Privacy Policy

Willowbroom ("we," "us," or "our") operates the website dedicated to Canadian dividend investing. We are committed to protecting your privacy and ensuring the confidentiality of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your data when you visit our site, specifically in compliance with the laws of Quebec and Canada.

1. Legal Framework and Jurisdiction

As we are based in Montreal, Quebec, our data processing activities are governed by:

• Quebec's Law 25 (formerly Bill 64), An Act to modernize legislative provisions as regards the protection of personal information;
• The Personal Information Protection and Electronic Documents Act (PIPEDA) at the Canadian federal level;
• To the extent applicable to international visitors, the General Data Protection Regulation (GDPR) for EU residents.

2. Data Controller

The entity responsible for your personal information is Willowbroom. To contact our Privacy Officer regarding your data rights, please use the following details:

3. Information We Collect

We may collect information that identifies you as an individual ("Personal Information"), including but not limited to:

• Identity Data: Name, username, or similar identifier.
• Contact Data: Email address and telephone numbers provided via contact forms or newsletter subscriptions.
• Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system, and platform.
• Usage Data: Information about how you use our website, products, and services related to Canadian dividend stock analysis.
• Interaction Data: Records of correspondence if you contact us regarding your investment portfolio structure inquiries.

4. Purpose and Legal Basis for Processing

Under Law 25 and GDPR, we must have a legal basis to process your data. Willowbroom processes data for the following purposes:

• Consent: When you voluntarily provide information (e.g., signing up for a guide on S&P/TSX Dividend Aristocrats).
• Contractual Necessity: To provide the services or information you have requested.
• Legitimate Interests: To improve our website content, ensure network security, and analyze the geographical distribution of our readers in Montreal and across Canada.
• Legal Compliance: To comply with Canadian tax or regulatory reporting requirements if applicable.

5. Cookies and Tracking Technologies

Our website uses cookies to enhance your experience. These are small files stored on your device. We use functional cookies (necessary for the site to work) and analytical cookies (to understand how users interact with our financial content). You can manage your preferences through your browser settings or by clicking Cookie Settings.

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Typically, contact form data is retained for 24 months unless a longer period is required by Canadian law.

7. Disclosure to Third Parties

Willowbroom does not sell your personal information. We may share your data with:

• Service providers (hosting, analytics, email marketing) who act on our behalf.
• Professional advisors (lawyers, auditors) in the course of business operations.
• Law enforcement or regulatory bodies where required by Quebec or Canadian federal law.

8. International Data Transfers

While our primary servers are located in Canada, some of our service providers may be located in other jurisdictions (such as the USA). When we transfer data across borders, we ensure that adequate protection is in place, consistent with Quebec's Law 25 requirements regarding data transfer outside of the province.

9. Your Rights

Depending on your location, you have significant rights regarding your data:

• Right to Access: Request a copy of the info we hold about you.
• Right to Rectification: Correction of inaccurate data.
• Right to Deletion ("Right to be Forgotten"): Request that we erase your personal data.
• Right to Withdraw Consent: If processing is based on consent, you may withdraw it at any time.
• Right to Portability: Request the transfer of your data to another service provider.

To exercise these rights, please contact our Privacy Officer at the email provided above.

10. Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. We limit access to your personal data to those employees and partners who have a business "need to know."

11. External Links

Our site contains links to other websites (e.g., TMX Group, Bank of Canada). We are not responsible for the privacy practices of these external sites. We encourage you to read their policies.