PRIVACY POLICY

Last updated: July 2026

This Privacy Policy explains how ShaCole® Group (“we,” “us,” or “our”) collects, uses, stores, and protects your personal information when you access shaunsutherland.ca, the Wealth Within Reach® framework, or any related tools, forms, assessments, booking systems, downloads, or communication channels.

We are committed to transparency, confidentiality, and responsible handling of personal information in accordance with:

• PIPEDA (Personal Information Protection and Electronic Documents Act)

• CASL (Canadian Anti-Spam Legislation)

1. Information We Collect

We collect only the information necessary to support communication, scheduling, and the delivery of clarity-based educational resources.

1.1 Information You Provide

You may voluntarily provide:

• Name

• Email address

• Phone number (optional)

• Clarity Check responses

• Form submissions

• Notes voluntarily shared during Quick Connect conversations or Clarity Sessions

• Communication preferences

Providing this information is always optional, although certain features of the website may require it.

1.2 Automatically Collected Information

Basic technical information may be collected automatically when you visit the website, including:

• Pages visited

• Time spent on pages

• Device and browser type

• IP address (used for security and anti-spam protection)

This information helps improve the performance and reliability of the website.

We do not collect sensitive financial documents, Social Insurance Numbers, banking credentials, or other protected identifiers through this website.

2. How Your Information Is Used

Your information may be used for the following purposes.

2.1 Communication and Scheduling

• Responding to inquiries

• Scheduling Quick Connect conversations

• Scheduling Clarity Sessions

• Sending confirmations, reminders, or follow-up communication

2.2 Educational Resource Delivery

Information may be used to:

• provide clarity-based educational insights

• share relevant resources

• communicate next steps based on Clarity Check responses

2.3 Service Coordination (When Requested)

In situations where regulated financial services are required, individuals may request introductions to licensed professionals.

If requested, limited information may be shared only with your consent to facilitate communication.

No information is shared without explicit permission.

2.4 Website Operations

Information may also be used to:

• improve website performance

• understand how educational resources are used

• support internal operational planning

We do not sell, rent, or trade personal data.

We do not use automated decision-making for eligibility, credit, or financial outcomes, and we do not build advertising profiles or track you across unrelated websites. Where the Clarity Check tailors its educational responses to your answers, this is used only to provide more relevant guidance — never to make regulated financial decisions about you.

3. How Your Information Is Protected

We implement industry-standard security practices to protect personal information, including:

• secure form submissions

• encrypted communication environments

• limited internal access to data

• authentication controls for administrative systems

While reasonable safeguards are used, no digital system can guarantee absolute security. By using this website, you acknowledge the inherent risks associated with internet communications.

4. Sharing of Information

We share information only under the following circumstances.

4.1 With Your Consent

Information may be shared if you request to be introduced to a licensed professional such as:

• mortgage professionals

• insurance advisors

• financial planners

• legal or tax professionals

Only the information required for the introduction will be shared.

4.2 Service Providers

We may use trusted third-party service providers for operational functions such as:

• email communication

• scheduling platforms

• secure form processing

• payment processing (if applicable)

These providers are required to maintain appropriate privacy protections.

4.3 Legal Requirements

Personal information may be disclosed if required by law or legal process.

Such situations are rare and typically occur only in connection with lawful investigations.

5. Your Privacy Rights (PIPEDA)

Under Canadian privacy law, you have the right to:

✔ Request access to personal information we hold about you

✔ Request corrections to inaccurate information

✔ Withdraw consent to communications

✔ Request deletion of personal information where legally permitted

Requests may be submitted using the contact information provided below.

6. CASL Compliance (Email and SMS)

By submitting contact information through this website, you may receive service—related communications connected to your request, including:

• Clarity Check responses

• Quick Connect scheduling

• Clarity Session confirmations

• educational resources related to your inquiry

• service-related updates

Marketing and promotional communications — such as our newsletter, occasional insights, and updates about Wealth Within Reach® — are sent only with your express consent. Where you check a marketing consent box on one of our forms, that constitutes your express consent to receive these communications.

You may unsubscribe at any time using the unsubscribe link in any email, by replying STOP to SMS messages where applicable, or by contacting us directly. Withdrawing consent stops promotional communications; you may still receive messages needed to complete a request you have initiated.