Privacy Policy

SOFTWARE AS A SERVICE (SaaS)/ CORPORATE WEBSITE

The website www.conquestplanning.com (the “Site”) is operated by Conquest Planning Inc. (also referred to as “Conquest”, “us”, or “we”). We respect your right to control your personal information. That is why we have developed this privacy policy (the “Privacy Policy”). This Privacy Policy describes:

• the types of personal information we collect about you;
• the purpose for which we collect that information;
• how we use that information;
• with whom we share that information;
• how we safeguard that information;
• the choices available to you regarding how we use your personal information; and
• how you can contact us about our privacy practices.

This document contains the Privacy Policy for the Site, as well as for any other websites or microsites operated by Conquest (collectively and together with the Site, the “Sites”), and for web applications, software applications, tools, forums, or social media pages offered by Conquest on the Sites, and for any online financial planning platform and software solutions for the Financial Services Industry offered by Conquest (together with the Sites, the “Service”).

By accessing or using the Service, you consent to the collection, use and disclosure of personal information by Conquest in accordance with this Privacy Policy. You may choose not to provide us with personal information. However, if you make this choice we may not be able to provide you with aspects or optimization of the Service to you of the information that you may request.

1. Definitions

For the purposes of this Privacy Policy, the following words have the following meanings:

“collection” means the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.

“consent” means voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by an individual or by an authorized representative of an individual, such as a parent or guardian. Express consent is permission that is granted by an individual taking a positive step to signify consent and may be given orally, in writing or electronically. Implied consent is the assumption of consent that can reasonably be inferred from a user's action or inaction.

“user” means an individual who uses the Service provided by Conquest, including anyone else who accesses or visits the Sites.

“disclosure” means making personal information available to a third party.

“employee” means an employee of Conquest, and for the purposes of this Privacy Policy only, includes agents, partners, independent and other contractors performing services for Conquest.

“personal information” means information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual.

“non-personal information” means information that does not identify a specific individual and which we are unable to connect to other information in order to identify a specific individual.

“registered user” means a user who has created and registered an account with Conquest, as well as a Subscribing Organization that has created and registered an account or accounts with Conquest on behalf of its clients.

“Subscribing Organization” means a company, entity or organization, including any financial institution and/or advisor that has subscribed to the Service on behalf of its clients.

“third party” means an individual other than the user, or the user's agent, or an organization other than Conquest or a Subscribing Organization.

“use” means the treatment, handling and management of personal information by and within Conquest.

2. Information We Collect

When you interact with us through the Service, we may collect or receive any or all of the following types of information.

Personal Information You Provide To Us

You may provide us with your personal information in different ways. For example, we may collect any or all of the following personal information if the information is reasonably required to provide the services accessed or requested by you:

1. information that you provide when you become a registered user or otherwise complete forms on the Service, such as your name, birth date, email address, postal address, telephone number, age, country of residence, occupation, and financial information required to produce a financial plan where applicable.
2. your log-in and password details in connection with your Conquest account(s), including your username;
3. your correspondence with Conquest employees, including any questions, concerns or comments you may have about the Service or problems that you report;
4. comments, videos, photographs, and any other content or information that you may post or submit to the Service; and/or
5. details of requests made by you or on your behalf through the Service.

Technical Information We Collect Automatically

When you visit the Sites, we may collect, using electronic means, technical information. This information may include:

1. the IP address of your computer and which browser you used to view our Sites;
2. operating system;
3. resolution of screen;
4. location;
5. language settings in browsers; and
6. the site you came from and searched for keywords if arriving from a search engine;

This technical information (some of which in certain instances may be considered personal information) is aggregated and used to measure and improve effectiveness of our Sites. We do not attempt to combine this technical information with other personal information we collect on our Sites.

Personal Information Posted by You or Others to the Service

If you voluntarily submit or post any information, videos, photographs or other content (“User Content”) to the Service, certain of your personal information may be included in the posting, such as your user name and email address, and this information may be collected and used by others. Conquest has no control over and is not liable for the collection, use or disclosure of any posted User Content or your included personal information by users of the Service. You are responsible for ensuring the protection of any of your personal information that you post to any other user’s Conquest messaging account.

3. Purpose of Collection and Use of Personal Information

Conquest collects your personal information and will use your personal information as is reasonably required for the following purposes:

1. you have given your consent for the collection and use of your personal information. If you are a Subscribing Organization, you acknowledge that you have obtained express consent from your clients for you to use the Service;
2. if you are a registered user, to establish and maintain your Conquest account;
3. to provide a platform for a Subscribing Organization to use the Service for its clients;
4. to provide web applications, the Service, and/or the other services or information that you request;
5. to verify your identity if you submit comments, videos, photographs, opinions, or any other content or information to the Service;
6. to respond to questions, comments, requests, job applications, or complaints that you submit to Conquest;
7. to collect amounts owing from you to Conquest, if applicable;
8. to track communications with you;
9. to analyze use of the Service and to improve the Service;
10. to send emails, educational materials, guides, newsletters, regular mail or other communications you have consented to receive from Conquest;
11. to provide Service-related announcements or notifications to you;
12. to fulfill a purpose that we disclose to you when we request your personal information;
13. to aggregate your personal information resulting from the combination and/or aggregation of certain raw personal information collected from you with other data in a way that no longer personally identifies you; and/or
14. to comply with legal and/or regulatory requirements.

Information will only be collected and used by Conquest and its employees in a manner consistent with the activities of Conquest. Access to your personal information by Conquest’s employees is limited only to those authorized, based on their need to deal with the personal information for the reason(s) for which it was obtained, including to enable them to perform a business, professional or technical support function for Conquest.

4. Disclosure of Personal Information

Conquest may disclose your personal information to:

1. Its employees as is reasonably necessary to enable these parties to perform a business, professional or technical support function for Conquest;
2. A person who, in the reasonable judgment of Conquest, is seeking the information as your agent; and
3. A third party or parties, where you consent to such disclosure or the disclosure is permitted or required by law.

Corporate Reorganization and Business Transfers

We may also disclose your personal information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

5. Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is consistent with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and obtain your express consent to do so pursuant to Section 17.

Please note that we may also process your personal data without your knowledge or consent where this is required by law.

6. Children

The Service is intended for general audiences and is not directed to children under the age of

18. We do not knowingly collect personal information from children under the age of 18. In the event that we learn that we have collected personal information from a child under the age of 18, we will take appropriate steps to delete that personal information. If you become aware or believe that a child has provided us with personal information, please contact us as provided in Section 13.

7. Safeguarding Your Personal Information

Conquest is committed to safeguarding your personal information. Conquest uses appropriate security measures to protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, misuse, modification or destruction, and any other unlawful form of processing of the personal information in our possession regardless of the format in which it is held. The methods of protection and safeguards used by Conquest may include, but are not limited to:

• Administrative safeguards such as privacy and security policies and procedures, privacy and data protection training for Conquest staff;
• Technical safeguards such as security testing, vulnerability scans, and technological measures, including the use of passwords, encryption, firewalls, and secure coding frameworks;
• Physical safeguards such as locked filing cabinets, and need-to-know access for Conquest employees.

In any organization, failure to protect personal information can increase the risk of a privacy breach which can lead to things such as financial loss, reputational harm, fraud, or identity theft. While Conquest cannot guarantee that that a privacy breach will not occur, Conquest will make every effort to prevent such occurrences by implementing the above security safeguards.

Conquest also ensures that its employees, agents, partners and service providers with access to personal information are made aware of the importance of maintaining the confidentiality of personal information.

Conquest takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to that information.

To maintain the security of your account, there are also some measures you can take, such as keeping your password and account information confidential, not posting account or financial

information to Conquest’s technical support channels, not sending any sensitive personal information by email, maintaining up-to-date virus protection software and regularly monitoring your account activity. Conquest staff do not request your password or PIN when you make requests to the Service.

8. Personal Information Transfers

Subject to any contractual restrictions as between Conquest and a Subscribing Organization, your personal information may be stored and processed in any country (e.g. Canada, United States) where we engage third party service providers. While such information is outside of your country of residence, it is subject to the law of the country in which it is held, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. For example, personal information stored in the United States is subject to the US PATRIOT ACT. However, our practices will at all times continue to be governed by this Privacy Policy.

Conquest has measures in place to ensure that during cross-border transfers of your personal information is subject to appropriate safeguards in accordance with data protection laws. These measures typically include contractual safeguards stipulating the confidentiality of the information and the purposes for which it is to be used.

9. Retention of Personal Information

Conquest will only keep personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Policy Privacy and in order to comply with our legal and regulatory obligations. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may also retain aggregated non-identifiable personal information indefinitely after your account has been closed for research or statistical purposes.

Please note, if you are a registered user and your Conquest account becomes inactive, Conquest may choose not to retain your User Content, personal information associated with your Conquest account, or any other records associated with your Conquest account, for a period longer than three years after your Conquest account becomes inactive, in which case such information may be destroyed. If your Conquest account becomes inactive, you are solely responsible for exporting any such information from your Conquest account that you may wish to retain.

10. Accuracy

Conquest Planning is committed to keeping your personal information as complete, up-to-date and accurate as is necessary for the purposes for which it is to be used. Conquest will promptly correct or complete any personal information found to be inaccurate or incomplete. Where and when appropriate, Conquest will transmit amended information to third parties having access to the personal information in question. Upon request, Conquest will provide you with a reasonable opportunity to review the personal information in your file to review its accuracy.

Such personal information will be provided within a reasonable time of the request and at a minimal or no cost to you.

Also upon request, Conquest will provide an account of the use and disclosure of your personal information and, where reasonably possible, will state the source of the information. In providing an account of disclosure, Conquest will provide a list of organizations to which it may have disclosed personal information about you when it is not possible to provide an actual list.

11. Cookies and Similar Technologies

The Sites use “cookies”, which are small text files placed on your computer or other device when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.

There are three main types of cookies:

1. Session cookies are specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don't have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;
2. Persistent cookies record information about your preferences and are stored in your browser cache or mobile device and remain on your device between browsing sessions. For example, a persistent cookie may be used on a website to remember your log-in details so you will not need to enter those details each time you visit that website; and
3. Third party cookies placed by someone other than us which may gather data across multiple websites or sessions.
   
   We use the below listed cookies to perform the following functions:
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4. Strictly necessary / technical cookies that are essential to enable you to move around a website and use its features. You cannot withdraw your consent to the use of these types of cookies because without them, the Service cannot be provided.
5. Analytical / performance cookies that collect information in aggregated form about how users interact with the Sites so that we may improve functionality. These cookies are sometimes placed by third party providers which enable features or functionality provided by third parties in connection with the Service. For example, advertising, interactive content, and analytics (see Section 12 below). The parties that set these third-party cookies can recognize your device both when it visits the website in question and also when it visits certain other websites.
6. Functional cookies that allow a website to remember choices you make, recognize you when you return and to personalize content.
7. Targeting / advertising cookies that track browser habits and used to deliver targeted (interest-based) advertising.

You acknowledge that where we allow third parties to drop cookies, we have no control over those cookies or the data generated. Please refer to the third party's privacy policy for information on what information they collect and how they use it. These cookies are likely to be analytical/performance cookies or targeting cookies.

Managing Cookies

You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Service. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.

Other Technologies

We may use other technologies similar to cookies like web beacons, which are sometimes called "tracking pixels" or "clear gifs". These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites or opened an email that we have sent them. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

12. Analytics

The Sites employ Google Analytics, a web analysis service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses "cookies," which are text files placed on your computer, to help the website analyze how users use the Sites, compiling reports on Sites activity for the Sites’ operators and providing other services relating to website activity and Internet usage. The information generated by the cookie (including the IP address) is transferred and stored on a Google server located in the United States.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other information held by Google.

We may also use additional analytics programs from time to time to process non-personal information about you.

We make no attempt to link this non-personal information with the identity of individuals using the Service. Non-personal information may be permanently archived for future use in any manner whatsoever by Conquest.

Disable Google Analytics

You can prevent the collection and processing of cookie created data relating to your utilization of the Sites (including your IP) via Google by downloading and installing the browser-plugin available under the following link (https://tools.google.com/dlpage/gaoptout?hl=en).

Google currently offers this opt-out tool for Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari and Opera.

Further information concerning the terms and conditions of Google’s use and data privacy can be found at https://www.google.com/analytics/terms/us.html or at https://policies.google.com/privacy.

13. Inquiries

To submit an inquiry, complaint, request a review of your personal information, correct or update your personal information, withdraw your consent or request more information or additional copies of the Privacy Policy contact:

Conquest Planning Privacy Officer

Mailing Address: 800 – 330 St. Mary’s Ave., Winnipeg, MB, R3C 3Z5

Telephone No.: (204) 560-2500

E-mail: privacy@conquestplanning.com

14. Complaints

Conquest will promptly investigate all complaints concerning our compliance with the Privacy Policy and our dealings with your personal information. If a complaint is found to be justified, Conquest will take appropriate measures to resolve the complaint, including, if necessary, amending our policies and procedures. You will be informed of the outcome of the investigation regarding your complaint.

15. Withdrawing Consent

You may withdraw your consent to the collection, use or disclosure of your personal information by Conquest at any time, subject to legal or contractual restrictions and reasonable notice. In certain circumstances, your withdrawal of consent may result in the inability of Conquest to continue providing aspects or optimization of the Service to you. Please contact Conquest for more information regarding the implications of withdrawing consent.

16. Unsubscribe from Commercial Electronic Messages

If you no longer wish to receive commercial electronic messages from Conquest regarding our new products or services, promotions or other similar communications, you may unsubscribe. Please note that, after you unsubscribe, Conquest may still send electronic communications to you in certain limited circumstances, such as to provide you with Service notifications and billing information, or to provide information that Conquest is legally obligated to provide you.

17. Privacy Policy Changes

We may modify this Privacy Policy to accommodate changes in, among other things, our services, technology and/or legal developments. If we make changes to this Privacy Policy, we will provide notice through the Service, or by other means to provide you the opportunity to review the changes before they become effective. For example, we may place a prominent notice on the Sites or e-mail you to let you know of an updated Privacy Policy.

If we make significant changes to this Privacy Policy, we will provide you with at least 30 days’ notice through the Service, or by other means, to provide you the opportunity to review the changes and provide your required consent before they become effective. A significant change may be using personal information for a new purpose or disclosing it to new third parties.

You acknowledge that your continued use of the Service after we modify this Privacy Policy, by publishing or sending out a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

If you object to any changes to the Privacy Policy you may close your account.

Whenever we update the Privacy Policy, we will change the date below to indicate when the changes were made.