Privacy Policy
Last Updated: June 26, 2017

This Privacy Policy discloses how Keyspire Group Inc. (“we”, “us”, or “our”) manages your personal information. When you interact with one of Keyspire Group Inc.’s websites, including www.keyspire.com and www.thewealthtour.com (the “Sites”), sign up for or attend our events, contact us, purchase products or services, or otherwise interact with us, you consent to our collection, use and disclosure of information about you as described in this Privacy Policy.

By accessing or using the Sites, or continuing to interact with us, you consent to the terms of this Privacy Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy, do not access or use the Sites, continue to interact with us, or provide us with any personal information.

Information Collection and Use

We may collect, use, and disclose your information in the following ways:

(1) We collect your name and contact information, and any investing history and strategies, financial goals, and relevant assets and financial information that you may provide to us when you establish an account or Membership, enroll or opt in to one of our services, request information, use any of the interactive portions of the Sites, sign up to receive marketing materials, online, in person at our events, through our customer service lines, or otherwise. We use this information to manage your account or Membership, provide the information or services you requested, and to tailor offers to you, as you may request from time to time or as otherwise permitted by law.

(2) We collect other personal information you voluntarily provide to us, such as demographic information, information about your hobbies and interests, and other similar information. This information may be requested when you participate in an event, or other special promotion, or sign up for products or services that we may make available from time to time. We use this information to learn more about how we can serve you and our potential Members better, and to personalize your experience on the Sites.

(3) We may receive and store certain types of information automatically when you access the Sites. For example, each time you visit the Sites, we automatically collect your IP address. We may collect and may store information about your use of the Sites, such as your search activity, the pages you view, and the date and time of your visit. We may also collect and may store information that your computer or mobile device provides to us in connection with your use of the Sites, such as your browser type, screen resolution, type of computer or mobile device, browser language, mobile carrier, unique device identifier, location, and requested and referring URLs. We may gather aggregated tracking information derived mainly by tallying page views throughout our Sites. This information allows us to better tailor our content to our customers’ needs and to better understand the demographics of our audience. See also our discussion about the use of cookies and tracking below.

(4) When you interact with us by telephone, we may record or monitor the conversation. We may use the recording of our conversations for internal recordkeeping, training and quality assurance purposes. We may also keep a record of your interactions with us to fulfil requests, respond to future inquiries, and to improve our service.

(5) To help us better understand and respond to your needs and interests, we may receive personal information about you from other sources such as Google Analytics and DoubleClick (by Google). We will ask any provider of such information to represent and warrant that the information has been gathered and maintained in accordance with all applicable Provincial, State and Federal laws. Any such information will be maintained by us in accordance with the standards set forth in this Privacy Policy along with other personal information you’ve provided.

(6) Subject to the provisions of any Terms of Use applicable to the Sites, you may post information on the Sites intended for public consumption, including your photos and comments. We may collect and use such information in accordance with this Privacy

Policy, including sharing the information you post publicly with other Members of the Sites. Note that we cannot be responsible for the access and use by third parties of information that you choose to make public and, even if you later request that we remove it from the Sites, it may not be possible for us to guarantee that it can no longer be accessed. Consider carefully what content you wish to disclose publicly, and limit the personal information associated with your posts.

(7) We may offer you the opportunity to engage with us through third-party social networking websites, plug-ins and applications. Subject to the terms and conditions and privacy policies of these platforms, we may ask and you may allow us to access information associated with your social media account(s). We may use this information to confirm your identity, and to personalize your experience on our Sites or in other communications.

(8) You may request or consent to receive electronic communications from us, such as emails or text messages, in which case we will use your contact information to fulfill your requested communications preferences. You may opt out of such communications at any time; please see our “Opt-Out Policy” below.

Note: Information that we collect may be stored on servers located in the United States. Your personal information may therefore be subject to the laws and regulatory agencies of the United States and/or other jurisdictions.

Cookies and Tracking Technologies

We and third party advertising companies use cookies, web beacons, local shared objects, and similar technology in connection with your use of the Site and other websites to track user traffic patterns. We use tracking information to tailor content and deliver advertising to you based on preferences we and third party advertising companies determine from products or web pages you view, or purchases you make, online. This helps us continue to build a better online experience for you, to display relevant advertising, and evaluate the success of our advertising.

Cookies are small data files that may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our Sites. The cookie itself does not contain personal information although it will enable us to relate your use of our Sites to information that you have specifically and knowingly provided. A cookie can’t read data off your hard disk or read cookie files created by other Sites. The “Help” portion of most Internet browsers will tell you how to prevent your browser from accepting new cookies, how to disable cookies altogether, or how to have the browser notify you when you receive a new cookie. For more information about opting out of tracking technologies, see our “Opt-Out Policy” below.

Usage and Sharing of Your Information.

We may share your personal information with third party agents or service providers who perform a number of functions for us. We remain accountable for the protection of all personal information within our possession or control, including any personal information that has been transferred to a third party service provider. We require a comparable level of protection for all personal information transferred or disclosed to our service providers as set out in this Privacy Policy.

Except as set out in this Privacy Policy, we do not sell, rent, trade or otherwise disclose your personal information to third parties. We may, however, disclose your information in the following circumstances:

(1) Agents, Contractors, and Service Providers: We may share your information with our agents, contractors or other service providers as needed to carry out the performance and functionality of the Site, to provide customer support, or otherwise to help us with our business operations. If you are a Keyspire Member, we may also use and disclose any contact information you have provided to Keyspire to connect you with our Success Coaches and/or third party consultants/Service Providers to fulfill your Membership services or other requests.

(2) Analytics and Usage: We may share user information, in the aggregate, with third parties such as advertisers, professionals, and businesses. For example, we may disclose to an advertiser our Member demographics to assist with future Keyspire promotional campaigns.

(3) Business Transfers: If we are acquired by or merged with another entity, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected about you to the other company. Our successors and assigns may collect and use your information for substantially similar purposes as described in this Privacy Policy.

(4) Other Users: Information that you post publicly on the Sites (e.g., photos, comments, your profile) will be made publicly available to other users of the Sites.

(5) Investigations: We may disclose information from or about you, as permitted or required by applicable law, if we have a good faith belief that such disclosure is (a) reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) helpful to prevent, investigate, or identify possible wrongdoing in connection with the Sites or our business; or (c) helpful to protect our rights, reputation, property, or that of our users, subsidiaries, or the public.

(6) In Accordance with Law: We may disclose information from or about you, as permitted or required by applicable law, or otherwise with your consent.

Recordings at Events

Live Keyspire events are periodically recorded by video and/or audio. You voluntarily and without compensation authorize Keyspire and its affiliates to use your image, voice or video recording for its business purposes. You also declare any information you provide on camera is accurate and not misleading, does not misrepresent the truth, and is based on your actual experiences. You further acknowledge you did not and will not receive any financial compensation for those statements.

Opt-Out Policy

(1) Electronic Messages for Event Registrants who have registered for our WEALTH TOUR on thewealthtour.com, or enrolled in our 3-Day Workshop: You may opt-out of receiving any marketing campaign. However, you agree that we may still contact you for the purposes of providing updated event information, confirming your attendance for an event, and following up on your customer service requests.

(2) Electronic Messages for Keyspire Members: You may opt-out of a marketing campaign by following the link provided in every notification. After you become a Keyspire Member, please be aware that, even if you have opted out of receiving marketing communications from us, we may still contact you for purposes such as providing updates on customer service requests, managing your Membership, or as otherwise permitted or required by law. Even if you choose to “opt-out” of our marketing programs, we may maintain and use your demographics information in a de-identified form (i.e., not in conjunction with your contact information). We may also aggregate all our users’ demographic information in order to evaluate our customers’ preferences and thereby improve our customer service. Note that certain Membership benefits are provided by means of electronic message. If a Member chooses to opt out of receiving Membership emails, that Member will not be reimbursed for any resulting reduction in the services provided.

(3) Tracking: The Sites may use social media and web analysis services such as Facebook, Google Analytics and DoubleClick (by Google) which utilize data collected to provide targeted advertising to you. Facebook, Google Analytics and DoubleClick may use the data collected to contextualize and personalize the ads of their own advertising networks.

Facebook’s privacy policy is available at: https://www.facebook.com/legal/FB_Work_Privacy. Google’s privacy policy is available at: https://www.google.com/policies/privacy. DoubleClick (by Google) has its Privacy & Terms available at: https://www.google.com/intl/en/policies/. The information gathered by these social media and web analysis services may be stored and processed in the United States. If you do not wish to receive this type of advertising, you can opt out using the opt-out page at http://www.networkadvertising.org/choices.

If you opt out of receiving interest-based ads, you will continue to receive advertising, but it will not be based on online behavioral information about you.

Links to Other Websites

There may be websites that link to and/or from our Site. We, of course, are not responsible or liable for the content or activities of any linked websites, or for the privacy practices of third parties. We recommend consulting their privacy policies to determine how they collect and use information.

Audience

The Sites are intended for an audience of 18 years of age and over, and is not directed to children. We do not knowingly collect personal information from persons under the age of 18. If you become aware that a child has provided us with personal information, please contact us and we will use all reasonable efforts to remove such information and terminate the child’s account.

Security

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We take reasonable precautions to protect your personal information from access, loss, misuse or alteration. We keep your personal information only as long as it is required and we destroy, delete or convert such information into an anonymous form when it is no longer required. No method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure – so we cannot guarantee its absolute security.

Modification and Updates to this Privacy Policy

We may revise this Privacy Policy from time to time. Our latest Privacy Policy (along with the date on which it was last revised) will be posted on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. We will not notify you individually each time the Privacy Policy changes. Any changes that are made to this Privacy Policy will apply to both any personal information that we hold prior to the effective date of the amended Privacy Policy and any personal information that we collect on or after such effective date. We welcome and encourage your review of our Privacy Policy each time you visit the Site.

Questions, Inquiries

We endeavour to ensure that any personally identifiable information provided to us is kept accurate, current and complete for the purposes for which the information is used. If you have questions or concerns about the data we maintain about you, or this Privacy Policy, or if you want us to edit or delete the information we maintain about you, please contact us.

Keyspire Group Inc. has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. Any questions can be addressed directly to the Privacy Officer at: Keyspire, Privacy Officer 485 Pinebush Road, Suite 301 Cambridge, Ontario N1T 0A6 or e-mail – privacyofficer@keyspire.com