Privacy Policy

The Canadian Estate Club, operated by Heritage Trust Company Inc.

Effective August 10, 2026

Our Commitment to Privacy

The Canadian Estate Club (estateclub.ca) is operated by Heritage Trust Company Inc. ("Heritage Trust", "we", "us"). Heritage Trust is entrusted with some of the most sensitive personal, family and financial information its clients possess, and protecting that information is fundamental to our role as a fiduciary. This Privacy Policy applies to this website and to Heritage Trust generally. It explains how we collect, use, disclose, safeguard, retain and destroy personal information, and describes your rights to access and correct your personal information and to make a privacy complaint.

Heritage Trust is a British Columbia trust company regulated by the BC Financial Services Authority (BCFSA). Our privacy practices are designed to comply with the British Columbia Personal Information Protection Act (PIPA) and, where applicable, other Canadian privacy legislation. We have designated a Chief Privacy Officer, who is accountable for our compliance with privacy law. The Chief Privacy Officer’s contact information appears at the end of this page.

What Personal Information We Collect

Personal information is information about an identifiable individual. Depending on the services we provide to you, this may include your full legal name, date of birth, Social Insurance Number, contact details, financial and account information, health information relevant to planning or administration, and information contained in wills, trusts and estate records. It does not include business contact information used to communicate with a person in their business capacity.

If you contact us through this website, by email or by telephone, we also collect the contact information and other details you choose to provide so that we can respond to your inquiry.

Information We Collect Through This Website

When you subscribe to our mailing list, download a resource, register for an account, or purchase a membership, program or other offering through this website, we collect the information you provide, such as your name, email address and, where applicable, payment details. We use this information to deliver the resources and services you request, to administer your account, and to send you communications you have consented to receive. You may unsubscribe from marketing emails at any time using the link included in every message.

This website and our member platform are operated on third-party platforms, and payments are processed by third-party payment processors. These providers may store or access information outside Canada. Like most websites, we may also collect limited technical information (such as browser type and pages visited) through cookies and similar technologies in order to operate and improve the site.

Why We Collect It

We collect personal information solely for the purposes of fulfilling our fiduciary duties as trustee, executor, attorney or agent; meeting anti-money laundering, know-your-client and sanctions screening obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act; facilitating tax filings with the Canada Revenue Agency; meeting BCFSA regulatory requirements; and administering the client relationship. We identify these purposes at or before the time of collection, on our Client Intake Form and in our Privacy Notice.

Consent

By signing our Client Intake Form, which incorporates our Privacy Notice, clients provide express consent to the collection, use and disclosure of their personal information for the identified purposes. We may rely on implied or deemed consent where permitted by PIPA, and we collect, use or disclose personal information without consent only where PIPA or another law authorizes or requires it (for example, reporting to FINTRAC, court orders, or information necessary to administer an estate where the individual is deceased or incapable).

You may withdraw your consent on reasonable written notice, subject to legal, regulatory and contractual restrictions. We will explain the consequences of withdrawal, which may include our inability to continue acting in a fiduciary role.

Limits on Collection, Use, Disclosure and Retention

We collect only the personal information that is reasonable and necessary for the identified purposes, and we collect it by fair and lawful means. We use and disclose personal information only for the purposes for which it was collected, unless you consent to another use or the use or disclosure is authorized or required by law. We disclose personal information to service providers only when necessary for the administration of your file, and to regulators and authorities (such as BCFSA, FINTRAC or the Canada Revenue Agency) as required by law.

We retain personal information only as long as necessary for the identified purposes and applicable legal requirements. Information that is no longer required is destroyed securely or anonymized.

How We Protect Your Information

We protect personal information with administrative, physical and technical safeguards appropriate to its sensitivity. These safeguards include confidentiality obligations and annual privacy training for all personnel; access to personal information restricted to those who need it to perform their duties; secure storage of sensitive physical documents, including original wills, in our controlled office vault; multi-factor authentication on our systems; encryption of data in transit and, where supported, at rest; and monitoring of our systems and security events. Our Chief Privacy Officer conducts a privacy review before any new system, tool or service provider that processes personal information is adopted.

Artificial Intelligence Tools

We use secure, enterprise-grade technology to administer client files. This may include Company-approved artificial intelligence tools operating within our controlled and monitored environment. We do not permit the use of public or consumer AI tools for any client-related work.

Our approved AI tools operate under contractual confidentiality protections. Your information is never used to train public or third-party AI models. Access follows least-privilege principles, all activity is logged and auditable, and a qualified staff member reviews any AI-assisted output before it is relied upon or sent to any client, counterparty, court or regulator. Our Chief Privacy Officer completes a privacy review before any new AI tool, or any materially expanded use of an existing tool, is adopted.

Service Providers and Processing Outside Canada

Before personal information is shared with a service provider, we conduct due diligence and require contractual commitments to privacy and security protections comparable to our own. Some of our service providers (for example, cloud service providers) may store or access information outside Canada, in which case it may be subject to the laws of those jurisdictions.

Accuracy, Access and Correction

We make reasonable efforts to ensure the personal information we hold is accurate and complete for the purposes for which it is used.

You have a right to request access to your personal information under our control, subject to the exceptions in PIPA (including solicitor-client privilege, information that would reveal personal information about another individual, and information generated in a formal dispute resolution process). Requests must be made in writing to the Chief Privacy Officer. We will respond within 30 days of receiving a request, or within any extended period permitted by PIPA, in which case we will give you written notice of the extension and the reasons for it. If access is refused in whole or in part, we will provide written reasons, identify the PIPA provision relied on, and advise you of your right to ask the Office of the Information and Privacy Commissioner for British Columbia (OIPC) to review the decision. Any fee will be a minimal amount permitted by PIPA and will be disclosed to you by written estimate before it is incurred.

You may also request correction of your personal information. Where a correction is warranted, we will correct the record and, where reasonable, notify service providers and other recipients. Where a correction is refused, we will annotate the record with the requested correction.

Privacy Breaches

We maintain a privacy breach response process to contain, assess, remediate and record any breach of personal information. Where required by law, or where notification could reduce the risk of harm, we will notify affected individuals and the OIPC.

Questions and Complaints

If you have a question or concern about our privacy practices, or wish to make a privacy complaint, please contact our Chief Privacy Officer in writing. We will acknowledge, investigate and respond to every complaint, and we will notify you of the outcome in writing, including any corrective action taken. No one will be penalized for making a good faith privacy complaint.

If you are not satisfied with our response, you may complain to the Office of the Information and Privacy Commissioner for British Columbia.

Contact Us

Chief Privacy Officer

Heritage Trust Company Inc.

Suite 220, 545 Clyde Avenue

West Vancouver, BC V7T 1C5

Tel: 778-742-5005

Email: nicole@heritagetrustcompany.ca

Office of the Information and Privacy Commissioner for British Columbia

PO Box 9038, Stn Prov Govt

Victoria, BC V8W 9A4

Tel: 250-387-5629

Website: www.oipc.bc.ca

Updates to This Policy

We review this Privacy Policy at least annually and update it as our practices or the law change. The effective date at the top of this page indicates when it was last revised.