Last updated: August 17, 2020
The Emma group of companies (Emma Services Financiers inc. and Emma Labs Inc. together "Emma", "our", "we" or "us") acts as an intermediary, either between life and health insurers and independent advisors or between mutual funds (mutual fund companies) and representatives of mutual fund dealers attached to MICA Capital Inc. Emma, and its financial security advisors, also collaborates with external financial security firms in order to offer you the product best suited to your needs.
Emma is committed to respecting your privacy and protecting your personal information.
In order to provide you with quality services, we need to have access to certain personal information about you. We ensure that our employees manage this information with the utmost discretion and rigour, in accordance with the legal and regulatory requirements in force.
We define "personal information" as any information that relates to an identifiable individual or that, taken separately or in combination with other data, allows an individual to be identified. Generally speaking, personal information does not include business contact information such as your name, title, business address or telephone number.
Generally, Emma will obtain the necessary personal information directly from you with your consent, subject to exceptions provided by law.
By providing us with personal information, through our website or web platform (collectively our "Sites"), when you apply for a subscription, by telephone, email, chat or any other means, you consent to the collection, use and disclosure of your personal information in accordance with this Policy.
Emma will not collect, use or disclose personal information without your consent unless it is permitted or required to do so by applicable regulations. When required, Emma may share your personal information with regulatory agencies with whom it must cooperate and which govern its activities. For example, Emma may need to proceed without your consent when, for example, for the detection or prevention of fraud or for law enforcement purposes, seeking the consent of the individual would defeat the purpose of the investigation.
Refusal regarding information collection and withdrawal of your consent
It is your right, if you wish, to refuse the collection, use and disclosure of your personal information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent to the use of personal information already collected by contacting our Privacy Officer. Refusal to disclose information or withdrawal of your consent may prevent us from providing or continuing to provide certain of our services to you, as the personal information is necessary for the proper management or administration of your files or the provision of ongoing services related to your file. In such circumstances, you should be aware that we may be forced to close your file or stop providing you with a product or service.
Please note, however, that anonymized information, which does not allow you to be identified, will be kept.
Use for secondary purposes
Emma may also seek your consent to use your personal information for secondary purposes, such as market research or to populate its databases. As noted above, we will seek your consent in this regard. In addition, your consent for secondary use may be withdrawn at any time, without affecting the provision of our services to you.
Information Collected by Emma
As part of our interactions with you, whether you are dealing with one of our advisors (life and health insurance) or one of our dealer representatives (mutual funds), we must collect certain personal information about you. The personal information we collect is necessary in order to provide you with the services you have requested. This includes, but is not limited to:
In addition to this information, we also collect the following anonymized data in connection with your use of our Sites:
Emma collects, uses and discloses personal information for the purposes identified at the time of collection or as permitted or required by regulation. This includes, but is not limited to, the following purposes:
As mentioned in the previous section, we may use various tools to improve your Web experience and better understand our customers' behavior, particularly in relation to our marketing strategies. The following section is intended to provide you with more information about our use of these tools.
Cookies and pixel
By using cookies and pixels, we are able to provide you with advertising that are targeted to your interests and that better meets your needs. When you visit our Sites, cookies and pixels tell us, among other things, which pages are of interest to you and, therefore, we may subsequently display advertising that matches your interests.
These technologies do not contain any personally identifiable information. They may, however, contain a unique identifier required for retargeting. When you click on one of these ads, we may also track the response rate of the campaign.
Emma uses different types of cookies (collectively referred to as cookies here):
Emma mainly uses 2 types of cookies:
It is possible to prevent the personalization features of our Sites by disabling cookies on your browser. You can do this by changing the settings on your browser or mobile device.
However, if you choose to decline cookies, certain pages or sections of our Sites may not display properly or certain features may not be available.
Do other sites have access to cookies when you browse our Sites?
We sometimes use third party service providers.
When you access our Sites, either directly or through an advertisement redirecting you to our Sites, a cookie is automatically created on your computer or mobile device. At that time, a web analytics tool (for example, Google Analytics and Amplitude) and possibly external ad servers have access to this cookie, which allows us to provide you with a better experience on our Sites or, in some cases, to track your activity to promote some of our products. Although a code in the cookie file identifies you as a user, it does not recognize you by name or address.
Our service providers may also need to collect your IP address or mobile device identifier when you visit a site. This information may be transmitted to and stored on servers located in Canada or elsewhere, such as the United States. Emma does not combine any information collected by these third parties with information we hold about you. Please be aware, however, that certain suppliers may be required to disclose the data collected to third parties if they are required to do so by law or if they wish to entrust the processing of certain data to third parties. No information that would allow these suppliers to identify you is transmitted to them.
Please note that third party service providers have their own cookies and privacy policies.
Usage of Google Analytics and Amplitude
Emma uses Google Analytics, which is provided by Google Inc. (Google), and Amplitude in order to analyze the browsing behaviors of visitors to its Sites, which are tools for analyzing the frequentation and use of Web sites.
The information collected by Google Analytics and Amplitude is used to analyze the use of our Sites and to generate statistical reports on visitor activity. You can obtain more information about Google Analytics here and about Amplitude here.
Emma also works with third party advertising companies, such as Facebook or Google Adwords, that collect and use information about your visits to our Sites in order to provide you with advertising that may be of interest to you. Emma does not disclose any information that would allow the advertising companies to identify you.
You can disable Google Analytics while browsing by selecting the appropriate settings for your browser or computer tool, as well as ad settings. You may opt-out of sharing your information with these third parties by installing an add-on to opt-out of receiving interest-targeted ads.
Emma also uses Facebook's personalized audience feature to target advertising related to the interests of its current and potential customers. We invite you to check your Facebook privacy settings if you wish to manage your advertising settings. You can get more information here.
Please note that even if you choose not to receive ads targeted to your interests, you will still be able to see Emma's ads. In this case, these ads will simply not be adapted to your real needs and may be displayed more frequently.
Social Media Features
Link to Web Sites
It is important to understand that this Policy does not apply to other third party websites that may be accessed through links on our Sites. We are not responsible for those third party sites, their content or access. Therefore, any personal information you transmit through these sites is subject to the privacy policies of those sites. It is your responsibility to review their privacy policies to ensure the protection of your personal information.
We may sometimes need to share your personal information with agents or other service providers to help us provide you with the full functionality of our Sites (maintenance, analysis, legal requirements, fraud detection, marketing and development). Please note that these may be located in Canada or in other jurisdictions or countries. They will only have access to personal information that is necessary to perform these tasks on our behalf and they are required not to disclose or use it for other purposes. Please be aware that we have contractual agreements with these suppliers to ensure the security of your data.
Please note that we may also share your personal information when required by law, to enforce compliance or to protect the property or safety of our rights or those of others. For example, we may disclose personal information to legal or regulatory authorities if we suspect money laundering, insider trading, manipulative or deceptive marketing practices or other criminal activities, to detect and prevent fraud, or to comply with legal or regulatory requirements of government, regulatory or other self-regulatory organizations. We may also need to disclose personal information to comply with a legal obligation (for example, a court order) or to protect our assets (for example, to collect overdue accounts).
In other words, we may share your personal information obtained about you with third parties, such as in the following cases:
In addition, as mentioned in the section "How We Use Your Personal Information", we may share anonymized data.
The security and confidentiality of your personal information is important to us. We strive to implement the necessary and appropriate security measures to ensure the confidentiality of the personal information in our possession. To do so, we follow the generally accepted industry standards. The personal information that we hold is therefore accessible only to persons who are qualified to have access to it and who consult it only when necessary in the performance of their duties.
Appropriate physical, technical and/or administrative safeguards and security measures have been put in place and are maintained to prevent:
In order to do so, we ensure, among other things, that access to our offices and computer equipment is restricted, that our staff is trained and that our agents and suppliers of goods and services having access to personal information sign confidentiality agreements and implement security measures deemed equivalent.
If you believe that your personal information has been compromised, we invite you to contact us using the contact information listed in the "Questions, Comments, Complaints" section of this Policy.
We only keep records of your personal information for as long as it is required for our business relationship, in accordance with our internal document retention policies or legal and regulatory requirements. These records will be retained by your advisor or mutual fund dealer representative with whom you normally deal, by Emma's Compliance Department or by our service providers.
Strict procedures for the retention of your personal information are followed and we will dispose of personal information which Emma no longer requires for the identified purposes.
If you wish to obtain additional information, we invite you to contact us using the contact information listed in the "Questions, Comments, Complaints" section of this Policy.
Access to and correction of your personal information
You have access to your personal information through your user account on our Sites. You can correct and update certain personal information from this access or by chatting with one of our advisors.
You may request access to your personal information or information about the existence of such information or about the manner in which we collect, use, maintain and/or disclose your personal information. You may also request that information held by Emma be corrected if it is found to be inaccurate, equivocal or incomplete.
You may submit a written request to this effect to the Privacy Officer at the address indicated in the "Questions, Comments, Complaints" section below.
If you wish to obtain copies of your personal information, we may be required to charge a nominal fee, which will be disclosed to you in advance, simply to cover the cost of transcription, reproduction or transmission.
The content of our Sites may be changed at any time. If so, we will notify you, as required by law. As this Policy may change over time, we recommend that you review it frequently to stay informed about how we treat your personal information.
To contact us, ask questions about this Policy, provide us with your comments, submit a request for access or correction, exercise any applicable right, file a complaint or obtain information about our practices or policies, we invite you to contact our Privacy Officer at the following address:
Emma Services Financiers inc.
4 Place Ville Marie Suite 300, Montréal, QC H3B 2E7
Emma would like you to know that we are committed to responding promptly and accurately to all your questions and concerns about the privacy and security of your personal information and our privacy policies and procedures.
In the event of a complaint from you regarding the exercise of your rights set out in this Policy, your file will be handled by Emma's Office of the Privacy Officer, who will inform you of the procedure to follow. Each complaint will be investigated. If the complaint is justified, the particular situation will be corrected and you will be informed.