Privacy

Personal Information Protection Policy

A question of trust

Since 1964, nearly 150,000 subscribers have placed their trust in the Universitas Foundation of Canada (the “Foundation”) and its exclusive distributor, Universitas Management Inc. (“Universitas Management”) (collectively referred to as “Universitas”).

Universitas 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 Universitas evolve, as do the methods of offering these to Clients, but Universitas’ view on protecting the privacy of Personal Information remains unchanged.

This policy outlines how Universitas 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 Universitas varies based on the purpose for which it is collected.

For example, if a potential client requests information on the products offered by Universitas, 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 Universitas 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 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

Universitas undertakes to determine, prior to collecting Personal Information from its Clients, the purposes for which it will be used. Any person mandated by Universitas 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 Universitas.

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

3. Obtaining the Client’s Consent

Universitas, 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 Universitas 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 Universitas Management. In this event, Universitas Management 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

Universitas 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

Universitas 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 Universitas. In cases when Personal Information must be disclosed to a third party, e.g.: a service provider, Universitas 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.

Universitas 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

Universitas 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 Universitas 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.

Universitas 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

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

Universitas 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.

Universitas 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.

Universitas 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 Universitas must be sent in writing to the following address:

Officer responsible for the protection of personal information

Universitas Management 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, Universitas 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)

Universitas 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.

Universitas 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 Universitas Foundation Board of Directors

Authorities in charge of applying and enforcing the policy

The Universitas Foundation of Canada and Universitas Management 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

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

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

 

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