Privacy

Privacy Policy

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.

The purpose of this Privacy Policy (the "Policy") is to inform you about how Emma collects, uses, discloses, retains and protects 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.

Personal information

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.

Consent

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.

What personal information do we collect?

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:

• Your contact information such as name, address, email or phone number to identify and correspond with you;
• Your Social Insurance Number (SIN) in order to meet government obligations, including tax reporting and other purposes, such as opening an income-generating account and for registered retirement income investments, to meet Canada Revenue Agency requirements;
• Information related to your health, such as your family history or smoking habits, in order to establish your eligibility for certain insurance products;
• Financial information, such as the amount of your mortgage, debts, savings, investments, liquid assets and salaries or information on your insurance contracts in force, in order to get to know you well and thus offer you advice and products and investments that meet your needs;
• Marketing information and communication preferences such as comments, survey responses;
• Information related to the use of our website, including technical information about visits or other information collected through cookies or other similar tools;
• Recruitment-related information such as resumes, information on your professional or academic background, psychometric test results or any other information relevant to potential recruitment;
• Any other personal information provided.

In addition to this information, we also collect the following anonymized data in connection with your use of our Sites:

• Number of visits;
• The conversion rate;
• The average length of your visit;
• Actions performed on our Sites;
• Pages viewed during your visit;
• The type of device used during your visit;
• The web browser used during your visit;
• The Ip address used during your visit;
• The origin of visitors, i.e., the Web page you visited before being redirected to our Sites.The advertising campaign that brought you to our Sites

Why do we collect your personal information?

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:

• Build and manage our relationship with you;
• Provide services, including your subscription to savings and insurance products;
• To facilitate the use of our Sites, to ensure their relevance and to monitor their use;
• Answer your requests for information;
• To allow business development and marketing in order to inform our current and future customers about our new offers with the prior consent of the person concerned;
• Carry out development and research to ensure that we maintain the highest standard of security and to understand our customers' requirements in order to improve our offer;
• Recruit staff, process applications and evaluate the candidate's profile in relation to the requirements of the position;
• As permitted or required by any applicable legal or regulatory requirements or provisions;
• Any other purpose to which you have consented.

How do we collect your personal information?

Emma collects your personal information primarily from you, but also from third parties or through the use of cookies or pixels.

1. From you
   ‍You provide us with personal information directly, such as when you purchase life insurance or savings products, when you contact us or when you click on an advertisement we have placed on a third party website (e.g. Google, Facebook, etc.).
2. From a third party
   We may also collect personal information from third parties, or from publicly available records as permitted by law or where we have obtained consent.
3. Chat tool
   ‍In connection with the use of the chat support tool, Emma offers you online services through an advisor who may, if necessary, ask for and collect information about you. This information establishes your identity and also allows you to benefit from the services that are available through this tool and that are best suited to your needs.
4. Cookies
   ‍Cookies are small data files that are commonly stored on your device when using websites and online services. They are used for the efficient operation of websites and can provide information and help customize services. Emma collects the personal information provided by cookies.
5. Pixels
   Web pixels are tiny images that we may place on our Web pages or in our emails. They can be used, for example, to anonymously obtain the number of times a particular page has been visited by a user. As their name implies, pixels are invisible, and any part of our Sites, including the advertisement displayed on them, may contain pixels. Unlike cookies, pixels are web beacons that are not placed on your computer.
6. Use for Research and Development Purposes
   Information obtained through the use of cookies or pixels may also be used for research and development purposes and to improve your experience on our Sites. In such case, the information is anonymized and is used primarily for statistical purposes. However, we want to reassure you that no data that could identify you will be used. As mentioned above, this is anonymized data that will be used for statistical and research purposes.

Clarification on the collection, use and disclosure of data on our Sites (cookies, pixels and other social media features)

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):

• Performance and functionality logon indicators
  ‍These cookies are not essential to the provision of our services. They make it easier to personalize and enhance the user experience. For example, they can remember your preferences so you don't have to re-enter information more than once or remember your credentials so you don't have to re-enter them each time you use the site. They allow us to understand your behavior in order to improve our services and Sites.
• Cookies for advertising purposes
  ‍These cookies are not essential to the provision of our services. They use information about your visit to the site, such as pages viewed or ad response, to help provide the best user experience for your situation.

• Login indicators for security purposes
  These cookies help protect your accounts from unauthorized users. They help maintain the integrity of the session and provide added security, helping to block unauthorized attempts to access your account.

Emma mainly uses 2 types of cookies:

• The session cookie
  This cookie is kept in memory for the duration of your visit on our Sites, after which it is erased from your device. It allows us to identify you and is later deleted when you leave our Sites.
• The persistent cookie
  Ce témoin est stocké sur votre appareil jusqu’à ce qu’il expire et sera récupéré lors de votre prochaine visite sur nos Sites. Nos témoins persistants ont une durée de 30 jours.

Please note that the use of cookies only identifies you as a user and does not recognize you by name or address.

Disabling 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.

Targeted advertisement

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.

Please note that our advertising partners and other third parties may also set cookies or pixels when you click on their advertisements or links to their websites or services on our Sites. This Privacy Policy does not apply to third party websites or third party advertising providers.

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

Our services include social media features such as the Facebook share button or interactive mini-programs that work on our Sites. If you use these features, they collect your IP address, the page you visit on our Sites and create a cookie to enable these features to function properly. These features may be hosted by a third party or directly on our Sites. Your interaction with these features is governed by the company's privacy policy that proves the feature and not by this policy.

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.

How do we share 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:

• We have obtained your consent to do so;
• You wish to purchase insurance or obtain one of our products: In which case, we transmit the following information to our partners, including Humania Assurance Inc. and MICA Capital Inc:
  - All the information you provided when you submitted your application;
  - The ID validation photo as well as the number of the ID document;
  - The information on the product you have selected;
  - A file containing a transcript of your conversation with the advisors as well as the metadata associated with each message (time, date, IP address, browser and device used);
• In order to enable the functionality of our Sites;
• A securities regulator or any other regulatory body has required it;
• We are required or permitted to do so by law.

In addition, as mentioned in the section "How We Use Your Personal Information", we may share anonymized data.

How do we protect your personal information?

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:

• Any accidental or unlawful destruction;
• Any accidental loss;
• Any unauthorized disclosure;
• Unauthorized modification;
• Unauthorized access; and
• Any illegal treatment.

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.

How long do we keep your personal information?

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.

What are your rights?

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.

Changes and updates to the Policy

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.

Questions, comments, complaints

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.
Privacy Officer,
4 Place Ville Marie Suite 300, Montréal, QC H3B 2E7
hello@emma.ca

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.