Collection of Personal Information
We only collect the information about you that we need, and retain it in a client record. You provide most of this information to one of our licensed sales representatives when you complete an application form to become a subscriber to one of our CST Registered Education Savings Plans ("RESP"). The personal information in your client record includes:
- Your name, address, email address, occupation and birth date;
- Your social insurance number for income tax reporting and other government purposes;
- Your financial information including information related to your financial institution(s) and bank account information, and your estimated annual family disposable income and liquid net worth;
- Information about beneficiaries such as the name, address, birth date and social insurance number of the child(ren) designated to receive benefits under your RESP;
- Information we may need in the course of the administration of your RESP such as tax records, school transcripts and other documentation necessary to support claims or requests for various types of payments and benefits.
We may collect personal information about individuals you or other sources refer to us, such as their name, contact information and information relating to the number and age range of their children. We collect this information for the purpose of marketing products and services that you or the other sources believe may be of interest to them. We will not use this information for any other purpose without their consent. We will contact such individuals using the telephone number, residential address, or e-mail or other electronic address you or the other source have given us, and will provide your name or identify the other source in any such communication. If the individual referred does not want us to keep their information, we will remove it at their request (see “Withdrawing Your Consent” below).
We may collect personal information, such as your name, contact information and information relating to the number and ages of your children, on a CST contest ballot or promotional entry form. We collect this information for the purpose of administering a contest or promotion. If you voluntarily provided your consent to be contacted to learn more about RESPs, the government grants and/or the Canadian Scholarship Trust Plan, a Sales Representative may contact you. We do not require such consent as a condition of your participation in the contest or promotional activity.
We may collect information in connection with our facilitation of fundraising projects, such as your Paypal user name, or other information in connection with a payment platform. Third party payment platforms used in connection with fundraising projects may be subject to additional terms and conditions, which we recommend you read carefully. We have no control over such platforms and therefore have no responsibility or liability for the manner in which the organizations that operate and use such platforms may collect, use or disclose and otherwise treat your personal information.
We may also automatically collect general anonymous information related to your use of our website, such as the date and time you visit the website and the pages you visit on the website. In addition, we collect "cookie" information from your browser to identify your computer and provide us with a record of your visits to our website. This statistical information helps us to understand how our website is used (e.g., which pages or sections are most popular and when are the peak activity times), which assists us in planning for future improvements to the site to better meet our visitors' needs.
Use of Personal Information
We collect and use your personal information for one or more of the following purposes:
- To identify who you are;
- To understand your needs;
- To establish and administer your RESP;
- To provide you with financial statements, tax receipts and other information about your RESP;
- To improve our service offerings;
- To improve our website;
- To meet our legal and regulatory requirements;
- To manage and assess our risks;
- To protect us from error and to prevent or detect fraud or criminal activity;
- To administer a contest or promotional activity; and
- To administer fundraising projects we facilitate.
We do not directly provide all the services related to your relationship with us. We may use third party service providers to process or handle personal information on our behalf and to assist us with various services such as the preparation and mailing of client statements, facilitating fundraising projects, data processing, document storage and contest or promotional activity administration. Some of our service providers are located outside of Canada, including in the United States (US). We require our service providers to maintain the confidentiality and security of personal information and do not authorize them to use or disclose personal information for any purpose other than providing the services on our behalf or as otherwise required by applicable law.
We, or our trusted retail partners, may ask you for your contact information, such as your telephone number, residential address, e-mail or other electronic address for the purpose of marketing products and services that we believe may be of interest to you. We keep and use this information so that we may contact you directly through these channels for the purpose of marketing including telemarketing. Your consent to this is not a condition of doing business with us and you may withdraw it at any time (see “Withdrawing Your Consent” below).
From time to time, we may also send you information about products and services offered by third parties that we believe may be of interest to you, but we do not provide your name and contact information to any third parties for marketing purposes.
Disclosure of Personal Information
We disclose personal information in your client record to Employment and Social Development Canada (ESDC), Canada Revenue Agency, Revenu Quebec and any other government body necessary for the purposes of administering your RESP(s), and to otherwise comply with legal and regulatory requirements. We only disclose the information that is reasonably necessary for you to obtain the benefits of your RESP.
Certain personal information in a client record may be shared with the custodial parent of a beneficiary of an RESP.
CST and its Canadian, US and other third-party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order (including lawful access by US or other courts or governmental authorities), to an investigative body or as required by applicable Canadian, US or other law. We may also disclose personal information where necessary for the enforcement or protection of our legal rights, to investigate or prevent loss or harm to persons or property, or as otherwise permitted by law.
We may also disclose your personal information in connection with a change in corporate control such as merger, acquisition, sale, reorganization, transfer or stock sale.
Except as set out above, we will not otherwise sell, transfer or disclose any of your personal information to any third party without your knowledge and consent unless required or permitted by law.
Withdrawing Your Consent
Subject to legal, regulatory and contractual requirements, you may refuse to consent to our collection, use or disclosure of your personal or business information, or you may withdraw your consent to our further collection, use or disclosure of your information at any time in the future by giving us reasonable notice. Depending on the circumstances, however, withdrawal of your consent may impact our ability to provide you or continue to provide you with some products, services or information that may be of value to you and may result in you or your beneficiary not being able to receive benefits that you would otherwise be entitled to under your RESP. We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately.
Where appropriate, we will ask for your consent to send commercial electronic messages, such as e-mail. You may withdraw your consent to receive emails about other products and services offered by CST or its marketing partners excluding emails directly related to the administration of your account at any time by clicking the “Unsubscribe” link provided in the email. Alternatively you may contact us or your sales representative using the contact information provided in the email to be removed from our mailing list.
Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry.
Third Party Links
Security of Personal Information
We maintain reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. We will maintain the strict confidentiality of all personal information collected, and will only disclose such information to employees and authorized contractors of CST who require such information for the purposes set out above. We will keep your personal information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law. Even after you cease to be a CST client, we keep some information about you on file in order to meet certain legal requirements.
How to Contact Us about Privacy Concerns
Last updated: March 2016