Privacy

Kaleido Growth Inc.

Personal Information Protection Policy

A question of trust

Since 1964, nearly 150,000 subscribers have placed their trust in the Kaleido Foundation (the “Foundation”) and its distributor, Kaleido Croissance Inc. (“Kaleido Croissance”) (collectively referred to as “Kaleido”).

Kaleido has built an enviable reputation for itself thanks to the sound management and security of its investments. The Personal Information it collects from its Clients must be thoroughly managed to guarantee its privacy, security, integrity and accuracy.

The products offered by Kaleido evolve, as do the methods of offering these to Clients, but Kaleido’s view on protecting the privacy of Personal Information remains unchanged.

This policy outlines how Kaleido protects Personal Information it holds and uses, specifically with regard to the management of scholarship plan agreements and government grants.

1. Definitions

Personal Information

All information that can be used to distinguish or trace an individual‘s identity is considered Personal Information, regardless of its nature or the format in which it is collected, i.e.: written, graphic, audio, visual, computerized or other.

The Personal Information collected by Kaleido varies based on the purpose for which it is collected.

For example, if a potential client requests information on the products offered by Kaleido, the only information required is the individual’s name and contact information. However, if a potential client wishes to open a scholarship plan, it becomes necessary to collect, among other information, this person’s financial information and social insurance number (SIN).

Client

Subscribers and Beneficiaries are considered to be Kaleido Clients. For the purposes hereof, all potential clients are included in the definition of the term “Clients”.

Subscriber

The individual/public guardian who opens a scholarship plan promoted by the Kaleido Foundation.

Beneficiary

The person designated by the Subscriber to receive educational assistance payments (EAPs) under the terms of the scholarship plan agreement.

2. Purpose of collecting personal Information

Kaleido undertakes to determine, prior to collecting Personal Information from its Clients, the purposes for which it will be used. Any person mandated by Kaleido to collect Personal Information must be capable of explaining how this information will be used.

The Personal Information of Clients is collected through various paper or electronic documents (forms) namely, the Account Opening Form, the grant application forms, referral coupons, information requests, contest entry/promotional event forms, surveys, etc.

These documents clearly indicate the purposes for which the Personal Information is collected by Kaleido.

Using the contact information on file, Kaleido will contact Clients by phone, email, or regular mail according to their preferred communication method.

3. Obtaining the Client’s Consent

Kaleido, through its authorized persons, only collects and uses the Personal Information of Clients after obtaining their consent to do so.

Generally, this consent is given by the individual in question or by a duly authorized third party (guardian or proxy) when the Personal Information is collected. In certain cases, Clients may give their consent verbally or by email.

If Kaleido must collect Personal Information from a third party, it is necessary to obtain the prior consent of the person for whom such information is collected.

Subject to the laws in force, Clients may withdraw their consent regarding their Personal Information at any time on written notice to Kaleido Croissance. In this event, Kaleido Growth must inform these Clients of the consequences of withdrawing their consent, specifically the impossibility to properly manage the scholarship plans to which they subscribed.

4. Responsibility

Kaleido also has the responsibility to enforce the legislation for the protection of Personal Information and this policy, and ensure the compliance of all employees, authorized persons, service providers and sales force representative likely to collect, use or access the database lists with the Personal Information of Clients.

5. Access to Personal Information

Kaleido exercises strict controls regarding access to the Personal Information of its Clients. Accordingly, only employees, representatives and service providers who genuinely need to view or edit the Personal Information of Clients are granted access to it. Accessing Personal Information for unwarranted reasons is not tolerated.

The Officer responsible for the protection of Personal Information ensures this policy is applied and takes all necessary measures to ensure the protection of the Personal Information held by Kaleido. In cases when Personal Information must be disclosed to a third party, e.g.: a service provider, Kaleido will only disclose the information necessary to carry out the mandate in question, and requires the service provider protect the confidentiality of the Personal Information by adopting policies with the same tenor and effect as those outlined herein.

Kaleido shall do everything in its power to apply the principles established herein to all its sectors of activity and to implement procedures intended to ensure the compliance of both head office employees and the sales force representatives, who are made aware of the importance of protecting Personal Information on a daily basis.

6. Restrictions – collecting and using Personal Information

Kaleido shall only collect the Personal Information of its Clients which is necessary to open and manage scholarship plans.

The Personal Information requested from Clients is that which allows Kaleido to meet its Know-your-Client (KYN) and suitability obligations, and that which is needed for the sound management of the plans, namely the information likely to be forwarded to the government for tax-related purposes or to apply for grant money.

Kaleido undertakes to collect, use and hold the Personal Information of its Clients in an honest manner and in accordance with applicable laws.

7. Accuracy of the information

Kaleido undertakes to do everything in its power to ensure the accuracy of the Personal Information it is entrusted, i.e. that which is collected from Clients at the time the plan is opened, as well as all subsequent changes brought to the information on file.

However, the Personal Information of Clients will not be updated systematically unless the operation in question requires such update.

Do not hesitate to contact our Customer Service to inform us of changes to your Personal Information or to check its accuracy.

8. Requests for access and correction of records

The Kaleido policy on the protection and use of Personal Information is available on written request or via the Kaleido website.

Kaleido also undertakes to inform anyone for whom it holds Personal Information of how this information is used and of his or her right to view such information.

Kaleido employees and representatives must be capable of responding to any questions or concerns Clients may have regarding the Personal Information collected or used to manage their files (accounts). If the answer provided is unsatisfactory to the applicant, he or she may contact the officer responsible for the protection of Personal Information identified hereunder to receive further information.

All Clients have the right to contest the accuracy of their Personal Information on file and request the applicable corrections be made.

Kaleido undertakes to diligently respond to requests for access to or correction of Personal Information.

Requests for access to and correction of Personal Information held by Kaleido must be sent in writing to the following address:

Officer responsible for the protection of personal information

Kaleido Growth Inc.
Centre d’affaires Henri-IV
1035 Wilfrid-Pelletier Ave., Suite 500
Quebec QC, G1W 0C5 

9. Identity verification

When a Client requests access to the information collected to open a scholarship plan account or that already on file, or to make changes/updates to such information, Kaleido employees and representatives must first confirm the applicant’s identity with certitude, according to the recognized or recommenced industry practices.

10. Complaint Processing

Clients may file a complaint regarding the protection of Personal Information by contacting the Officer responsible for the protection of Personal Information identified in the aforementioned paragraph 8.

11. Security Measures (Theft of Loss)

Kaleido has implemented material, organizational and technological security measures to reduce to a maximum the risks of theft, loss, undue disclosure or the unauthorized modification of Personal Information.

Kaleido regularly revises these measures to stay current and offer the best possible protection to its Clients regarding their Personal Information.

12. Management of the Policy

Authority in charge of adopting the policy

The Kaleido Foundation Board of Directors

Authorities in charge of applying and enforcing the policy

The Kaleido Foundation and Kaleido Growth Inc. through their designated officers

Policy’s date of acceptance of the policy: June 4, 2015

Policy’s date of entry into force: December 11, 2008

13. Amendements to the Policy

Kaleido reviews its Personal Information Protection Policy periodically to ensure it meets the highest standards.

Kaleido undertakes to make this policy and all amendments made thereto available on its website (www.kaleido.ca) as soon as reasonably possible.

 

Kaleido Financial Services Inc.

1. Definitions

  • Personal Information: All information of combination thereof that can be used to trace an individual’s identity is considered Personal Information, regardless of its nature or the format in which it is collected, i.e.: written, graphic, audio, visual, computerized or other.
  • Policyholder: The Policyholder is a natural person about whom Kaleido Financial Services Inc. collects, holds and uses Personal Information, including but not limited to clients, potential clients, spouses of clients, clients contacts, etc.

2. Purpose of Collecting Personal Information

The Personal Information collected by Kaleido Financial Services Inc. varies based on the purpose for which it is collected. Kaleido Financial Services Inc. undertakes to determine, prior to collecting Personal Information from its Clients, the purposes for which it will be used. Any person mandated by Kaleido Financial Services Inc. to collect Personal Information must be able to explain how this information will be used.

For example, if a person requests information on the products offered by Kaleido Financial Services Inc., the only information required is the individual’s name and contact information. However, if a person wishes to subscribe to an insurance policy, it becomes necessary to collect, among other information, this person’s financial information and social insurance number (SIN).

The Personal Information of Policyholders is collected through various paper or electronic documents (forms). Said documents clearly indicate the purposes for which the financial information is collected by Kaleido Financial Services Inc. Personal Information can also be collected during a recorded phone conversation with a customer service employee from Kaleido Financial Services Inc.

Using the contact information on file, Kaleido Financial Services Inc. may contact Policyholders by phone, email, or regular mail according to their preferred communication method. 

3. Obtaining Consent

Kaleido Financial Services Inc., through its authorized persons, only collects and uses the Personal Information of Policyholders after obtaining their consent to do so.

Generally, this consent is given by the Policyholder or by a duly authorized third party (guardian or proxy) at the time the Personal Information is collected. In certain cases, Policyholders may give their consent verbally or by email.

Before the Policyholder’s consent can be given, Kaleido Financial Services Inc. must disclose:

  • the necessary purposes for which the Personal Information is collected;
  • how the information will be used;
  • the categories of people who will have access to this information;
  • where the Personal Information will be held;
  • the Policyholder’s rights of access and rectification.

Subject to the laws in force, Policyholders may withdraw their consent regarding the use of their Personal Information at any time with a written notice to Kaleido Financial Services Inc. In this event, Kaleido Financial Services Inc. must inform the Policyholder of the consequences of revoking his consent.

4. Responsibility

Kaleido Financial Services Inc. also has the responsibility to enforce the legislation for the protection of Personal Information and this policy, and ensure the compliance of all employees, authorized persons, service providers and sales force representative likely to collect, use or access the database lists with the Personal Information of Policyholders.

5. Access to Personal Information

Kaleido Financial Services Inc. exercises strict controls regarding access to the Personal Information of Policyholders. Accordingly, only employees, representatives and service providers who genuinely need to view or edit the Personal Information of Policyholders are granted access to it.

In cases when Personal Information must be disclosed to a third party, e.g.: a service provider, Kaleido Financial Services Inc. will only disclose the information necessary to carry out the mandate in question, and requires the service provider to protect the confidentiality of the Personal Information by adopting policies with the same tenor and effect as those outlined herein.

Accessing Personal Information for unwarranted reasons is not tolerated.

The Officer responsible for the protection of Personal Information ensures this policy is applied and takes all necessary measures to ensure the protection of the Personal Information held by Kaleido Financial Services Inc. Kaleido Financial Services Inc. shall do everything in its power to apply the principles established herein to all its sectors of activity and to implement procedures intended to ensure the compliance of both head office staff and the sales force, who are regularly made aware of the importance of protecting Personal Information.

6. Restrictions: Collecting and Using Personal Information

Kaleido Financial Services Inc. shall only collect the Personal Information of Policyholders which is necessary to open and manage insurance policies, or for other legitimate purposes to which the Policyholder has given consent.

The Personal Information requested from Policyholders is that which allows Kaleido Financial Services Inc. to meet its Know-your-Client (KYC) and investment suitability obligations, and that which is needed for the sound management of the client files.

Kaleido Financial Services Inc. undertakes to collect, use, hold and destroy the Personal Information of Policyholders in an honest manner and in accordance with applicable laws.

7. Information Accuracy

Kaleido Financial Services Inc. undertakes to take all reasonable measures to ensure the accuracy of the Personal Information it holds, specifically at the time of subscription to one or several insurance policies and/or at the time any subsequent changes are brought to the information on file.

However, the Personal Information held by Kaleido Financial Services Inc. will not be updated systematically unless the operation in question requires such update.

Contact customer service to notify Kaleido Financial Services Inc. of any changes to your Personal Information or to check its accuracy.

8. Requests for Access and Correction of Records

Upon request and at not cost, Kaleido Financial Services Inc. undertakes to inform anyone for whom it holds Personal Information of how this information is used, of any third party disclosures, and of his or her right to view such information.

The files of Policyholders are kept at the head office of Kaleido Financial Services Inc. on computer support and certain files are also kept in archived hard copy. Therefore, it is not recommended for Policyholders to go directly to the head office to consult their files; it is rather recommended to proceed by written request, as explained hereinafter.

Policyholders may also request a copy of the Personal Information held by Kaleido Financial Services Inc., subject to certain reproduction fees.

Policyholders have the right to contest the accuracy of their Personal Information on file and to request rectification. A Policyholder may also request the removal of Personal Information that is expired or unjustified by the file’s subject. He or she may make written comments to add to the file held by Kaleido Financial Services Inc.

Kaleido Financial Services Inc.’s employees and representatives must be capable of responding to any questions or concerns Policyholders could have regarding the Personal Information collected or used to manage their files or other disclosed purposes. If the answer provided is unsatisfactory to the Policyholder, he or she may contact the officer responsible for the protection of Personal Information identified hereunder to receive further information.

Kaleido Financial Services Inc. undertakes to diligently respond to requests for access to, correction of or removal of Personal Information within a thirty- (30) day period.

Requests for access to and correction of Personal Information held by Kaleido Financial Services Inc. must be sent in writing to the following address:

Officer responsible for the protection of personal information
Kaleido Financial Services Inc.
Centre d’affaires Henri-IV
1035 Wilfrid-Pelletier Ave., Suite 500
Quebec QC, G1W 0C5

If necessary, the Officer responsible for the protection of personal information or Kaleido Financial Services Inc.’s customer service team can help you apply for access or rectification.

In the event of refusal or non-response from Kaleido Financial Services Inc. within thirty (30) days of application, Quebec residents may submit an Application for examination of a disagreement to the Commission d’accès à l’information du Québec (Information Access Commission).

9. Identity Verification

When a Policyholder requests access to the information collected to subscribe to one or several insurance policies, or to information already on file, or to make changes/updates to such information, Kaleido Financial Services Inc. employees and representatives must first confirm the applicant’s identity with certitude, according to the recognized or recommended industry practices.

10. Complaint Processing

Policyholders may file a complaint regarding the protection of Personal Information by contacting the Officer responsible for the protection of Personal Information identified in the aforementioned paragraph 8. The complaint will be handled in accordance with Kaleido Financial Services Inc.’s complaint handling policy, available upon request or online.

11. Security Measures (Theft of Loss)

Kaleido Financial Services Inc. aims to apply the best practices and has implemented material, organizational and technological security measures to reduce to a minimum the risks of theft, loss, undue disclosure or the unauthorized modification of Personal Information.

Kaleido Financial Services Inc. regularly revises these measures to stay current and offer the best possible protection to its Policyholders regarding their Personal Information.

12. Amendements to the Policy

Kaleido Financial Services Inc. reviews its Personal Information Protection Policy regularly to ensure it meets the highest standards. Kaleido Financial Services Inc. undertakes to make this policy and all amendments thereto available on its website (www.kaleido.ca) as soon as reasonably possible.