1. Scope and accountability
Espanioli Financial (“we,” “us,” or “our”) is responsible for the personal information under its control. This policy explains how we handle personal information collected through our website, our communications with you, and our services. It is intended to support our obligations under applicable Canadian privacy law, including Alberta's Personal Information Protection Act where applicable.
Our privacy lead is accountable for our privacy practices. To ask a question, make a request, or raise a concern, contact the privacy lead at ef@admin.ca.
2. Personal information we collect
Depending on how you interact with us, we may collect:
- contact and identity information, such as your name, email address, telephone number, and the information you provide in a form or message;
- account and service information, including information needed to administer an account or respond to a request;
- communications and records of our interactions with you; and
- website, device, and security information, such as your IP address, browser and device characteristics, pages or features used, and limited activity records associated with an authenticated account.
We collect information directly from you, automatically when you use the Website, and from third parties where permitted by law and relevant to our relationship with you.
3. How we use personal information
We use personal information to:
- respond to inquiries and communicate with you;
- provide, administer, and support our services and accounts;
- protect people, accounts, and the Website; detect, investigate, and prevent fraud, misuse, and security incidents;
- understand and improve the Website and our services;
- meet legal, regulatory, recordkeeping, and audit obligations; and
- seek your consent for optional analytics or marketing activities.
We collect, use, and disclose personal information only for purposes that are reasonable in the circumstances and as permitted or required by law. Where consent is required, we will seek meaningful consent.
4. Consent and your choices
By providing personal information or using our services, you consent to the handling described in this policy, except where the law permits or requires otherwise. You may withdraw consent to optional uses at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal may affect our ability to provide a requested service or feature.
5. When we disclose information
We do not sell personal information. We may disclose it to service providers and professional advisers that help us operate our business and provide services; to financial institutions or other parties when necessary for a requested service or transaction; to regulators, courts, law enforcement, or other authorities where permitted or required by law; and in connection with a business transaction, where permitted by law. We require service providers to protect information and use it only for authorized purposes.
6. International processing
Some of our service providers may process personal information outside your province or Canada. Information processed in another jurisdiction may be subject to its laws and may be accessible to courts, law enforcement, or other authorities there. You may contact our privacy lead with questions about our use of service providers outside Canada.
7. Retention
We retain personal information only for as long as needed for the identified purposes, legal and regulatory requirements, dispute resolution, and legitimate business records. We securely delete, anonymize, or otherwise dispose of information when it is no longer needed. Website security and authenticated activity records are generally retained for 90 days, unless a longer period is needed for a lawful purpose.
8. Safeguards
We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information and the nature of the activity. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
9. Cookies and similar technologies
We use necessary cookies to operate the Website, protect it, and remember your privacy choices. With your consent, we may also use optional analytics or marketing cookies to understand usage and measure campaigns. You can accept, reject, or change optional cookie choices through the Cookie settings link in the Website footer. You can also adjust your browser settings, although blocking necessary cookies may affect Website functionality.
10. Access, correction, and complaints
Subject to applicable law, you may request access to or correction of your personal information, ask about our handling of it, or make a privacy complaint. Contact our privacy lead at ef@admin.ca. We may need to verify your identity before acting on a request. If we cannot resolve your concern, you may have the right to contact the applicable privacy regulator, including the Office of the Information and Privacy Commissioner of Alberta or the Office of the Privacy Commissioner of Canada.
11. Updates to this policy
We may update this policy from time to time. The current version will be posted on this page with a revised “Last updated” date. Where required, we will provide additional notice of material changes.