December 2024

This Privacy Policy of Guaranteed Funeral Deposits of Canada (Fraternal) (“GFD”, “we”, “us” or “our”) describes GFD’s practices with respect to the collection, use, disclosure and protection of personal information in the course of operating our business in Canada. This policy does not apply to personal information about directors, officers, employees or any volunteer or individual assigned to GFD on secondment or contract from a third party, or to information that is not personal information as defined by applicable laws.

“Member Bereavement Establishments”, means licensed funeral homes, transfer services, cemeteries and crematoriums who either have funds invested through GFD or who are enrolled in an insurance program offered by GFD and/or its subsidiaries.
“Clients” of Member Bereavement Establishments means individuals who have monies either held in trust by a bereavement establishment or underwritten by an insurance company through GFD and/or its subsidiaries, or by an agent acting on behalf of GFD and/or its subsidiaries in respect to pre-paid services. For purposes of this policy a Client may include the applicant or the owner of the services.
“Personal Information” means information about an identifiable individual.

The nature of the personal information we collect will vary depending on your relationship with GFD.
If you are a representative of a Member Bereavement Establishment, we may collect your business contact information for the purposes of managing our relationship with the Member Bereavement Establishment. We may collect this information directly from you, or from another representative.
If you are a Client, we may collect your:

• Name, address, email address, telephone number, birth date and gender.

• Social insurance number or other government issued identification information (e.g., driver’s license, passport, etc.).

• Payment information, including credit card and bank account information and other financial information.

• For certain pay plans and insured offerings, personal health information such as information about current or past illnesses, conditions, or
medical procedures, and information about general health status.

We collect personal information relating to Clients from the relevant Member Bereavement Establishment. We take steps to ensure that the Member
Bereavement Establishment has the authority to share Client personal information with us for the purposes identified in this Privacy Policy.
Please note that GFD is not made privy to, nor does it collect copies of any contract between the Client and the Member Bereavement Establishment. Any and all inquiries in respect of the contract must be directed to the Member Bereavement Establishment as GFD does not deal with Clients except in the context of a data subject request as described herein.
In addition, when a Member Bereavement Establishment or a Client views, applies for or enrolls in a service via a digital channel (such as online), GFD may collect information about the Client and or Member Bereavement Establishment’s computer or device, operating system, internet connection or telephone account, settings, IP address and device locational data, and transaction data. GFD uses this information to determine which settings are appropriate for the user’s computer system, to provide or enhance digital functionality and for security purposes, internal analysis and reporting. The Member Bereavement Establishment or Client may control the use of these automatic data collection tools through browser or device settings, however in some cases this may prevent utilization of the digital channel to apply for or use a service or to communicate with GFD, or may reduce the functionality of that channel.

GFD uses personal information about representatives of Member Bereavement Establishments and the Clients that they serve for the purpose of collecting, holding, investing, administering and disbursing funds held in trust and for the purpose of collecting and disbursing insurance funds by the Member Bereavement

Establishment on behalf of a Client. These purposes include:

• To confirm identity of the Client or other contact person.

• To determine the amount of investment.

• To establish, manage and continue the relationship and service.

• To offer pay plans and insured offerings.

• To satisfy income tax and other reporting obligations.

• To verify and report credit information to credit bureaus and credit reporting agencies.

• To assist in the collection of a debt that may be owed to GFD.

• To respond to a complaint or inquiry by a Member Bereavement Establishment on its own behalf or on behalf of a Client.

• To satisfy and respond to a Court Order, search warrant or other legal demand or request, or to respond to the rules of production of a Court.

• To satisfy legal and regulatory requirements placed upon GFD.

• To prevent or detect fraud or criminal activity and to protect against any loss arising from such activity.

• To fulfil the contract of service with the Member Bereavement Establishment

GFD may share Client personal information with the applicable Member Bereavement Establishment or insurer (for insured offerings) to the extent necessary for the purposes described in the “Purposes For Which Personal Information Is Used” section above.
GFD may share Client personal information with the eligible depositaries that hold the trust funds for the purposes of meeting the requirements of Canada Deposit Insurance Corporation (CDIC) and Deposit Insurance Reserve Fund (DIRF) coverage.
GFD may use third party service providers to process or handle personal information on our behalf and to assist with the provision of various services, including investment, marketing, postal or other services. When personal information is provided to our service providers, GFD requires them to protect the information in a manner that is consistent with GFD privacy practices.
Service providers may be located in any province in Canada or outside of Canada, including in the United States. While the information is in another jurisdiction it may be accessed by the courts, law enforcement and national security authorities pursuant to the laws of that jurisdiction. To obtain information about our policies and practices with respect to any service providers outside Canada contact our Privacy Officer at the address below.

GFD may also disclose personal information to:

• Satisfy income tax and other reporting obligations or responsibilities. This may include reporting to Canada Revenue Agency or responding to requests for information from government or regulatory authorities.

• Verify and report credit information to credit bureaus and credit reporting agencies.
• Assist in the collection of a debt that may be owed to GFD.

• Satisfy and respond to a Court Order, search warrant or other legal demand or request, or to respond to the rules of production of a Court.

• Satisfy legal and regulatory requirements placed upon GFD.

• Prevent or detect fraud or criminal activity and to protect against any loss arising from such activity.

We collect, use and disclose personal information with consent, except as otherwise permitted or required by law. Consent may be express or implied, depending on the circumstances. When we collect Client personal information from a Member Bereavement Establishment, we take steps to ensure that the Member Bereavement Establishment has the authority to provide that personal information to us for the purposes described in this Privacy Policy.
Subject to legal, regulatory and contractual requirements, Clients and representatives of Member Bereavement Establishments may refuse to consent to GFD’s collection, use or disclosure of their personal information or may withdraw consent to further collection, use or disclosure of personal information at any time in the future upon the provision of reasonable notice. Depending on the circumstances, refusal to provide consent, or the withdrawal of a previously given consent, may prevent GFD from providing, or continuing some or all of its services.
There may be legal, regulatory and contractual requirements that may prohibit the withdrawal of consent (for example, where the collection, use or disclosure of information is required by law).

GFD maintains personal information in accordance with its data retention policy. Personal information is retained for so long as is necessary to fulfill the identified purpose for which it was collected, used and disclosed and for reasonable business record retention, legal and regulatory reporting requirements.

GFD undertakes reasonable and appropriate methods, including administrative, electronic and physical security measures, to protect and safeguard personal information from unauthorized access, use, and disclosure, however, GFD cannot provide complete guarantees to the protection of personal information.
We have policies and procedures in place designed to ensure our compliance with this Privacy Policy and applicable laws, including policies and procedures regarding the retention and destruction of personal information, the handling of complaints, and the appropriate management of personal information by our personnel. We restrict access to personal information to those of our personnel with a need to know for the purposes described in this Privacy Policy, which may include personnel in our marketing, customer service, compliance, legal, audit, finance and IT departments.

A Client or a Member Bereavement Establishment on behalf of a Client, may file an access request with GFD in respect of personal information about the Client which has been collected, used and disclosed by GFD. Where the Member Bereavement Establishment seeks access on behalf of the Client an executed consent to disclose information is required.

Access requests should be specific about the type of information required so as to ensure that the access request may be reasonably fulfilled. GFD will respond within a reasonable time and will advise what personal information GFD has, what it is being used for, and to whom it has been disclosed. If GFD is unable to provide access to some or all of the information GFD will advise as to why the access request cannot be fulfilled. Any and all third party information will be redacted from the information requested.

Where permitted by law, GFD may charge a reasonable fee in respect to processing the access request. However, GFD will not issue such fee without first advising of the cost of providing the requested information and giving the requesting party the option of withdrawing the request.

A Client or a Member Bereavement Establishment on behalf of a Client may also request that any inaccurate, incomplete or out of date personal information be corrected, updated or otherwise rectified. You may also have the right to make a complaint regarding our personal information handling practices, or request that a copy of the personal information you have provided to us be transferred to you or another person in a structured, commonly used, technological format.

These data subject requests may be submitted to:
Privacy Officer
Guaranteed Funeral Deposits of Canada
PO Box 100 Lakeshore W PO
Oakville, ON L6K 0A3

This Privacy Policy is effective as of the Effective Date below. GFD reserves the right to change this Privacy Policy at any time. We will post any updated versions of our Privacy Policy on our website. It is your responsibility to review our Privacy Policy from time to time to ensure that you are aware of any changes made. By continuing to use our services following the posting of any updates, you consent to the updated Privacy Policy.