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1. CM’s Commitment to Privacy
CM is committed to protecting the privacy of our Advisors and customers. We have and will take measures that protect the privacy of personal information held by us.
- why we collect personal information;
- what we do with that information;
- what steps we take to ensure that the information is secure;
- who you should contact if you have questions or concerns about our policies or practices.
Children: We encourage parents to take an active interest in their children’s use of the Internet. We do not intend to collect information from children who are under 18 years of age. If you are under 18, please do not provide information on our Site.
2. What is personal information?
In general terms, personal information means any information about an identifiable individual. For example, this includes your name, postal and email address, telephone number, credit card number, banking information, demographic information, country you are accessing our system from and purchasing history. Personal information does not include aggregate information, such as data about a group or category of products or customers from which individual customer identities have been removed. For example, information about the products you purchase may be collected and combined with information about the products purchased by others but no personal information will be included in the resulting data.
We may also gather aggregate information about how CM customers use our Site. Aggregate information about product purchases helps us understand trends and customer needs, and assists us in product selection and the introduction of new products.
3. When we collect personal information.
We only collect such personal information as is strictly necessary for the purposes outlined in the next Section. We collect personal information when you:
- sign up as an Advisor;
- opt into (subscribe) our newsletter e-mailing program;
- contact us with questions, inquiries, comments, complaints or requests;
- use our Site;
- create an account;
- place orders, or seek further information about our products; and
- enter into a contest or respond to one of our surveys;
4. How we use personal information.
As part of our business operations, we hold and use certain personal information pertaining to you in order to process your requests and to understand your needs so that we can serve you better. Specifically, we may use personal information for the following purposes:
- Approving you as an Advisor if you apply to be an Advisor;
- Managing invoicing, accounting and information security services related to our transactions with you such as processing orders, payments and payments to Advisors;
- To fulfill your online orders and to facilitate product deliveries and returns;
- To send you information and updates pertaining to your orders;
- Internal management purposes, including planning, resource allocation, policy development, quality improvement, monitoring, audit, evaluation and reporting;
- To respond to your questions and concerns, to understand your needs and preferences and to monitor your satisfaction with our products;
- To detect, prevent, or otherwise address fraud, security or technical issues;
- Protecting against harm to the rights, property or safety of CM, its customers, employees, or the public;
- To create aggregate information as described above.
- To improve our customer service, products and services or improve our Site and to facilitate and monitor certain features of the Site that you choose to interact with;
- To provide you with customized Site content and advertising
- To run promotions, contests, surveys and other research;
- To send you information you agreed to receive about topics we think will be of interest to you;
- To manage our Newsletter subscription lists;
- If you are an Advisor with an up-line Advisor, to inform that up-line Advisor that you have signed as part of his or her down-line group;
- If you are an Advisor, to list your name on the Advisor Locator unless you opt out of the Advisor Locator;
- If you are a Customer, to inform an Advisor that you have placed an order using their URL;
- If you opt-in to one of our publications, you will receive emails that may include company news, updates, related product or service information, etc. (If at any time the you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via our Site);
5. When we share personal information.
From time to time we engage unaffiliated third parties and their affiliates, agents and subcontractors (“Service Providers”) to perform certain technological or administrative services. For example, a Service Provider may be asked to perform credit card processing services or ETF direct deposit payments. We also may use a Service Provider to host and administer our Site, process and store data, and fulfill similar technology-related functions on our behalf. In these circumstances, the personal information that the Service Provider receives is limited to only the personal information held by us that they need in order to render their service to us. The companies that are provided with the personal information are first required to sign an agreement that obligates them to keep the information confidential and secure and prohibits them from using it for unauthorized purposes.
We may engage Service Providers to provide us with cloud computing services. Cloud computing is the provision of network-based services, located on remote computers, that allow individuals and businesses to use software and hardware operated by third parties. Examples of these services include online file storage, webmail and online business applications. Service Providers have policies and processes in place to ensure that the confidentiality of information in their care is properly safeguarded at all times.
You acknowledge that if Service Providers provide services from other countries, your personal information may be processed and stored in these countries and the governments, courts or law enforcement or regulatory agencies of these jurisdictions may be able to obtain disclosure of your personal information through a lawful order.
We may disclose personal information without your knowledge or consent if a law, regulation, search warrant, subpoena or court order legally authorizes us or requires us to do so. We may also disclose personal information to protect the rights, property or personal safety of CM, its customers, employees or other members of the public.
We reserve the right to transfer any and all information that we collect from visitors, or that we otherwise collect concerning or in connection with the Site, to a third party in the event of a sale or other transfer of assets or of any portion of our business. In the event we enter a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your information may be among the assets transferred.
Except as set out above, or as provided in Section 10 below, we do not sell, rent, share or disclose the personal information we hold without your consent.
6. How long do we hold personal information?
Personal information is retained only for so long as is necessary for the purposes set out above. When no longer required, we will destroy, erase or de-personalize the personal information. Legal requirements may necessitate our retaining some or all of the personal information we hold for a period of time that is longer than we might otherwise hold it. However, CM will restrict access to such information to prevent it from being used except for the fulfillment of these legal requirements.
To ensure that the personal information you provided is accurate, complete and up-to-date, we urge you to provide us with updates regarding such information and to inform us of any errors affecting the personal information we hold.
8. Security measures.
We will continue to keep in place security measures in an effort to protect personal information held by us from unauthorized use, access, disclosure, distribution, loss or alteration. We employ physical, administrative, contractual and technological safeguards to protect personal information, and insist that our Service Providers do the same. Access to personal information will be restricted to authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties. Please also see our “Online Privacy Practices” in Section 10 below.
We periodically update our policies regarding information security measures in an effort to protect the personal information held by us in the most effective manner possible.
9. Accessing personal information.
Our customers are entitled to access the personal information held by us concerning them. You can access your personal information by contacting us at the address below. We will generally respond to your request for information within thirty (30) days, unless, for reasons beyond our control, a longer response time is necessary, in which case you will be advised accordingly. While our response will generally be provided at no cost, you will be informed in advance of any charges that apply in connection with the information request.
10. Online privacy practices.
Collection: We may collect personal information online when you visit our Site as described in Section 3 above.
Cookies help us to customize our home page for you and to better display pages according to your browser type. While cookies are optional for browsing, they are required for registering, logging on, purchasing or adding items to your cart. If you wish to purchase items or set up an account on the Site, you will need to accept a cookie. (In order to control the ability of website providers to place cookies on your computer, you should consult your browser’s “Options” and “Help” pages to learn how to adjust your settings to suit your privacy preferences.)
Use: We may use personal information collected online as described in Section 4 above.
Sharing: We share personal information collected online as described in Section 5 above. In addition, we may provide Service Providers with certain information that is necessary to fulfill an order you have placed with us. We also may use Service Providers to host and administer the Site, process and store data, and fulfill other technology-related functions on our behalf. However, we only give or permit access to vendors, suppliers and other Service Providers involved in Site administration and the commerce distribution chain the limited information needed to perform their duties and provide you with the products. We are not responsible for any additional information you provide directly to these parties.
Protection: Personal information we collect on our Site is stored electronically, and may be combined with other off-line information. Personal information entered on our Site is encrypted using a security protocol called SSL (Secure Sockets Layer). SSL encrypts information entered on our site before it is sent over the Internet. SSL also allows you to view securely your online account and registration information.
Account information is accessible online only through the use of a password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of our Site by any person using your password.
You are advised that, unlike communication within our Site, we have no control over the privacy of your email communications with us while in transit. We recommend that you do not include confidential, proprietary, personal information in emails, including credit card numbers, passwords and other similar information. Also, if other people have access to your email account, they may be able to access your password and obtain personal information about you (such as your credit card information), or change information about your user profile. You should not use an email account operated by your employer because many employers have the legal right to access such email accounts. Please advise us immediately by email if you believe your password has been misused.
Some sites you access may be managed by a CM Advisor, and they may request your personal information in order to assist in providing requested services. CM Advisors (and not CM) are individually responsible for ensuring the security and privacy of any personal information you give to them. We encourage you to familiarize yourself with their privacy policies to gain an understanding of the manner in which they will handle information about you.
11. Complaint process.
If you wish to unsubscribe from electronic messages providing news, promotions, special offers and other information from CM, regarding CM you may do so at any time by clicking on the “Unsubscribe” feature on each electronic message.
CM Canada Holdings Inc.
C/O 640 60th Street South
St Cloud, MN 56301
Attn: Privacy Officer