For subscribers, when we collect information from you, we will explain what information we collect and how we intend to use it. This explanation is set out in the Privacy Agreement, which is included in the documentation you will receive when you open a plan with us.
For non-Subscribers, when you visit our website, enter contests, interact with us on social media or use any products or services offered by Heritage, we may collect information from you depending on the type of service or interaction, and which may include your full name and contact information such as your address, telephone number or email address; and other personal information that you choose to submit to us.
We will provide your personal information to other parties: where we have your consent, where the other parties are our suppliers or business partners who provide service to your plan, and where we are required by law. You understand that some of your information may be stored in the “cloud” (limited to name and contact information), and may be stored in other countries such as the United States of America. Thus, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions per the laws in those jurisdictions.
We may also, with your consent, provide your personal information to outside sources. For example, service providers who we hire to do things like process and mail your annual statements, which will have access to certain personnel information to provide specified services. We require our third-party service providers to sign a Privacy Agreement to help ensure that they will protect the confidentiality of your personal information. We may also be required to disclose your personal information to government agencies or law enforcement agencies, or when we are in receipt of a valid Court Order or search warrant. We are also required to make our subscribers records available in case of a regulatory examination or by our external auditors in discharging their duties.
We will take appropriate steps to protect your information. We will retain your information if it is necessary to service your plan or as is required by applicable law.
We will provide you with access to your information upon your request. We will take reasonable steps to ensure that your personal information is current and accurate, but the accuracy of our information is dependent on you.
Addressing Your Concerns
If you have any questions or complaints about our privacy policies write to the Privacy Officer at:
Heritage Education Funds Inc.
2005 Sheppard Ave East, Suite 700
Alternatively, you can email your questions or complaint to “email@example.com”.
Why We Need Your Information
We ask for a variety of information when you open a plan with us. We offer services in a highly regulated environment and we are required to obtain a minimum amount of information about you so that we can provide the proper level of service and supervision to your plan. We may also base our recommendations about our products to you on the information that you provide to us. We require your social insurance number (“SIN”) in order to comply with certain Canada Revenue Agency requirements, and without it, we cannot offer you a registered education savings plan. Industry standards demand that we know your financial information to help us ensure that the products recommended to you are suitable for you. We may also request a copy of your identification from you or the beneficiary for the administration and protection of the plan (i.e., from fraud).
We may use your personal information to: respond to your inquiries; supply you with requested products or services; send you informational or promotional communications; to carry out other purposes that are disclosed to you and to which you provided consent; to carry out any other purpose permitted or required by law. We may transfer personal information to third-party service providers that assist us with carrying out these purposes.
Collection from Third Parties
With your consent, we may obtain personal information about you from third parties such as credit agencies. This information may help us locate you if you fail to advise us of a change of address, or may be used to verify employment information provided or assist you in determining if the product is suitable for you.
Protection of Information
We have thorough security standards in place to protect your personal information against unauthorized access and use. If you access your plan documents through an electronic means (such as online account access), we use passwords that you alone should know. Our internet-based applications that use “cookies” will use only “session cookies”, which means that the cookies will be erased from your computer as soon as your session is over. We also provide training to our employees so they will understand the need for confidentiality when dealing with your personal information. We retain your personal information only if we need it to service your plan, or if required by applicable law. When we no longer need your information, we will delete electronic records and destroy physical records within the timelines set out by regulatory bodies.
Your Right to Access, Correct and Update Your Personal Information
You may request access to your personal information and request that erroneous or inaccurate personal information be updated.
For Subscribers, most of your information is in the form of plan documentation and transaction records. You will receive a mailed or electronic copy of any documents you sign to open your plan with Heritage. You will also receive an annual statement of your plan, which detail all securities transactions that have taken place in your plan during the period. If you have chosen to have access to your plan electronically through online account access, you may also view your plan transactions that way. If you detect any errors in the information (such as the information appearing on your copy), please advise us immediately.
Having accurate information about you will enable us to give you the best possible service.
For Subscribers, we expect that you will provide us with updated information if there is a change in banking information, in your marital status (if applicable), when you move, change telephone numbers or email addresses, or have any other material changes to your financial information. If you detect any errors in information (such as the information appearing on your copy), please let us know immediately.
If you require further details about your information, you may contact us at any time.
Your Right to Withdraw Consent
You may request that your consent for us to collect, use and release your personal information be withdrawn or your personal information be deleted.
When you sign the documentation required to open your plan, you will see that within that documentation is our Privacy Agreement. By opening a plan with us, you are providing your consent for us to collect, use and release your personal information. If at any time you wish to withdraw this consent, please advise us. However, please note that withdrawing consent may mean that we will be unable to provide certain services to you. We will explain the consequences of withdrawing consent, should you choose to do so.
Online Services and Email
When you send us an email, we learn your exact email address as well as any other information you may have included in the email. While we may use your email address to reply to you, we do not make your email address known to anyone outside our firm. We may use your email address to advise you about products or services that may be of interest to you. You may ask us to remove you from our mailing list anytime by using the “unsubscribe” instructions provided with each email. We may also send certain required information to you via email if you have requested that we do so. Again, you may cancel this at any time. Please keep in mind that information sent via email is generally unencrypted, so we would remind you not to send us confidential information via email.
As mentioned previously in this material, we do offer Subscribers online services through our secure online access portal (“Online Account Access”). While we may keep records of when you visit us through your Online Account Access, we may also use your log-in activity to ensure that you have accessed your communication in a timely manner.
Prior to posting a document on your personal Online Account Access, we will send you an email notification. The information on the email notice is limited and contains very little information and we request that you access the actual document online. You can change your preferences at any point in time and there is no cost to receiving your mail electronically. If you “unsubscribe” from email communications, we will post documents to your Online Account Access without an email notice. However, where we are legally required to send you the document, we will still provide you with notification by-passing the “unsubscribe” based on your online preferences.
How is Your Information Secured and Protected?
Heritage Education Funds Inc. uses encryption and authentication tools to protect your personal information. The information that you provide through your Online Account Access is secure.
Communicating with Us Safely
To help our Subscribers recognize fraudulent email and websites pretending to represent Heritage, Heritage will never ask you to provide personal, login or account information through an unsolicited email. Should you receive an email requesting this type of information, please do not respond. We would appreciate if you report this email by forwarding a copy to this email address, firstname.lastname@example.org. Please delete the email from your inbox.
Heritage Plans are scholarship plans issued under the sponsorship of the Heritage Educational Foundation. Units of the Heritage Plans are offered by prospectus only, a copy of which can be obtained from the registered dealer, Heritage Education Funds Inc. at HeritageRESP.com. These securities may not be appropriate for all investors and are subject to certain risk factors. See the prospectus for details.