This Privacy Policy explains how 49Maple Inc., which builds and operates Living My Plan™ (“Living My Plan,” “we,” “us,” or “our”), handles your personal information when your advisor uses Living My Plan as part of your Service Plan. If you’d like more detail on any part of it, contact us using the details in Section 10.
Most of your personal information reaches us through your advisor, not directly from you. Your advisor and their firm are responsible for the advice they give you and for their own record keeping. This policy covers what Living My Plan, as the technology provider, does with your information.
1. Information About You We Process
Depending on how your advisor sets up your Service Plan, the information we process about you may include:
- Your first and last name (your last name is visible only to your advisor in the tools they use to build your Service Plan, not on the Service Plan page you see)
- Your age (we do not collect your birthdate)
- General life circumstances your advisor notes as relevant to your planning
- General information about the accounts you hold, such as the type of account, where it is held, and whether it is on-book or off-book with your advisor’s firm. This does not include your account balances or values, which are not entered into Living My Plan
- A backup email address, used to help you regain access if you have trouble with your PIN, and where we may also send reminders and notifications you’ve set up
- Notes your advisor may add relating to your Service Plan
Living My Plan is not built to hold sensitive personal identifiers such as your Social Insurance Number, full account numbers, or banking credentials. If you notice information like this in your Service Plan that shouldn’t be there, please let your advisor know.
2. Where This Information Comes From
The large majority of the information in your Service Plan comes from your advisor and their firm, based on your existing relationship with them, not directly from you to us. Some information, like a backup email address for PIN recovery, may be provided directly by you when you set up access to your Service Plan.
3. How We Use Your Information
- To operate and display your Service Plan
- To let you securely access your Service Plan using your link and PIN, including account recovery
- To send you reminders you’ve set, or let you know when new resources relevant to you are available
- To support your advisor’s delivery of service to you, including maintaining the activity and audit record your advisor relies on
- To maintain the security and proper functioning of the Platform
We do not use your information to send you third-party marketing, and we do not sell, rent, or trade your personal information.
4. Who We Share It With
- Your advisor and their firm, who created and maintain your Service Plan
- Service providers who help us host and secure the Platform, under agreements requiring them to protect your information
- Others, only if required by law or to protect our legal rights
5. Where Your Information Is Stored and How It’s Protected
Information you provide directly to Living My Plan is hosted on servers located in Canada. Access to your Service Plan is protected by a unique link and a PIN that you set. We use reasonable administrative, technical, and physical safeguards to protect your information, but no online system can be guaranteed 100% secure. This policy covers Living My Plan only; we cannot speak to the practices of other tools or systems your advisor’s firm may use outside of Living My Plan.
6. How Long We Keep Your Information
We generally keep your information in the Platform for as long as your advisor’s firm maintains an active relationship with Living My Plan and with you. If that relationship ends, your advisor is able to print or export a record of your Service Plan’s activity before your access ends, and your advisor’s own obligations govern how your information is handled from that point.
7. Your Rights
You have the right to access and request correction of the personal information we hold about you, and to ask questions about how it’s used. Because most of your information comes to us through your advisor, the most direct way to exercise these rights is usually to speak with your advisor first. You’re also welcome to contact us directly using the details below, and we will work with you and, where appropriate, your advisor’s firm to respond.
8. Cookies
Your Service Plan page may use cookies or similar technology to keep you signed in and remember basic preferences. You can manage cookies through your browser settings.
9. Changes to This Policy
We may update this Privacy Policy from time to time. If we make a material change, we’ll post an updated version with a new date, and where appropriate, let you know within your Service Plan.
10. Contact Us
Questions or concerns about this Privacy Policy can be directed to our privacy officer:
Living My Plan is a 49Maple Inc. platform. LIVING MY PLAN™ is a trademark of 49Maple Inc.