Privacy Policy
Effective date: May 27, 2026 — Last reviewed: May 2026
Canadian Wealth Creation Centre Inc. (CWCC), operating as CWCC and ibcfinancial.com, is committed to protecting the personal information of every individual we serve. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA, S.C. 2000, c. 5) at the federal level and, for individuals in Quebec, in accordance with the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1, as modernized by An Act to modernize legislative provisions as regards the protection of personal information, S.Q. 2021, c. 25, commonly referred to as Law 25).
This policy applies to personal information collected through cwcc.ca, ibcfinancial.com, financierecbi.com, any associated booking or scheduling platforms used by CWCC, and through the direct client engagement process including insurance applications, policy administration, and ongoing coaching relationships.
1. Accountability — Our Privacy Officer
CWCC is accountable for the personal information under its control and has designated a Privacy Officer responsible for CWCC’s compliance with PIPEDA and, for Quebec clients, Law 25. The Privacy Officer is the first point of contact for any privacy question, access request, correction request, or complaint.
Privacy Officer: [PRIVACY OFFICER NAME — COMPLETE BEFORE LAUNCH]
Organization: Canadian Wealth Creation Centre Inc. (CWCC)
Address: [REGISTERED OFFICE ADDRESS — COMPLETE BEFORE LAUNCH]
Email: [PRIVACY EMAIL — COMPLETE BEFORE LAUNCH]
Phone: [PHONE NUMBER — COMPLETE BEFORE LAUNCH]
The Privacy Officer’s contact information is published in accordance with the requirement under Law 25 (section 3.1 of the Act, as amended) that every organization designate a person responsible for the protection of personal information and publish that person’s contact information on its website.
2. Identifying Purposes — Why We Collect Personal Information
CWCC collects personal information only for specific, identified purposes. We identify the purpose before or at the time of collection. The purposes for which we collect personal information are:
To respond to inquiries and schedule Discovery Meetings. When you submit a contact form or use our booking platform to schedule a Discovery Meeting, we collect your name, email address, telephone number, and province of residence. This information is used solely to respond to your inquiry and schedule the meeting. It is not used for marketing without your explicit consent.
To assess suitability and provide insurance recommendations. During the Discovery Meeting and subsequent assessment process, we collect financial information including income range, existing insurance and investment holdings, family situation, and financial objectives. This information is used to assess whether CWCC’s services and products are appropriate for your situation and to develop personalized recommendations.
To complete insurance applications. Insurance applications require detailed personal information including full legal name, date of birth, provincial health card information, residential address, beneficiary information, medical history, and financial information required by the insurer. This information is collected on behalf of the issuing insurance company and transmitted to that company for underwriting purposes. CWCC does not retain original insurance application information beyond what is necessary for its advisory and service functions.
To administer ongoing client relationships. Once a policy is in place, CWCC maintains client records necessary to provide ongoing service: policy numbers, insurer contact details, beneficiary designations, premium schedules, policy loan records, and notes from annual review meetings. This information is retained for the duration of the client relationship and for the retention period described in Section 6.
To comply with legal and regulatory obligations. As a licensed insurance distributor, CWCC is subject to record-keeping requirements under provincial insurance legislation and applicable regulatory guidance. We retain certain records to meet these obligations regardless of the status of the client relationship.
To communicate service and educational information. With your consent, CWCC may send you educational newsletters, policy review reminders, and information about CWCC services relevant to your situation. You may withdraw this consent at any time. Commercial electronic messages are sent only in compliance with Canada’s Anti-Spam Legislation (CASL, S.C. 2010, c. 23).
3. Consent
CWCC collects, uses, and discloses personal information with the knowledge and consent of the individual concerned, except where the law permits or requires otherwise. The form of consent we seek depends on the sensitivity of the information and the circumstances of collection.
For routine personal information collected through contact forms and Discovery Meeting bookings, implied consent is generally sufficient — you provide your information knowing we will use it to respond. For sensitive personal information collected during the insurance application process (health information, detailed financial information), express written consent is obtained as part of the application form.
For commercial electronic messages (newsletters, promotional communications), we obtain express consent through a clear opt-in mechanism before sending any such messages. You may withdraw consent to receive commercial electronic messages at any time by using the unsubscribe mechanism included in every message or by contacting the Privacy Officer.
You may withdraw consent to the collection, use, or disclosure of your personal information at any time, subject to legal and contractual restrictions and reasonable notice. Withdrawing consent may affect our ability to provide certain services. The Privacy Officer will explain the implications before processing your withdrawal request.
4. Limiting Collection
CWCC collects only the personal information necessary for the identified purposes. We do not collect information indiscriminately. We collect information by fair and lawful means. We do not deceive individuals about the purposes for which information is collected.
Contact forms on our website collect only name, email, telephone number, and province of residence — the minimum necessary to respond to an inquiry and confirm CWCC holds licensing in your province. No additional financial or health information is collected through the website. Detailed financial and health information is collected only during the formal client engagement process when its collection is necessary for the insurance application or suitability assessment.
5. Limiting Use, Disclosure, and Retention
CWCC uses and discloses personal information only for the purposes for which it was collected, except with the consent of the individual or as required or permitted by law.
Disclosure to Third Parties
CWCC discloses personal information to third parties only in the following circumstances:
Insurance companies. Applications and policy administration require disclosure to the issuing insurer. We disclose only the information the insurer requires for underwriting, issuing, and administering the policy. By proceeding with an insurance application, you consent to the disclosure of your personal information to the insurer named on the application.
Reinsurers. Insurance companies routinely share application information with reinsurers as part of standard insurance industry practice. This disclosure is governed by the insurer’s own privacy practices and insurance industry agreements.
CIRO-registered investment firms. For clients whose financial plans involve securities-based investment products, CWCC coordinates with a CIRO-registered firm. Information shared with this firm is limited to what is necessary for the coordination of the investment components of the plan, with your knowledge and consent.
Technology service providers. CWCC uses third-party technology platforms for website hosting, appointment scheduling, and email communications. These providers process personal information as data processors on CWCC’s behalf. Current service providers include: [BOOKING PLATFORM NAME — CONFIRM BEFORE LAUNCH], [EMAIL PLATFORM NAME — CONFIRM BEFORE LAUNCH], and website hosting provided by [HOSTING PROVIDER — CONFIRM BEFORE LAUNCH]. CWCC enters into data processing agreements with service providers to ensure they handle personal information in accordance with applicable privacy law.
Legal and regulatory disclosure. CWCC may disclose personal information without consent when required by law, court order, or regulatory authority — including the AMF, FSRA, Insurance Council of British Columbia, the Office of the Privacy Commissioner of Canada, or the Commission d’accès à l’information du Québec (CAI).
Professional advisors. With your express consent, CWCC may share relevant client information with your accountant, lawyer, or notary as part of coordinated financial planning. We do not share client information with advisors outside CWCC without your consent except as described above.
Disclosure Outside Quebec and Outside Canada
Some of CWCC’s technology service providers process data on servers located outside Quebec, potentially including outside Canada. When personal information is communicated to a third party outside Quebec, CWCC takes reasonable steps to ensure the recipient provides comparable protections to those required by Quebec Law 25. Where personal information is transferred outside Canada, CWCC notifies affected individuals in accordance with applicable law.
Retention Periods
CWCC retains personal information only as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:
Insurance client files are retained for a minimum of seven years following the end of the client relationship, in accordance with standard insurance industry practice and applicable regulatory requirements. Files related to active insurance policies are retained for the duration of the policy and for seven years following policy termination. Records required for CRA purposes are retained for a minimum of seven years. Contact and inquiry records for individuals who did not proceed to a client engagement are retained for no more than two years unless there is an ongoing relationship or legal reason for longer retention.
When personal information is no longer required for its purpose and the minimum retention period has passed, CWCC destroys, erases, or anonymizes it in a secure manner.
6. Accuracy
CWCC takes reasonable steps to ensure that personal information is as accurate, complete, and current as necessary for the purposes for which it is used. For insurance purposes, accurate information is essential — inaccurate information on an application can affect policy validity. We rely on clients to inform us of changes to their personal information that may affect their policies or coverage. Annual policy reviews provide a structured opportunity to verify and update information on file.
If you believe that CWCC holds inaccurate personal information about you, please contact the Privacy Officer to request a correction. We will correct or annotate information that is demonstrated to be inaccurate.
7. Safeguards
CWCC protects personal information with security safeguards appropriate to the sensitivity of the information. Client files containing insurance application information, health information, and financial information are among the most sensitive categories of personal information we hold and receive the highest level of protection.
Physical safeguards include secure storage of paper documents and restricted access to client files. Technical safeguards include encrypted transmission of personal information, password-protected systems, and access controls that limit employee access to personal information on a need-to-know basis. Organizational safeguards include privacy training for all individuals who handle personal information and contractual privacy obligations for service providers.
CWCC’s website uses HTTPS encryption for all data transmission. Contact forms and booking platforms transmit information over encrypted connections. CWCC does not send sensitive personal information (health information, financial account details) by unencrypted email.
8. Openness
CWCC makes information about its privacy policies and practices readily available. This Privacy Policy is published on cwcc.ca and ibcfinancial.com and is available at no charge. A copy can be obtained by contacting the Privacy Officer. This policy is reviewed annually and updated when our practices change or when legal requirements change.
9. Individual Access
Upon written request, CWCC will inform you of the existence, use, and disclosure of your personal information and will give you access to that information within 30 days (or within 30 days for federal PIPEDA purposes, with possible extension; within 30 days for Law 25 purposes with possible extension for complex requests). CWCC will also explain how the information has been used and, where reasonably possible, provide a list of any third parties to which it has been disclosed.
To make an access request, contact the Privacy Officer in writing at the address above. You may be asked to provide proof of identity before we process your request. Access may be denied in limited circumstances permitted by law — for example, where providing access would reveal personal information about another individual or where it would be subject to legal privilege. If we deny an access request, we will explain why and inform you of available recourse.
If you identify information that is inaccurate, incomplete, or outdated, please request a correction in writing. We will correct the information or annotate our records to reflect the dispute.
10. Challenging Compliance
You may challenge CWCC’s compliance with this Privacy Policy or with PIPEDA or Law 25 by contacting the Privacy Officer in writing. We will investigate all complaints and respond within a reasonable time. If a complaint is found to be justified, we will take appropriate corrective action.
If you are not satisfied with CWCC’s response to your complaint, you may file a complaint with the appropriate oversight authority:
Federal (PIPEDA): Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, QC K1A 1H3 — priv.gc.ca
Quebec (Law 25): Commission d’accès à l’information du Québec (CAI), 525, boul. René-Lévesque Est, Bureau 2.36, Québec (Québec) G1R 5Y4 — cai.gouv.qc.ca
11. Additional Rights Under Quebec Law 25
Individuals in Quebec have additional rights under Law 25 beyond those provided by PIPEDA. If you are a Quebec resident, the following rights apply to your personal information held by CWCC:
Right to Data Portability
You have the right to receive, in a structured, commonly used, and technological format, the computerized personal information you have provided to CWCC and to have it communicated to any person or body authorized by law to collect it, if technically feasible. Contact the Privacy Officer to make a portability request.
Right to De-indexation and Cessation of Dissemination
If your personal information has been communicated to the public without a lawful basis, or if the legitimate purposes for which it was collected no longer justify its dissemination, you have the right to request that the dissemination cease and that hyperlinks providing access to the information be de-indexed. CWCC does not publish personal client information publicly. This right is most relevant to any directory listings or published references; contact the Privacy Officer if you believe such a situation applies to you.
Confidentiality Incident Notification
In the event of a confidentiality incident (a data breach) involving your personal information that presents a risk of serious harm to you, CWCC will notify you and the Commission d’accès à l’information du Québec as required by Law 25, with the information specified in the Act.
Privacy by Default
CWCC applies a privacy-by-default principle: when a technology or process involves personal information, we configure it to provide the highest level of privacy protection by default, without requiring any action from the individual.
13. Children
CWCC’s services are designed for adults. We do not knowingly collect personal information from individuals under the age of 14 without verifiable parental consent. Insurance applications involving children (such as child riders on a parent’s policy or RESP beneficiary designations) involve the parent or guardian as the primary applicant, with the child’s information collected only as necessary for the specific product purpose. If you believe CWCC has collected personal information from a child under 14 without appropriate consent, please contact the Privacy Officer immediately.
14. Changes to This Policy
CWCC may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. Material changes will be communicated by posting the updated policy on our website with a revised effective date. If we make changes that affect how we use personal information you have already provided, we will provide notice and, where required by law, seek fresh consent.
This policy was last reviewed in May 2026. The current version is always available at cwcc.ca/privacy/.