Privacy and Security

Privacy

C.S.T. Spark Inc., the Canadian Scholarship Trust Foundation and their respective employees and licensed direct dealing (sales) representatives (collectively, “CST”) are committed to taking steps to preserve and safeguard your right to privacy. As part of this commitment, we want you to be fully aware of what happens to your personal information, which we have in our possession. This Privacy Policy sets out the manner in which we will collect, use, disclose and otherwise manage your personal information.

Collection of Personal Information

Information You Provide:
We only collect the information about you that we need, and retain it in a client record. You provide most of this information to one of our licensed direct dealing (sales) representatives when you complete an application form to become a subscriber to our Bright Plan Registered Education Savings Plan (“RESP”) or use our self-serve website.

The personal information in your client record includes:

  • Your name, address, email address, occupation and birth date;
  • Your social insurance number for income tax reporting and other government purposes;
  • Your financial information including information related to your financial institution(s) and bank account information, and your estimated annual family disposable income and liquid net worth;
  • Information about beneficiaries such as the name, address, birth date and social insurance number of the child(ren) designated to receive benefits under your RESP;
  • Information we may need in the course of the administration of your RESP such as tax records, school transcripts and other documentation necessary to support claims or requests for various types of payments and benefits.

We may collect personal information, such as your name, contact information and information relating to the number and ages of your children, on a CST contest ballot or promotional entry form. We collect this information for the purpose of administering a contest or promotion. If you voluntarily provided your consent to be contacted to learn more about RESPs, the government grants and/or Bright Plan, a licensed direct dealing (sales) representative may contact you. We do not require such consent as a condition of your participation in the contest or promotional activity.

Automatic Collection:

We receive and store certain types of information when you interact with our websites, including use of the self-serve website. This may include information such as the type of internet browser or computer operating system you are using, the domain name of the website from which you linked to the website, the date and time you visit the website and the pages you visit on the website. In addition, when you view the website, we may store some information on your computer in the form of a “cookie”. Cookies are small pieces of data which are stored on your computer to allow your internet browser to remember something about a website, and for us to identify your computer and provide us with a record of your visits to our website. This statistical information helps us to understand how our website is used (e.g., which pages or sections are most popular and when are the peak activity times), which assists us in planning for future improvements to the site to better meet our visitors needs. At your option, you may turn off our cookies using the application features contained in your internet browser; however, doing so may prevent you from accessing all or parts of the website. We do not link your cookies to other personally identifiable information about you.

Social Media

We may offer you the opportunity to engage with us through third-party social networking websites, plug-ins and applications. Through these platforms, you may provide us with personal information or allow us to access information associated with your social media account. We may use this information to confirm your identity, respond to your posts or other inquiries and to personalize your experience on our website.

Information from Other Sources:

We may collect personal information about individuals you or other sources refer to us, such as their name, contact information and information relating to the number and age range of their children. We collect this information for the purpose of marketing products and services that you or the other sources believe may be of interest to them. We will not use this information for any other purpose without their consent. We will contact such individuals using the telephone number, residential address, or e-mail or other electronic address you or the other source have given us, and will provide your name or identify the other source in any such communication. If the individual referred does not want us to keep their information, we will remove it at their request (see “Withdrawing Your Consent” below).

Use of Personal Information

We collect and use your personal information for one or more of the following purposes:

  • To identify who you are;
  • To understand your needs;
  • To establish and administer your RESP;
  • To provide you with financial statements, tax receipts and other information about your RESP;
  • To improve our service offerings;
  • To improve our website;
  • To meet our legal and regulatory requirements;
  • To manage and assess our risks;
  • To protect us from error and to prevent or detect fraud or criminal activity;
  • To administer a contest or promotional activity; and,
  • To facilitate and administer gifting to RESPs.

In order to comply with our legal and regulatory obligations, we may share your personal information among the CST entities listed above when you apply for, or to determine if you may qualify for, a new product or service. We may also share your personal information among CST entities to keep your contact information and other personal information accurate and up-to-date, and to better manage your relationship with us. For example, if you update your personal information with one entity, we may use this information to update our records on other CST platforms.

We do not directly provide all the services related to your relationship with us. We may use third party service providers to process or handle personal information on our behalf and to assist us with various services such as the preparation and mailing of client statements, data processing, document storage and contest or promotional activity administration. Some of our service providers are located outside of Canada, including in the United States (US). We require our service providers to maintain the confidentiality and security of personal information and do not authorize them to use or disclose personal information for any purpose other than providing the services on our behalf or as otherwise required by applicable law.

We, or our trusted retail partners, may ask you for your contact information, such as your telephone number, residential address, e-mail or other electronic address for the purpose of marketing products and services that we believe may be of interest to you. We keep and use this information so that we may contact you directly through these channels for the purpose of marketing including telemarketing. Your consent to this is not a condition of doing business with us and you may withdraw it at any time (see “Withdrawing Your Consent” below).

From time to time, we may also send you information about products and services offered by third parties that we believe may be of interest to you, but we do not provide your name and contact information to any third parties for marketing purposes.

Disclosure of Personal Information

We disclose personal information in your client record to Employment and Social Development Canada (ESDC), Canada Revenue Agency, Revenu Quebec and any other government body necessary for the purposes of administering your RESP(s), and to otherwise comply with legal and regulatory requirements. We only disclose the information that is reasonably necessary for you to obtain the benefits of your RESP.

Certain personal information in a client record may be shared with the custodial parent of a beneficiary of an RESP.
CST and its Canadian, US and other third-party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order (including lawful access by US or other courts or governmental authorities), to an investigative body or as required by applicable Canadian, US or other law. We may also disclose personal information where necessary for the enforcement or protection of our legal rights, to investigate or prevent loss or harm to persons or property, or as otherwise permitted by law.

We may also disclose your personal information in connection with a change in corporate control such as merger, acquisition, sale, reorganization, transfer or stock sale.
Except as set out above, we will not otherwise sell, transfer or disclose any of your personal information to any third party without your knowledge and consent unless required or permitted by law.

Withdrawing Your Consent

Subject to legal, regulatory and contractual requirements, you may refuse to consent to our collection, use or disclosure of your personal or business information, or you may withdraw your consent to our further collection, use or disclosure of your information at any time in the future by giving us reasonable notice. Depending on the circumstances, however, withdrawal of your consent may impact our ability to provide you or continue to provide you with some products, services or information that may be of value to you and may result in you or your beneficiary not being able to receive benefits that you would otherwise be entitled to under your RESP. We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately.

Where appropriate, we will ask for your consent to send commercial electronic messages, such as e-mail. You may withdraw your consent to receive emails about other products and services offered by CST or its marketing partners excluding emails directly related to the administration of your account at any time by clicking the “Unsubscribe” link provided in the email. Alternatively, you may contact us or your licensed direct dealing (sales) representative using the contact information provided in the email to be removed from our mailing list.

Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry.

Third Party Links

Our website may include links to third party websites. Except as outlined in this Privacy Policy, we will not provide any of your personal information to these third parties without your prior consent. CST provides links to third party websites as a convenience to the user. The inclusion of any link does not imply CST’s endorsement of any other company, its websites, or its products and/or services. These linked websites have separate and independent privacy policies, which we recommend you read carefully. We have no control over such websites and therefore have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose and otherwise treat your personal information.

Security of Personal Information

We maintain reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. We will maintain the strict confidentiality of all personal information collected, and will only disclose such information to employees and authorized contractors of CST who require such information for the purposes set out above. We will keep your personal information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law. Even after you cease to be a CST client, we keep some information about you on file in order to meet certain legal requirements.

How to Contact Us about Privacy Concerns

If you would like to review or update the personal information in your client record or if you have any inquiries or comments about this Privacy Policy, please contact CST’s Chief Privacy Officer by mail at 1600-2235 Sheppard Avenue East, Toronto ON M2J 5B8 or by e-mail at privacy@cstspark.ca.

Other information

We may amend this Privacy Policy from time to time to take into consideration changes in legislation or other issues that may arise. The most up-to-date version of our Privacy Policy is always available on our public website.

Last updated: January 2018

 

Security

Security of information

Protecting your privacy and the confidentiality of your personal information has always been fundamental to the Canadian Scholarship Trust Foundation and C.S.T. Spark Inc., whether we conduct business with you through the Internet, over the phone or in your home.

This section contains the information you need to feel confident in dealing with us over the Internet. If you have any questions that we have not covered please contact us.

Internet privacy

As you navigate our website, we may collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our website (such as the Web pages viewed, and the links clicked) and when you viewed them (date and time).

When expressing an interest in obtaining additional information about Bright Plan, or registering to use the website or other services, we require you to provide us with personal contact information, such as name, address, phone number, and email address (“Required Contact Information”). If you have provided personal identifying information via the website or in an e-mail, this information will only be used to satisfy your specific needs and to provide you better customer service.

You will find direct links on our site to other websites. These third-party sites are not covered by this Security Statement.

Prospect and Contributor information

It is Canadian Scholarship Trust Foundation (“Foundation”) and C.S.T. Spark Inc. policy to comply with all federal and provincial laws pertaining to the privacy and confidentiality of prospect or customer information. In addition, it is inherent in the financial services business that we have a duty to protect the confidentiality and private nature of our contributors’ records. Please see our privacy policy which sets out the manner in which we will collect, use, disclose and otherwise manage your personal information.

Encryption

Encryption is the process of scrambling data into an unreadable format that is more secure for transmission over the Internet. Very similar to secret code, encryption takes your data and uses complex mathematical equations called algorithms to scramble the information into an unreadable format called ciphertext. The ciphertext is impossible to read without having a key to unscramble the information to its original form.

Information is scrambled or encrypted at the client side (your browser) and then unscrambled or decrypted at the server side (Canadian Scholarship Trust Foundation).

The encryption we use during our sessions to transmit your personal data is based on a 128-bit encryption.

Use of links

Links to other websites are not endorsements or approvals of such sites, the third parties named therein, or their products and services. Canadian Scholarship Trust Foundation cannot assume any responsibility for the availability of, or the content located on or through any external site nor shall Canadian Scholarship Trust Foundation assume any liability for any incompatibility, non-suitability, viruses or other destructive/disruptive components on or from such sites.

Use of email

Email over the Internet is not a secure medium and privacy cannot be assured. Canadian Scholarship Trust Foundation cannot assume any responsibility for any harm or damage you may experience or incur by sending personal or confidential information to Canadian Scholarship Trust Foundation over the Internet by email, or if we send such information at your request.