Legal

1. Who is responsible for your information

ALM ANALYZED INC. operates EconCERF and is responsible for the personal information described in this policy. This policy is written to the Personal Information Protection and Electronic Documents Act, the federal privacy law that applies to private sector organisations in Canada.

The platform is not currently offered to residents of Quebec, and this policy does not attempt to describe the additional privacy obligations that apply there.

2. What we collect

We collect only what the platform needs in order to work for you:

• Your email address, when you create an account. This is how you sign in, how you recover access, and how we reach you about your account.
• Your name, which is required when you save your first plan.
• The figures you enter to build a plan: your age or time horizon, what you have saved, what you contribute, the goal you are aiming at, and your answers to the risk questions.
• The plans you save, and any Investment Policy Statement you generate.
• Your progress through the courses, so the platform can show you where you left off and what you have completed.
• Basic technical information that any website receives when you visit, such as your browser type and general location derived from your network address, used to keep the service running and secure.

We do not ask for and do not want your account numbers, your social insurance number, your date of birth, government identification, or the login details of any financial institution. The platform has no connection to any account you hold anywhere, and it never asks you to link one.

We do not collect information about your health, your background, or anything else of that nature, and we ask you not to type such things into free text fields.

3. Why we collect it

To let you create an account and sign in. To build, save and show you your own plan. To record your progress through the courses. To send you the emails your account requires, such as confirming your address or resetting your password. To keep the platform secure, to diagnose faults, and to understand in aggregate which material is being read so that we can improve it.

We use the information you give us to calculate, save and display the plan outputs you request. We do not use it to profile you for advertising, change what you are charged, or make unrelated decisions about you.

4. Consent

We ask for your consent before anything is stored about you, not afterwards. At the point where information would first be saved, we show a short notice setting out what is collected, why, who else holds it, that it is stored outside Canada, and how to have it deleted. You then tick a box to agree. Nothing is saved until you do, and the box is never ticked for you.

We record that you agreed: which documents, which version of each, a fingerprint of the exact wording you were shown, and the date and time. That record cannot be edited or deleted by us, and you can ask to see your own at any time.

If we change these documents in a way that materially affects you, we will ask you to agree again rather than assume your earlier agreement carries over.

You can withdraw consent at any time by asking us to close your account, subject to any legal obligation we have to retain records. Withdrawing consent means the platform can no longer keep or show your plan.

5. What we never do with it

We do not sell your personal information. We do not rent, trade or otherwise make it available to anyone for their own marketing purposes.

We do not share your personal information with fund companies, product issuers, insurers, brokers or advisers. Nobody currently pays us for access to you or for displaying, selecting or prioritising a product or firm. Your plan may show funds selected under our published standard, but those selections are not influenced by payment.

6. Who we share it with

We use a small number of service providers to run the platform. They process information on our instructions, for the purposes we set, and for no purpose of their own:

• A database and authentication provider, which stores your account and your saved plan.
• A hosting provider, which serves the website itself.
• An email delivery provider, which sends account emails such as address confirmation and password resets.
• A business email provider, which receives mail you send to our published addresses.

We may also disclose information where we are required to by law, or where it is necessary to establish or defend a legal claim, or to protect the safety of a person.

If the business is ever sold or reorganised, information may pass to the acquiring party, which would remain bound by this policy or by one no less protective. We would tell you before that happened.

7. Where your information is kept

Our service providers operate infrastructure outside Canada, including in the United States. Your information may therefore be stored or processed outside the country, where it can be subject to the laws of that jurisdiction, including lawful access by courts and authorities there.

We select providers that offer appropriate protection and we require them by contract to protect your information, but we cannot exempt them from the law where they operate. If you would prefer not to have your information handled on that basis, please do not create an account.

8. Cookies and similar technologies

The platform uses a small number of cookies, and each one does a job you would recognise:

• A sign-in cookie, which keeps you signed in between pages. Without it you would have to sign in again on every click.
• A theme cookie, which remembers whether you chose the light or dark appearance, so the page does not flash the wrong one while it loads.
• A navigation cookie, which remembers whether you collapsed the side navigation.
• While the platform is in pre-launch review, a cookie that records that a reviewer has already entered the shared review password.
• A cookie set when you create an account, which remembers the page you were on so we can return you there after you confirm your email. It is cleared once you confirm, and expires after a day.

None of these follows you to other websites, and none is used for advertising. We do not use third party advertising or tracking cookies.

You can block or delete cookies in your browser settings. If you block the sign-in cookie you will not be able to stay signed in.

9. Analytics

At the time this policy takes effect, the platform runs no third party analytics or tracking service.

We expect to add a privacy-respecting way of measuring how the platform is used, because without it we are guessing about what helps people. If and when we do, this section will say which service, what it records, and whether it uses cookies, before it is switched on. We will not add a service that builds advertising profiles or that follows you across other websites.

10. How long we keep it

We keep your account information and your saved plan for as long as your account is open, because the plan is the thing you came back for.

When you ask us to close your account, we delete your account and your saved plans within thirty days, other than anything we are required to retain by law and information held in routine backups, which is overwritten on our normal backup cycle.

If you start creating an account and never confirm your email address, we delete it automatically after 30 days, along with the record of your agreement. You do not have to ask, and nothing is kept from an account that was never completed.

11. How we protect it

Information is transmitted over an encrypted connection and stored with access controls that limit each account to its own data. Access by us is limited to what is needed to operate and support the platform.

No system is perfectly secure, and we will not claim otherwise. If a breach occurred that created a real risk of significant harm to you, we would notify you and the Office of the Privacy Commissioner of Canada as the law requires.

12. Your rights

You may ask us what personal information we hold about you and receive a copy of it. You may ask us to correct anything that is inaccurate. You may ask us to delete your account and the information held with it.

Write to support@econcerf.com and we will respond within 30 days. We may need to confirm your identity before acting, which we will do through the email address on the account.

13. Children

The platform is not intended for anyone under 18, and we do not knowingly collect information from anyone under that age. If you believe a child has created an account, tell us and we will delete it.

14. Changes to this policy

If we change this policy we will change the effective date at the top of this page, and where a change is material we will tell you by email or by a notice on the platform before it takes effect.

15. Questions and complaints

Write to support@econcerf.com with any question or concern about how your information is handled. We would rather hear it directly and fix it.

If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada. Residents of Ontario may also have recourse under provincial law depending on the circumstances.