesture to help improve the quality of your life. Yes, it's a genuine good-will gesture. Although some people may be skeptical about this aspect of our business, we formed out of recognizing a serious need in our society and all of our employees and partners are chosen because of their desire to serve the needs of the people we seek to help. In so doing, we may uniquely use your personal information to provide services for you that serve no apparent purpose, other than to help you and hopefully improve upon your personal well-being. We will always respect your right to privacy. We will never force ourselves on you, we will not offer services to you that you don't need, we will not bill you for simply picking up the phone and talking to us, and we will not induce or try to force you into accepting any product or service that you don't want. At any time, if we provide a service or offer something to you that you don't appreciate, simply let us know. We're not here to harass you, we're here to help. If anything we do is in any way not helpful, just tell us. We'll make it right. In general, we collect your personal information, and protect it judiciously, because it helps us deliver a level of care that we hope is unparalleled in any industry. We've even called it “Client Care” because it goes far beyond “Customer Service.” We care. We expect our employees and affiliates to care as well. The company exists because we care. That means that on a regular basis, we will personally review your account to provide you with the best possible service to inform you of anything that may be of value or interest to you. Why We Collect Personal InformationWe collect, use and disclose personal information about you throughout our relationship so that we can:
At any time we may review and analyze your applications, transactions and other personal information. We may do this to offer solutions that help meet your needs, and to develop new solutions to meet the needs of clients in general. We also do this to review the status of your account and to ensure that we are providing the most complete service for your needs, and to proactively identify any issues, problems or concerns that may require attention before the issue becomes more serious. Collection and Use of Information
Protection and DisclosureWe take your privacy very seriously. JFG does not sell, rent, or freely give away your personal information to any other party who is not also bound by our privacy terms. We will protect your personal information and keep it within our company exclusively, subject to the following exceptions:
Disclosing Within JFGTo help us provide superior service, your personal information is made available to the legal entities that exist within JFG and to affiliate agencies that are bound by JFG's Mission, Vision, Values, Code of Conduct and Privacy Policy. Disclosure to Other Service Providers and Strategic PartnersMuch of our operational strategy involves partnering or affiliating with other individuals, companies and agencies in order to be a resource hub for our clients. Our standard practice for disclosure is to inform you of the affiliates that we are associated with that might be in a position to provide an important service or product that benefits you, and to give you the option to be introduced to someone at that agency who can help you. It is not our practice to simply pass on your information and have that agency contact you to solicit business, except in a circumstance where we may be able to meet an emergency need and you are otherwise unreachable. Whatever the circumstance, disclosure to affiliate agencies is only done on a “need-to-know” basis, which restricts not just the access to personal information, but also what information is made available. For most affiliate agencies, only your publicly available information (ie, name, phone number, address) is disclosed should there be a need for the agency to contact you directly. We also will typically provide all marketing materials through our own personal and direct contact with you, even when sharing information about products or services made available by affiliate agencies. In other words, we will regularly check in on our partners and affiliates to ensure that no one is making use of your personal information to solicit from you without your express consent. By filtering these communications through JFG, you can be assured that we are providing you with information that we genuinely feel is important or of interest to you, and that if you ask us to stop at any time, you will only need to inform us, and not be required to contact the many affiliate agencies that we have partnered with. You can choose not to receive direct marketingFrom time to time, we may offer you products or services that we believe will be of interest to you. We will typically use a non-obtrusive, non-invasive method, such as email or included in a regular mailing to you. We will never telephone solicit, or try to “up-sell” you on any product or service that we offer, except where in the natural course of a conversation with you, we determine that a particular product is in your best interests and will improve upon your experience with us and your overall well-being. Addressing Your Concerns
Our goal is to serve youWe proactively seek any opportunity to work with you to help you in almost every area of your life. Under no circumstance will we use your personal information to coerce or mislead you into buying any product or service that you do not need. We will never deliberately hide or fail to disclose information about a product or service that would benefit you. In recent years, some companies provide special offers that are available to “new customers” but are not available to existing clients. We do not agree with this practice and fully support the “open-book” honesty factor that makes all of our products and services available equally to anyone who qualifies according to criteria that does not discriminate according to unfair criteria. In other words, we genuinely want what's best for you. Integrity of Your Personal InformationWe take every precaution–administratively, technologically and physically–to protect and safeguard your personal information, and to ensure that it is up to date, complete and accurate for the purposes for which it is intended. Protection of FamilyWe recognize that many of the services we provide extend beyond the individual and can often affect the entire family, especially when disability, injury or death has occurred. Because of this, we may need to be able to communicate with more than one member of your family, particularly during times of stress, illness or trauma. For this reason, we may collect and use information about your family unit to ensure that we are protecting your personal information in the best possible way, to ensure that we are not mistakingly revealing information to a non-legitimate party, and to ensure that we are sensitive to, and respect, the impact of how our services may help you and your family. In particular, this practice ensures that we take steps to verify the identity of an individual that we may contact. For example, if your spouse is listed as having the authority to make decisions about your account with us, and your child happens to have a voice that is similar to that of your spouse, we will take every precaution to ensure that we are speaking to your spouse, and not to your child, when discussing your account. We are also sensitive to the nature of family, and respect the right of a parent to withhold or protect their children or other family members from information that they do not wish to share. We will respect your rights in those matters, and will keep all communications with you–including phone messages left on an answering machine, postcards sent in the mail, or messages left with other members of your family–as generic as possible so as not to reveal any otherwise confidential information. Protection of Digital InformationA standard practice on many corporate websites is to use “cookies” and other technologies to better understand which parts of a site are most popular, where visitors are going, and how much time is spent there. Contrary to popular belief, cookies are not actually a bad thing. Cookies are primarily used to store information on your own computer that can be retrieved the next time you visit our website. This is the intended use for all of the cookies used on our site. In particular, this means that when you visit our site, you may have an option to select a specific preference, such as the font size that you want the information to appear in. If we didn't store a cookie, then you would have to select the font size every time you visit our site. Or, we may need to change the nature of the information we display based on your location, which may require us to ask for your location information such as country, province, state, or zip/postal code. This would ensure that we can provide information that is legally accurate to your region. To avoid needing to enter that information every time you visit our site, a cookie stores that information on your own computer so that we can retrieve it each time you visit. Please note some of the following information about cookies:
We feel, however, that the use of cookies should be extremely limited, and should only be used when no other method exists to make the website experience better for you as our client. Privacy QuestionsIf you have any questions or concerns about JFG's Privacy Policy, please contact us directly using one of the methods below. Justice Financial Group Inc., 3-60 Meg Drive, London, Ontario, Canada, N6E 3T6 Toll Free: 866.641.4446 Ph: 519.641.4446 Fax: 519.641.0366 Email: privacy@justicefinancialgroup.com Version 1.0 |
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