Privacy Policy

1. Who we are and what this policy covers

This website and newsletter are operated by Elite Wealth & Insurance Management (Edward Hambarchian, CLU, Insurance & Investment Advisor), referred to here as “we” or “us”. We follow the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada’s Anti-Spam Legislation (CASL).

This policy covers personal information collected through elitewealthinsurance.ca and our email newsletter. It does not cover information collected as part of an advisory or client relationship.

2. Information we collect

When you subscribe to our newsletter

• Your first name and email address.
• The date, time and IP address of your sign-up and of your confirmation, which we keep as a record of your consent.
• Whether our emails are opened and which links in them are clicked, along with the browser or email-app details and approximate time zone recorded at that time. We use this to understand which content is useful.

When you contact us

If you email or call us, we receive whatever information you choose to share, such as your name, email address, phone number and the content of your message.

When you visit the website

• Server logs. Like most websites, our web server automatically records each request: IP address, date and time, the page requested, the referring page and your browser type. These logs are used for security and to produce traffic reports, and are deleted automatically after about two weeks.
• Visitor statistics. We measure overall traffic with Umami and Plausible, privacy-focused analytics tools that we run on our own server rather than through a third party. They are designed to work without cookies and without storing your IP address, and they report totals such as page views and referring sites, not individual profiles.
• Calculators. The calculators on this site run entirely in your web browser. The figures you enter are not sent to us or stored.
• Cookies. This website does not place cookies on visitors’ devices. Cookies are used only when a site administrator logs in.

We do not use advertising networks, social-media tracking pixels or third-party advertising cookies.

3. Why we use your information

• To send you the newsletter you asked for, and to confirm your subscription.
• To reply to questions you send us.
• To keep a record of your consent and of any unsubscribe request, as CASL requires.
• To keep the website secure and working, and to understand in aggregate how it is used.

We will not use your information for any other purpose without first asking for your consent, unless the law requires or permits it.

4. Consent and our email practices (CASL)

• We only send our newsletter to people who have given express consent. When you sign up, we email you a confirmation link, and you are subscribed only after you click it.
• Every email we send identifies Elite Wealth & Insurance Management, includes our contact information, and contains an unsubscribe link.
• You can withdraw your consent at any time, free of charge, by clicking the unsubscribe link in any email or by contacting us (see section 10). Unsubscribe requests are processed without delay, and never later than 10 business days after we receive them.
• We do not buy, rent or use email lists from other sources.

5. We do not sell or share your information

We do not sell, rent, trade or share your email address or other personal information with third parties for their own marketing or any other purpose of theirs.

We rely on a small number of service providers who process information only on our behalf, to deliver the services described here:

• MailPoet (a service of Automattic Inc.) stores our subscriber list and delivers our newsletter emails.
• Liquid Web provides the server that hosts this website, its server logs and our visitor-statistics tools.

We may also disclose personal information if the law requires us to, for example under a court order.

6. Where your information is stored

Our website server is located in the United States, and our email service provider may store and process subscriber information outside Canada, including in the United States. Information stored in another country is subject to that country’s laws and may be accessible to its courts, law-enforcement and national-security authorities.

7. How long we keep it

• Newsletter subscribers: for as long as you remain subscribed. If you unsubscribe, we keep your email address and the date you unsubscribed, only so that we do not email you again. You may ask us to delete it entirely.
• Messages you send us: for as long as needed to respond and to keep a reasonable record of our correspondence.
• Server logs: about two weeks, after which they are deleted automatically.

8. How we protect it

The website is served only over an encrypted (HTTPS) connection, and access to the server and to our newsletter account is restricted to the people who need it. No method of transmission or storage is completely secure, but we use safeguards appropriate to the sensitivity of the information.

9. Your rights

Under PIPEDA you may:

• ask what personal information we hold about you and how it has been used;
• ask us to correct information that is inaccurate or incomplete;
• withdraw your consent, for example by unsubscribing, or ask us to delete your information where we are not required to keep it.

To make a request, contact us using the details below. We will respond within 30 days. If you are not satisfied with how we handled your request, you can contact the Office of the Privacy Commissioner of Canada at priv.gc.ca.

10. Contact us

Edward Hambarchian is responsible for our compliance with this policy. Questions, requests and complaints about privacy can be sent to:

Edward Hambarchian, CLU
Elite Wealth & Insurance Management
Email: edward@elitewealthinsurance.ca
Phone: (416) 816-6641

11. Changes to this policy

If we change this policy, we will post the new version on this page and update the date at the top. If a change affects how we use information you have already given us, we will ask for your consent where the law requires it.