Privacy Policy

At SeeWhy Financial Learning, Inc. [SeeWhy], we are committed to providing our retail students, learners, corporate customers, and sponsoring organizations [clients] with exceptional service. As providing this service involves the collection, use, and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.

We will inform our clients of why and how we collect, use, and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), outlines the principles and practices we will follow in protecting clients' personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to SeeWhy. This policy also applies to any service providers collecting, using, or disclosing personal information on behalf of SeeWhy.

Definitions

Personal Information - means information about an identifiable individual, including, but not limited to, name, home address, phone number, email address, account information, and Learning Data where it identifies or can reasonably identify an individual. Personal information does not include contact information (described below).

Learning Data - means personal information and related learner information collected, used, disclosed, transferred, stored, or processed in connection with SeeWhy products and services, including, but not limited to, name, email address, username, account ID, organization-issued identifiers such as employee ID, student ID, advisor or representative ID, course enrolments, subscription status, study activity, progress, quiz or test attempts, scores, results, completion status, login or activity dates, due dates, expiry dates, and other learning, progress, or performance indicators.

Sponsoring Organization - means an employer, firm, agency, school, association, corporate customer, referral partner, or other organization that purchases, pays for, sponsors, refers, assigns, administers, monitors, or otherwise facilitates access to SeeWhy products or services for a client or learner.

Contact information - means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email, or business fax number. Contact information is not covered by this policy. However, where contact information is combined with Learning Data or other information about an identifiable individual, the combined information may be treated as personal information under this policy.
Privacy Officer - means the individual designated with responsibility for ensuring that SeeWhy complies with this policy and PIPEDA.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect client information that is necessary to fulfill the following purposes:

• To verify identity;
• To identify client preferences;
• To deliver requested products and services;
• To enrol the client in a program;
• To ensure a high standard of service to our clients;
• To meet regulatory requirements;
• To collect and process payments;
• To monitor, support, and report on learner progress, completion, exam readiness, and learning performance;
• To administer training programs, subscriptions, course access, certification or compliance-related learning requirements, and related learner support;
• To provide Sponsoring Organizations and their authorized representatives with access to Learning Data where a client or learner's access to SeeWhy products or services is purchased, paid for, sponsored, referred, assigned, administered, monitored, or otherwise facilitated by a Sponsoring Organization;
• To operate, support, and improve learner-progress dashboards, reporting tools, analytics tools, web portals, learning management systems, and related technology platforms.

Policy 2 – Consent

2.1 We will obtain client consent to collect, use, or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided verbally, in writing, or electronically, or it can be implied where the purpose for collecting, using, or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, or the marketing of new services or products, and the client does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for SeeWhy to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client in making the decision.

2.5 We may collect, use, or disclose personal information without the client’s knowledge or consent in the following limited circumstances:

• When the collection, use, or disclosure of personal information is permitted or required by law;
• When the personal information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• To investigate an anticipated breach of an agreement or a contravention of law.

2.6 Where a client or learner's access to SeeWhy products or services is purchased, paid for, sponsored, referred, assigned, administered, monitored, or otherwise facilitated by a Sponsoring Organization, the client or learner's acceptance of the applicable agreement, terms of use, or EULA may include consent for SeeWhy to collect, use, disclose, transfer, store, and process Learning Data, including disclosure of Learning Data to the Sponsoring Organization and its authorized representatives.

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection, or for a purpose reasonably related to those purposes such as:

• To conduct client surveys in order to enhance the provision of our services;
• To contact our clients directly about products and services that may be of interest;
• To monitor, support, and report on learner progress, completion, exam readiness, and learning performance;
• To administer training programs, subscriptions, course access, certification or compliance-related learning requirements, and related learner support;
• To provide Sponsoring Organizations and their authorized representatives with access to Learning Data where permitted by consent, agreement, or applicable law.

3.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client lists or personal information to other parties.

3.4 Where applicable, we may disclose Learning Data to a Sponsoring Organization and its authorized representatives through a learner-progress dashboard or related reporting tool. This disclosure may include individual learner information, personal identifiers, course enrolment information, subscription status, progress, completion status, quiz or test attempts, scores, results, login or activity dates, due dates, expiry dates, and other progress or performance indicators.

3.5 We may use and disclose Learning Data to help Sponsoring Organizations stay informed about learners' progress, support course completion, identify learners who may require assistance, administer training programs, assess exam readiness, satisfy internal training or compliance requirements, and report on learner status and performance.

3.6 Learning Data may be transferred to, stored in, and processed by systems or service providers that are separate from the learning management system, web portal, or other learning tools used to deliver the Services, provided the transfer, storage, and processing are for the purposes described in this policy or in the applicable agreement, terms of use, or EULA.

Policy 4 – Retaining Personal Information

4.1 If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make all reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.

5.2 Clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification, or disposal or similar risks.

6.2 The following security measures will be followed to ensure that client personal information is appropriately protected:

• The use of locked filing cabinets;
• Physically securing offices where personal information is held;
• The use of user IDs and passwords;
• Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access);
• Contractually requiring any service providers to provide comparable security measures;
• Using appropriate administrative, technical, and contractual safeguards for learner-progress dashboards, reporting tools, analytics tools, web portals, learning management systems, and any related third-party or separate systems that process Learning Data.

6.3 We will use appropriate security measures when destroying client’s personal information such as shredding documents and deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Clients Access to Personal Information

7.1 Clients have a right to access their personal information, subject to limited exceptions.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.

7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer

8.1 The Privacy Officer is responsible for ensuring SeeWhy’s compliance with this policy and PIPEDA.

8.2 Clients should direct any complaints, concerns, or questions regarding SeeWhy’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of Canada.

Contact information for SeeWhy’s Privacy Officer:

Cory Snyder
[email protected]

READ ME FIRST: With the exception of LLQP and CIRO products, where SeeWhy Financial Learning is the course provider, purchasing SeeWhy Financial Learning exam preparation materials does not enrol you in the actual licensing course or exam. Our non-LLQP, non-CIRO exam preparation materials are designed to support your understanding of the applicable course content. However, you must still register with the applicable course provider to access their required course materials and write the exam.