Voyant Privacy Policy

Last Revised: June 26, 2020

Introduction

This is the privacy policy for www.planwithvoyant.com ("Site"). We are committed to protecting and respecting your privacy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Our Site is operated by Voyant, Inc. and its affiliates ("Voyant", "we", "our" or the "Company"). The Site allows financial advisers and clients work together to plan their financial investments ("Service").

Users of the Service may be either a financial adviser who has executed an agreement with Voyant ("Customer") or clients of a Customer, i.e. individuals seeking financial advice from the Customer, whom the Customer has as permitted by their commercial agreement with Voyant granted access to the Service ("Client User") (collectively Customer and Client User shall be referred to as "Users" or "you").

This Privacy Policy ("Privacy Policy") explains the types of information we may collect from Users or that End Users may provide when visiting the Site and/or using the Services. This Privacy Policy also describes Voyant's practices for collecting, using, maintaining and processing information. This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

By visiting our Site and/or using our Services you acknowledge you have read, understood, and agreed to this Privacy Policy and our Terms of Use. For more information about how we secure your information, please visit our Security Policy. For details on how we use cookies, visit our Cookies Policy. Our Security Policy, Cookies Policy, and Privacy Policy are incorporated into and form part of our Terms of Use.

For residents of Canada, personal information (as the term is defined in the Personal Information Protection and Electronic Documents Act of Canada ("PIPEDA")) will be collected, stored, used and/or processed by Voyant in compliance with Voyant's obligations under PIPEDA and/or other federal and provincial privacy laws, as applicable ("Data Protection Law").

Voyant will be in custody or control of certain information provided by a User directly to Voyant and certain analytical information which Voyant may collect about each User's use of the Site.

We may amend or update this Privacy Policy from time to time, by changing the Privacy Policy on the Site and/or by notifying you when you return to the Site, or by email. Any amendments will take effect 7 days after they are published. We encourage you to periodically review this page for the latest information on our privacy practices.

No system is perfectly secure or reliable, the Internet is an inherently insecure medium, and the reliability of hosting services, Internet intermediaries, your Internet service provider, and other service providers cannot be assured. When you use the Site and/or Service, you accept these risks, and the responsibility for choosing to use a technology that does not provide perfect security or reliability. In particular, you acknowledge that you are aware of, and accept as satisfactory, our Security Policy.

Information collected and how it may be used

Data we collect about you from your use of the Site and/or Service

The type of information is non-identifiable and anonymous information ("Non-personal Information"). We are not aware of the identity of the User from which we have collected Non-personal Information. Non-personal Information is any unconcealed information which is available to us while Users are using the Site and/or Service. Non-personal Information which is being gathered consists of technical information and behavioural information and which may include, the User's Internet protocol (IP) address used to connect your computer to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the User's 'click-stream' on the website, the period of time the User visited the website, methods used to browse away from a page, and any phone number used to call our customer service number.

Data you give us

In general, you can browse the Site without telling us who you are or revealing personal information about yourself. To access some areas of the Site and our Service, we may require you to provide various contact and identity information, billing information, and other personal information as indicated on the relevant forms on the Site (which vary, depending on what kind of user you are). Where possible, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use our Site and Service.

This information is given by Users directly to us and may identify you and any others for whom you provide us with information and may be of a private and/or sensitive nature.

This is information about you that you give us by filling in forms on our Site or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our Site, subscribe to our Service, search for products and services, subscribe for Services on our Site, submit a query, and when you report a problem with our Site.

By providing us with any information, you agree that you have all necessary consents and rights to do so, and agree that the indemnity you give to us in the Terms of Use applies to any non-compliance by you with this requirement.

If you choose to use our referral service to tell a friend about our Site, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting them to visit the Site. Voyant stores this information for the sole purpose of sending this one-time email, tracking the success of our referral program, and compliance with laws. Your friend may contact us at to request that we remove this information from our database.

Data we collect about you from third parties

This is data we receive about you but which you have not given us directly and will include information we collect about you from your use of other services that we may provide.

You do not have any legal obligation to provide any information to us however, we require certain information in order to provide the Services. If you choose not to provide us with certain information we may not be able to provide you with the Services.

Why we collect such information

Information you give to us

We will use this information to:

• carry out our obligations arising from any contracts entered into between you and us and/or any contracts entered into between a Customer and Client User and to provide you with the information, products and Services that you request from us;
• administer your account with us, including billing;
• provide you with information about services we feel may interest you, if you have given your consent to receiving marketing material from us at the point when we collected the information you gave us;
• notify you about changes to our Service;
• contact you for the purpose of providing you with technical assistance and other related information about the Service;
• reply to your queries, troubleshooting problems, detect and protect against error, fraud or other criminal activity; and
• ensure in our legitimate interests that content from our Site is presented in the most effective manner for you and for your computer.

Information we collect about you from your use of our Site

We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:

• to administer our Site under our terms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to keep our Site safe and secure;
• to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
• measure consumer interest in our services;
• to allow you to participate in interactive features of our Service, when you choose to do so; and
• to make suggestions and recommendations to you and other Users of our site about Services that may interest you or them.

Sharing information gathered through Service and Site with third parties

We may disclose your information to members of our group and third parties. For a list of the third party organizations with whom information may be shared, please reach out to our team at .

Members of our group

We may disclose your information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy.

Third parties

We may disclose your information to our selected third parties, which may include:

• analytics and search engine providers that assist us in the improvement and optimization of our site and subject to this policy (this will not individually identify you);
• data processors who process your personal data on our behalf and in accordance with our instructions and applicable data protection law; and
• payment intermediaries in the course of the payment process.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of our Privacy Policy.
• If Voyant or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. If Voyant is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
• If we are permitted or required by law to disclose your personal data. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose your personal information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding, and (c) as otherwise required or permitted under any applicable law, rule, or regulation
• In order to enforce or apply our Terms of Use and other agreements with you.
• To protect the rights, property, or safety of Voyant, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Where we store your data

The information you provide through the Site and the Service is hosted and stored on servers in North America.

To facilitate our global operations, we may transfer and access such personal information from around the world, including from Canada, the United States, and other countries in which Voyant has operations. Therefore, your personal information may be processed in Canada and the United States. Where your information is transferred between jurisdictions, we will take all steps reasonably necessary to ensure that your information is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism and standard contractual clauses for the transfer of data, and that it is treated securely and in accordance with this Privacy Policy.

Your rights in respect of data in our custody or control

You have the right under certain circumstances:

• to be provided with a copy of any personal information we hold about you;
• to request the rectification or erasure of your personal information held by us;
• to request that we cease processing your data;
• to request that we restrict the processing of your personal information (for example, while we verify or investigate your concerns with this information);
• to request that your User Personal Data be transferred to a third party; and
• to withdraw your consent to the processing of your personal information.

You can also exercise the rights listed above at any time by contacting us at .

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.

Security and storage of information

We take a great care in implementing, enforcing and maintaining the security of the Service, Site and your personal information. Voyant implements, enforces and maintains security policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of personal data and monitor compliance of such policies on an ongoing basis.

Voyant maintains documentation regarding compliance with the requirements of the law, including without limitation documentation of any known breaches and holds reasonable insurance policies in connection with data security.

Voyant aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the shortest time period necessary to fulfill the purpose for which the data is gathered. Voyant only collects data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy.

Data retention

We will retain your information for as long as your account is active or as needed to provide you services.

Our goal is to retain your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; this retention period may extend past the point at which you close your account.

The criteria that will be used for determining periods of retention will be based on the type of data. For example, data relevant to accounting information will be retained for at least 7 years, whereas temporary cookie data of a web visitor may not be retained at all.

Breach notification

In the event of a security and/or privacy breach, we will notify the necessary authorities and impacted customers within the legally required timelines based on the applicable Data Protection Law.

Privacy authority

You may have the right to lodge a complaint with a privacy authority in your jurisdiction (such as the Office of the Privacy Commissioner of Canada, or one of its provincial counterparts) in case of a breach of certain laws and regulations. To request their contact information, please contact us.

Questions and contact information

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to contact us at .