Privacy Policy

We at First Inheritance Inc. and our affiliated companies (“First Inheritance”, “we”, “us”) are committed to protecting your privacy and safeguarding your personal information. This policy describes the types of personal information we collect, how it is used and disclosed, and the steps we take to safeguard your information.

Personal information we may collect

“Personal Information” means any information, recorded or unrecorded, about an identifiable individual, which either on its own or in combination with other information, could be used to identify an individual. Examples of the personal information that we may collect includes, but is not limited to, your contact information (name, address, phone number, email address), date of birth, occupation, credit history, social insurance number (SIN), financial information. Personal information does not include your name, business title, business address, and business telephone number.

Our collection and use of personal information

We will obtain your consent to collect, use or disclose your personal information. Your consent can be express or implied. An example of express consent is when you provide specific consent by ticking or clicking on a box on an application form. An example of implied consent is when you provide us with personal information voluntarily.

In most cases, we will collect personal information directly from you, with your consent, when you contact us, request information from us, purchase products or services from us, or otherwise interact with us about a product or service that we offer or provide (for example, when you email us or contact us through our website). Occasionally, we may collect personal information from a third party based on your consent or as otherwise permitted by law.

In some cases, the purposes for which we are collecting, using and disclosing your information will be apparent or implied from the circumstances. For example, when you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address, postal code and a phone number) along with additional information we need to help us answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service and product and service offerings.

Disclosure of personal information

We will not disclose, trade, rent, sell or otherwise transfer personal information for purposes other than as those set out herein, except with your consent or as required or permitted by law.

To assist us with offering the best services to you, we may share your personal information with our other companies and respective affiliates, which adhere to the same level of data protection.

We may transfer your personal information to third party service providers, our partners or agents in order for them to provide services to or on behalf of us. We will take steps to help ensure that any such service providers will provide a level of protection to your personal information comparable to that provided by us. Some service providers may be located outside of Canada where personal information may be subject to disclosure to governments, law enforcement or others pursuant to the laws of those jurisdictions. To obtain access to information about First Inheritance’s policies and practices with respect to service providers outside Canada, please contact our Privacy Officer as indicated below.

We may disclose your personal information in connection with a merger or sale involving all or part of our business or as part of a corporate reorganization.

Withdrawing Consent

You can withdraw your consent to any collection, use or disclosure of your personal information at any time on reasonable written notice, subject to permitted or required exceptions under Privacy Laws (e.g. where withdrawal of consent would frustrate a legal obligation such as collecting on a loan). While we will make reasonable attempts to provide alternative arrangements, in some situations, withdrawal of consent may also deprive you of a benefit or service. To change your consent to collection, use or disclosure of personal information about you, refer to the “Contact Us” section below.

Accuracy of your information

We use reasonable efforts to ensure that your personal information is as accurate, complete and up-to-date as necessary for the purposes for which such information was collected. However, you are responsible for advising us of any change in your contact information or other information necessary for us perform our obligations to you.

Safeguarding your information

We are committed to protecting the personal information in our possession or control from loss, theft, alteration and misuse.

We use a variety of security measures to protect your personal information including:

The safeguards employed by us to protect your personal information depend on the sensitivity, amount, distribution, format and storage of the personal information.

In addition to the steps we take to safeguard your personal information, we believe there are measures you should take to protect yourself as well.

We advise you to not share any personal or financial information with others unless you clearly understand the purpose of them requesting the information and that you have confirmed you are dealing with a legitimate contact. We also recommend that you not share any significant personal or financial information via email or voicemail.

Although technologies can make it easier for fraud to occur, we employ around the clock monitoring systems and controls to detect and prevent fraudulent activity. We also build fraud prevention measures into our due diligence processes and regularly update our fraud detection/prevention methods.

While we take precautions to protect your personal information from loss, theft, alteration, or misuse, no system or security measure is completely secure. Any transmission of your personal data is at your own risk and we expect that you will use appropriate measures to protect your personal information as well.

Retaining your personal information

We retain personal information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. Typically, we will retain information only so long as necessary for customer service, dispute resolution or other legal or business purposes.

Accessing to your personal information

You may contact our Customer Support Manager in writing by email or mail to access to your personal information or to request modification or correction of inaccuracies in your personal information. To confirm your identity, we may ask you to provide additional personal information such as your name and contact information and the contract number of any contract you have with First Inheritance for the supply of a product or service. We will attempt to respond to your written request within thirty (30) days. We will advise you in writing if we cannot meet your request or access within this time limit.

You may contact our Privacy Officer in writing with any complaints you may have regarding your personal information. Within a reasonable time upon receiving the written complaint, we will conduct an investigation, respond to the complaint and take any measures that may be appropriate to address the complaint.

Marketing communications

We may collect, use or disclose your personal information for secondary marketing purposes, such as sending you our newsletter or informing you about valuable offers and information that may be of interest to you. In most cases, we will obtain your express consent. In certain circumstances, consent may be assumed where we provide you with a readily exercisable means of telling us that you do not want your personal information used for such purposes (an ‘opt out’) and you do not exercise that option. In addition to any ‘unsubscribe’ or equivalent mechanism that may accompany our communications to you, you may withdraw or vary your consent regarding such marketing, at any time, by giving reasonable notice by telephone at 1.877.996.2233 or by contacting First Inheritance Customer Support by email or mail as indicated below (including your name and contact information).

Online Privacy Policy

While the internet is revolutionizing the way that we do business – providing convenient access to financial services from your home or office – we also recognize that it may bring legitimate concerns about privacy and security.

This Online Privacy Policy describes how your personal information is collected, used and disclosed when using or visiting our website or utilizing any of the online services offered by us.

  1. Controlled Access to your Information
    To ensure that you are the only person accessing your personal information, we restrict access to your online account by requiring that you enter your customer number and password to login. Only you know your password. Our employees do not have access to your password, and they will not ask you to reveal it. If someone does ask you to provide your password to them, we ask that you refuse to do so and contact us immediately.
  2. Online Banking Security
    To create a secure channel between your browser and our server, we use 128-bit Secure Socket Layer (SSL) encryption, the highest level available. To learn more about 128-bit SSL encryption, and our security policies, please review our security information.To provide you with a convenient method for purchasing financial services products, we provide secure online application forms. By nature, these forms capture personally identifiable information that we use to provide you with the products and services that you have requested. This information is processed in a fashion similar to that of application forms received through our other channels. The information contained in the application may be archived or stored, as governed by existing law or policy.

    However, despite these measures, our systems could be compromised by parties seeking unauthorized access to our data or users’ data, by a technological malfunction or in error by an employee, vendor or contractor. In addition, the transmission of information via the Internet or mobile data networks could be intercepted by third parties. As a result, our efforts to protect our data and users’ data from unauthorized access may be unsuccessful and we cannot assure you that the security measures we have adopted will provide absolute certainty. Any transmission by you is at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below. If we learn of a security systems breach, we will inform you and the appropriate authorities of the occurrence of the breach in accordance with applicable law.
  3. Website Usage Statistics
    To continually improve our Website, we often collect information about how our customers are using it. These usage statistics are only viewed in the aggregate – and are never tied to an individual.

    We use this information for purposes such as improving the pages where our customers are having difficulties and ensuring that we have the appropriate infrastructure in place to service future needs.

    The information collected may include your location, your IP address, your browser type and your operating system, as well as data that is passively generated as you browse, such as the number and types of pages visited, and the length of time spent per page and on the Website overall.
  4. Our use of Cookies
    We also use a key web technology called cookies. A cookie is a small information token that sits on your computer or mobile device. As you use any service offered through the First Inheritance Website, cookies are passed back and forth between our server and your browser. While cookies can be used for a variety of reasons, we only use cookies where they are of benefit to our customers.

    Specifically, we use two kinds of cookies – session cookies and persistent cookies. A session cookie exists only for the length of your browsing session and is deleted when you close your browser. A persistent cookie is a cookie that stays on your computer or mobile device after you close your browser. A persistent cookie may or may not expire on a given date. We use a session cookie to maintain the integrity of your internet session. With each page that you visit, the cookie is passed back and forth between our server and your browser. We use the cookie to distinguish your session from the many others that may be happening at the same time. Our session cookies never store any personal information, such as your name, or date of birth, or financial information, such as your accounts and balances.

    Most recent browser versions allow the user to set some level of control over which cookies are accepted and how your browser uses them. Many browsers will allow you to accept cookies from only known, reliable sites that you select such as the First Inheritance Website. If you are concerned about cookies, we encourage you to upgrade your browser to a recent version and review the Help section of your browser to learn more about its specific control features.
  5. Email
    If you choose to communicate with us electronically, we strongly recommend that you use our Contact Us feature. This feature provides a secure channel for sending us comments, questions or instructions.

    General email is not secure since it passes through many points on its route from you to us. If you are using general email to communicate with us, we strongly recommend that you do not include personal financial information (such as account numbers) within the email as we cannot guarantee its confidentiality en route to us.

    When you email us your comments, questions or instructions, you provide us your email address and we use it to correspond with you.

    We will not provide your email address to anyone outside of First Inheritance or our affiliated companies. We may use your email address to send you information about financial products or services that we think may be of interest to you. If you do not want us to contact you with product information by email, you may tell us so at any time by using the Contact Us feature. We will discontinue the practice.

    If you have asked us to provide you with information on a regular basis, or if we email you information about our products or services, you may ask us to remove you from the list at any time. We intend to include instructions to unsubscribe from the list in every mailing, and on the site where you originally subscribed to the list.
  6. Links to Other Sites
    First Inheritance’s website may also contain links to other websites or internet resources. However, First Inheritance has no responsibility or liability for or control over these other websites or internet resources or their collection, use and disclosure of your personal information. Always review the Privacy Statements of the sites that you are viewing.

    You should be aware that off-site pages or other sites might be available only in English or in other languages.

Where we store your Personal Information

The personal information you provide to us is primarily stored on servers in Canada. However, we maintain secondary disaster data back-up on computer systems that may be located outside of Canada. Personal information collected by us pursuant to our Privacy Policy may be stored, whether as part of our secondary disaster data back-up or otherwise, on out-of-country computer systems, and therefore may be subject to disclosure pursuant to the laws of the jurisdictions where such personal information data is stored. We will disclose personal information as required by law.

Monitoring of Telephone Calls

We may monitor and/or record in-bound and out-bound telephone calls as permitted by law for training and quality assurance purposes, to detect and prevent fraud or other losses, and to

enforce our contracts. Any recording obtained from monitoring telephone calls is treated as confidential.

Contact Us

If you have any questions, concerns or complaints about our privacy policies or are uncomfortable about any information or requests you receive from First Inheritance via phone, fax or email, we encourage you to contact us immediately at 1-855-683-2881. In most cases, any questions or concerns that you have can be resolved by discussing it with us or our Privacy Officer.

You may contact our Privacy Officer:

If you are not satisfied with how we have attempted to resolve your questions, concerns or complaints, please consult the federal or provincial privacy commissioner in your jurisdiction whose information can be found online at the below sites.

Canada www.priv.gc.ca
British Columbia www.oipc.bc.ca
Ontario www.ipc.on.ca
Alberta www.oipc.ab.ca

Protecting your privacy – we’re in it together

This policy is subject to change. Please review it from time to time. If we make changes, we will amend the “revised” date at the bottom. Any changes will become effective when we publish the revised Policy. If we make any material changes, we will notify you by mail, email or by means of a notice on the Website commensurate with or prior to the change becoming effective.