PRINCIPLE #1 — CLEARLY FINANCIALS IS ACCOUNTABLE FOR YOUR PERSONAL INFORMATION IN ITS POSSESSION OR CONTROL.
Clearly Financials is accountable for all personal information in its possession or control. This includes any personal information that Clearly Financials has collected about staff, customers, third party consultants, (each, a “Clearly Financials Stakeholder”), as either collected directly from such Clearly Financials Stakeholder; “Clearly Financials Website”(s) including but not limited to www.clearlyfinancials.ca.
Clearly Financials has:
established and put into effect policies and procedures aimed at properly protecting personal information;
educated its staff regarding such policies and procedures and their roles and responsibilities in protecting personal information;
selected a software vendors that utilize high grade security;
put in place safeguards for Stakeholders’ email addresses; and
selected a form builder vendor that provides high grade security. (256 bit SSL, PCI Certification, GDPR Compliance, CCPA Compliance and HIPAA Compliance) Read the Security Statement (https://www.jotform.com/security/) from JotForm, our form builder supplier, for more information.
PRINCIPLE #2 — CLEARLY FINANCIALS IDENTIFIES THE PURPOSES FOR WHICH IT COLLECTS PERSONAL INFORMATION FROM YOU BEFORE IT IS COLLECTED.
We generally identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use.
Some of the primary purposes for which we collect and use your Personal Information include:
to provide services to you in your capacity as a Clearly Financials Stakeholder;
to complete a transaction with you when you purchase or use a product or service offered by us;
to advise you of Clearly Financials products or services that may be of interest to you;
to send you electronic Clearly Financials newsletters or correspondence that may be of interest to you or to which you have subscribed, and to better understand which articles are of interest to you;
to conduct research and analytics for purposes that include but are not limited to better understanding Clearly Financials Stakeholders, allowing Clearly Financials Stakeholders to provide feedback on products and services, and producing data analytics and statistical reports;
to present non-Clearly Financials content and advertising that is customized to your interests;
to respond to inquiries you submit;
to establish and manage your Clearly Financials account(s);
to customize the content presented to you when using a Clearly Financials Website;
to utilize certain Clearly Financials Website services, and
to report usage of a Clearly Financials Website – the reports may be used by Clearly Financials, third-party consultants, and individual(s) designated as group administrator(s).
We may also use your Personal Information as otherwise permitted or required by law.
PRINCIPLE #3 — CLEARLY FINANCIALS OBTAINS YOUR CONSENT BEFORE COLLECTING PERSONAL INFORMATION FROM YOU.
We explain your options and obtain your implicit or explicit consent at the time of or prior to collecting, using or disclosing your Personal Information. We will always collect your Personal Information by fair and lawful means (for example, when you complete an application form or purchase a product or service from us). We may collect Personal Information about you from Clearly Financials Website(s). We also collect your Personal Information where we have obtained your consent to do so or as otherwise permitted or required by law.
Where is it reasonable to do so, or permitted by law, we may rely on implied consent.
Any personal information provided by you on behalf of others, you have obtained consent for collecting, using and disclosing this information, according to privacy legislation.
Except as required to process a transaction, to maintain records of Clearly Financials or as required or permitted by applicable law, providing us with your personal information is voluntary. You may withdraw or modify your consent at any time, subject to legal and contractual restrictions, provided that reasonable notice is given to us. If you withdraw your consent to receive information regarding certain products, publications, services or events being offered by us, you may not be made aware of some information that would serve your best interests. Refusal or withdrawal of consent from use of personal information by Clearly Financials Website(s) may result in our being unable to provide you with Clearly Financials Website services or related online services.
From time to time, Clearly Financials Website site and service updates are emailed to users. If you do not wish to receive such mailings, you may request to be removed from this electronic mailing list at any time by contacting our office (see contact information under Principle #3). You should understand, however, that if you are removed from the mailing list you may not be made aware of the status or availability of certain Clearly Financials Website services.
Personal Information is any information that is identifiable to you. This information may include, but is not limited to, your name, mailing address, phone numbers, email address, identification numbers, credit card numbers, banking information, and creditor information. Personal Information, however, generally does not include information that Clearly Financials collects, uses or discloses solely for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession such as the individual’s name, position name or title, work address, work telephone number, work fax number or work electronic address.
PRINCIPLE #4 — CLEARLY FINANCIALS DISCLOSES YOUR PERSONAL INFORMATION ONLY FOR PURPOSES FOR WHICH IT HAS CONSENT, OR AS PERMITTED OR REQUIRED BY LAW.
We identify to whom, and for what purposes, we disclose your Personal Information, at the time of or prior to collecting such information from you and obtain your consent to such disclosure. For example, we may:
transfer/disclose your Personal Information, in the case of Clearly Financials Stakeholders, to national and provincial CPA bodies, for the purposes of providing services to such Clearly Financials Stakeholders;
transfer your Personal Information to our volunteers, for the purposes of the volunteers performing volunteer functions;
transfer your Personal Information to third party service providers with whom we have a contracted agreement that includes appropriate privacy standards, such as service providers that provide communication services support or data storage or processing – for the purpose of, for example, providing member benefits, facilitating commercial transactions with us or offering educational programming;
We have engaged a third-party service provider to assist us in providing professional services to you. We may share confidential information about you with these service providers, but remain committed to maintaining the confidentiality and security of your information. Accordingly, we maintain internal policies, procedures and safeguards to protect the confidentiality of your personal information. In addition, we will secure confidentiality agreements with all service providers to maintain the confidentiality of your information and we will take reasonable precautions to determine that they have appropriate procedures in place to prevent the unauthorized release of your confidential information to others. In the event that we are unable to secure an appropriate confidentiality agreement, you will be asked to provide your consent prior to the sharing of your confidential information with the third-party service provider.
on Clearly Financials Website(s), to your organization via usage reports accessible by the individual(s) designation by your organization as its group administrator(s);
disclose your Personal Information to such persons and for such purposes for which you provide your consent; and
disclose your Personal Information as otherwise permitted or required by law or by the Code of Professional Conduct / Code of Ethics (CPA Alberta / CPA Canada).
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law.
From time to time we may disclose or hold your Personal Information outside of Canada, and while outside of Canada it may be subject to access by regulators in accordance with the laws of those jurisdictions.
PRINCIPLE #5 — CLEARLY FINANCIALS ENDEAVOURS TO KEEP ACCURATE, COMPLETE, AND UP-TO-DATE, PERSONAL INFORMATION IN ITS POSSESSION OR CONTROL, TO THE EXTENT REQUIRED TO MEET THE PURPOSES FOR WHICH IT WAS COLLECTED.
We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible based on information provided to us by you. We expect you, from time to time, to supply us with written updates to your Personal Information, if applicable. In the case of Clearly Financials Stakeholders, Personal Information may be updated by accessing profiles created on a related Clearly Financials Website or online service.
PRINCIPLE #6 — CLEARLY FINANCIALS PROTECTS THE PRIVACY OF PERSONAL INFORMATION IN ITS POSSESSION OR CONTROL BY USING SECURITY SAFEGUARDS APPROPRIATE TO THE SENSITIVITY OF THE INFORMATION.
We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to your Personal Information are those with a business 'need-to-know' or whose duties reasonably require such information.
You can visit our Clearly Financials Website(s) without telling us who you are or revealing any information about yourself, including your email address. However, our web server may collect the IP address and domain you used to access our Clearly Financials Website(s), the type and version of web browser and operating system you are using, the number, duration and frequency of visits to our Clearly Financials Website(s) and the Clearly Financials Website you came from and visited next. This anonymous information cannot be traced to a specific individual User - it is used by us simply for the purposes of analytics – for example, to measure the number of visits, average time spent, page views, most popular preferences and other statistics about visitors to the Clearly Financials Website(s) and to determine the characteristics in which users use our Clearly Financials Website(s) and services. We may use this data to monitor Clearly Financials
Website performance for systems administration purposes, to make Clearly Financials Website(s) easier and more convenient to use, to improve our services and to track information in aggregate form (e.g. how many visitors use Clearly Financials Website(s)). This helps us better understand our Clearly Financials Website(s) traffic, visitor behavior and the impact of campaigns, content and email-driven traffic. By having access to such deeper data insights, we are able to measure, re-evaluate content offerings, map customer buying journeys and provide you with a more personalized visitor site experience, enabling demographic and interest reporting.
We make use of Google Analytics. A description of how Google Analytics collects and processes data is set out in “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/).
Please note that we have also implemented the following specific Google Analytics Advertising Features:
Remarketing with Google Analytics
Google Display Network Impression Reporting
Google Analytics Demographics and Interest Reporting
Integrated services that require Google Analytics to collect data via advertising cookies and identifiers.
Should you wish to opt out of the Google Analytics advertising features, you may do so at https://tools.google.com/dlpage/gaoptout/.
Our Clearly Financials Website(s) contains security mechanisms that protect against the loss, the misuse and the modification of information under our control.
Please note that it is your responsibility to protect your user id and password information. If this information is disclosed the privacy of your information cannot be assured.
PRINCIPLE #7 — CLEARLY FINANCIALS IS OPEN ABOUT THE PROCEDURES IT USES TO MANAGE PERSONAL INFORMATION.
Up-to-date information on Clearly Financials’s privacy policies can be obtained from our office (see contact information under Principle #8).
PRINCIPLE #8 — CLEARLY FINANCIALS RESPONDS ON A TIMELY BASIS TO REQUESTS FROM CLEARLY FINANCIALS STAKEHOLDERS ABOUT THEIR PERSONAL INFORMATION, WHICH CLEARLY FINANCIALS POSSESSES OR CONTROLS.
We will generally make available to you any Personal Information that we have collected about you, utilized or disclosed, upon your written request, to the extent permitted or required by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes. Personal Information of Clearly Financials Stakeholders may be reviewed and updated by accessing profiles created on a related Clearly Financials Website.
You can at any time, challenge the accuracy or completeness of the Personal Information we have which is related to you. Where we validate your identity, and you successfully demonstrate the inaccuracy or incompleteness of your Personal Information, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.
We will not assess any costs to you for access to your Personal Information or to our Privacy Policies or Practices without first providing you with an estimate of the approximate costs, if any. We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such information shall be used only for this purpose.
Clearly Financials Professional Corporation
203, 8603 104 Street NW
Edmonton, AB T6E 4G6
We will inform you of the relevant procedures if you make an inquiry or lodge a challenge or complaint.
Last revised: April 17, 2019