This Privacy Policy describes how 49Maple Inc., operating Living My Plan™ (“Living My Plan,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information about advisory firms and the individual advisors and team members who use the Living My Plan platform (the “Platform”), in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Canadian privacy law.
This policy covers advisor and firm information only. Information about your clients is addressed separately in the Client Privacy Policy, since your clients’ information generally reaches us through you, not directly from us.
1. Information We Collect
We collect personal information about advisors and team members that you or your firm provide when you:
- Register your firm or create an individual user account
- Are added to the Platform by your firm as an advisor or team member
- Contact us for support or communicate with us
- Make a payment for a subscription
This may include: full name, business email address and phone number, firm name and role, login credentials, billing and payment information (processed securely by our payment provider), and records of your use of the Platform (such as log-in activity and support requests).
Living My Plan also maintains an activity log within the Platform for service quality and audit purposes. For example, if a team member updates a piece of client or service plan information, that change is recorded, and the log can be accessed by your firm’s account administrators.
2. How We Use Advisor and Firm Information
- To provide, operate, and maintain the Platform
- To manage your firm’s subscription, billing, and account
- To communicate with you about your account, service updates, and support
- To improve the Platform, including through aggregated and de-identified usage analysis
- To detect, prevent, and address technical issues, fraud, or misuse
- To comply with legal and regulatory obligations
3. Marketing Communications
With your consent, we may send communications about product updates, resources, or offers, in compliance with Canada’s Anti-Spam Legislation (CASL). You may withdraw consent at any time using the unsubscribe link in our emails or by contacting us at privacy@livingmyplan.com.
4. Disclosure of Information
We do not sell, rent, or trade advisor or firm personal information. We may share it:
- With service providers who help us host, operate, secure, or support the Platform (for example, cloud hosting and payment processing providers), under agreements requiring appropriate safeguards
- If required by law, regulation, or a valid order from a regulatory or governmental authority
- To protect our legal rights, investigate misuse, or enforce our Terms and Conditions
5. Where Your Information Is Stored
Living My Plan hosts data on servers located in Canada. If this changes, or if a service provider we use processes data outside Canada, we will update this policy to reflect that.
6. Data Security
We use administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
7. Retention
We retain advisor and firm account information for as long as your firm maintains an active subscription, and for a reasonable period afterward to meet legal, accounting, billing, and dispute-resolution needs. We may retain limited records beyond that period where required by law.
8. Your Rights
Subject to applicable law, you have the right to:
- Access the personal information we hold about you
- Request correction of inaccurate or incomplete information
- Withdraw consent to certain uses of your information, subject to legal or contractual limitations
- Request deletion of your personal information, subject to our legal and legitimate business retention needs
To exercise these rights, contact our privacy officer using the details in Section 11.
9. Cookies and Tracking Technologies
The Platform may use cookies and similar technologies to keep you signed in, remember preferences, and understand how the Platform is used. You can manage cookie preferences through your browser settings; disabling cookies may affect Platform functionality.
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will post the updated policy with a new “Last updated” date, and where changes are material, we will provide additional notice by email or within the Platform.
11. Contact Us
Questions or concerns about this Privacy Policy, or requests to exercise your privacy rights, can be directed to our privacy officer:
Living My Plan is a 49Maple Inc. platform. LIVING MY PLAN™ is a trademark of 49Maple Inc.