Privacy Policy

1. Personal information we may collect

"Personal Information" generally means information that identifies, relates to, describes, or can reasonably be associated with an identifiable individual, subject to applicable law.

Depending on the Service or campaign, we may collect information such as:

• first and last name;
• email address;
• telephone or mobile number;
• mailing address;
• city, province/state, postal/ZIP code, or other geographic information;
• age or age range, where relevant and legally permitted;
• information submitted through forms, questionnaires, surveys, or applications;
• information relating to your interest in a particular product or service;
• appointment and contact preferences;
• communications and correspondence with us;
• IP address;
• device and browser information;
• referring website or advertisement;
• website and landing-page activity;
• cookie, pixel, and similar technology data;
• advertising attribution and campaign information; and
• other information you voluntarily provide through our Services.

We seek to limit the Personal Information we collect to information reasonably necessary for the purposes disclosed to you.

Certain campaigns may request additional information where reasonably necessary to provide the requested service. Sensitive information, where collected, will be handled in accordance with applicable law and appropriate safeguards.

2. How we collect information

We may collect Personal Information:

• directly from you when you complete a form, questionnaire, survey, request, or application;
• when you interact with our websites or landing pages;
• when you respond to an advertisement;
• when you communicate with us by telephone, text message, email, web form, or another communication channel;
• through cookies, pixels, analytics technologies, and similar tools;
• from advertising platforms and marketing providers;
• from clients or Business Partners where permitted by law; and
• from other lawful sources.

Where required by applicable law, we will provide appropriate notice and obtain consent before collecting, using, or disclosing Personal Information.

3. How we use personal information

Family First Financial may collect and use Personal Information to:

• process and respond to requests;
• connect consumers with relevant Business Partners or professionals;
• generate and deliver inquiries or leads;
• schedule or facilitate appointments;
• provide requested products, information, offers, resources, or services;
• enable follow-up regarding a request;
• communicate by telephone, email, text message, or other permitted methods;
• operate and improve our websites, landing pages, campaigns, and Services;
• measure advertising and campaign performance;
• determine the source of inquiries and leads;
• analyze traffic, usage, conversion rates, and interactions;
• prevent fraud, abuse, security incidents, and unauthorized activity;
• maintain and secure our systems;
• provide customer support;
• maintain business and transaction records;
• comply with legal and regulatory requirements;
• enforce our agreements and policies; and
• carry out other purposes disclosed at or before collection.

We will not use Personal Information for a materially different purpose without providing any notice or obtaining any additional consent required by applicable law.

4. Business Partners and lead generation

Family First Financial may operate marketing and lead-generation campaigns that connect consumers with third-party businesses, licensed professionals, or service providers.

When you submit information through a particular campaign, we may disclose your information to the Business Partner or Business Partners associated with that campaign for the purposes disclosed on the applicable form or landing page.

Depending on the campaign, Business Partners may include:

• insurance companies;
• insurance agencies;
• licensed insurance agents or brokers;
• financial service providers;
• estate-planning service providers;
• marketing clients;
• appointment-setting providers;
• campaign sponsors; or
• other businesses offering products or services about which you requested information.

Where required, the identity or category of the intended recipient will be disclosed through the applicable campaign, consent language, form, or other notice.

Family First Financial does not control the independent privacy practices of a Business Partner once that Business Partner receives information as an independent organization. Consumers should review the privacy policies of the businesses with which they interact.

5. Consent and communications

By submitting Personal Information through a form, landing page, advertisement, or other Service, you authorize Family First Financial to process that information for the purposes disclosed at the point of collection and as described in this Privacy Policy, subject to applicable law.

Where required, separate or additional consent may be requested for marketing communications, telephone calls, automated communications, or text messages.

Consent to receive marketing communications may be withdrawn in accordance with applicable law.

Withdrawal of marketing consent does not necessarily prevent Family First Financial or a Business Partner from contacting you where communication is necessary to respond to a request you initiated, complete a transaction, provide a requested service, comply with law, or for another legally permitted purpose.

6. Telephone, text and email communications

Depending on the consent provided through a particular campaign, Family First Financial and/or identified Business Partners may contact you using the information you provide.

Communications may include telephone calls, emails, or text messages where permitted by law and consistent with the consent obtained.

Marketing emails will provide an unsubscribe mechanism where required.

Where applicable, users may opt out of marketing text messages by following the instructions provided in the message, such as replying STOP.

Message and data rates may apply.

The specific consent language presented when you submit your information governs the communications authorized through that submission.

7. Disclosure of personal information

We may disclose Personal Information to:

Business Partners

Businesses, agencies, licensed professionals, clients, or organizations associated with the campaign or Service through which you submitted your information.

Service Providers

Companies that assist Family First Financial with services such as:

• website hosting;
• cloud storage;
• database and CRM services;
• communications and messaging;
• analytics;
• advertising technology;
• security;
• information technology;
• data processing; and
• other operational services.

Advertising and Analytics Providers

We may work with advertising and analytics providers to measure campaign effectiveness, understand website usage, attribute inquiries to advertising sources, and improve our Services.

Legal and Regulatory Authorities

We may disclose information where reasonably necessary to:

• comply with applicable law;
• respond to lawful court orders, subpoenas, warrants, or regulatory requests;
• cooperate with law enforcement;
• investigate fraud or illegal activity;
• protect the rights, property, or safety of Family First Financial, consumers, Business Partners, or others; or
• establish, exercise, or defend legal claims.

8. Sale or sharing of personal information

Family First Financial does not sell Personal Information for monetary consideration unless expressly disclosed.

Certain privacy laws may define "sale" or "sharing" more broadly than an exchange of information for money. Certain advertising, lead-distribution, or data-disclosure activities may therefore be considered a "sale" or "sharing" under applicable law.

Where Family First Financial engages in activities legally defined as a sale or sharing of Personal Information, we will provide any notices, choices, and opt-out mechanisms required by applicable law.

Nothing in this section is intended to characterize a disclosure as a "sale" or "sharing" where applicable law does not define it as such.

9. Cookies, pixels and analytics

Our Services may use cookies, pixels, tags, scripts, local storage, and similar technologies to:

• operate websites and landing pages;
• remember preferences;
• measure website traffic;
• understand user interactions;
• measure advertising performance;
• identify the source of an inquiry;
• prevent fraud or security incidents;
• improve user experience; and
• support advertising and remarketing activities where permitted.

Third-party advertising, analytics, CRM, hosting, or technology providers may also use these technologies.

Users may be able to control cookies through browser settings or cookie-preference tools where available.

10. Advertising

Family First Financial may use advertising platforms to promote campaigns, products, and Services.

Advertising providers may collect information regarding interactions with advertisements or websites through cookies, pixels, device identifiers, and similar technologies.

This information may be used for advertising measurement, attribution, audience measurement, campaign optimization, and targeted or interest-based advertising where permitted by law.

Where applicable law provides a right to opt out of targeted advertising, cross-context behavioral advertising, sale, or sharing of Personal Information, Family First Financial will provide the required mechanism for exercising that right.

11. Data retention

Family First Financial retains Personal Information only for as long as reasonably necessary to:

• provide Services;
• fulfill requests;
• maintain business records;
• satisfy contractual obligations;
• resolve disputes;
• prevent fraud;
• enforce agreements; and
• comply with legal, regulatory, accounting, and reporting requirements.

When Personal Information is no longer required, we will securely delete, destroy, or de-identify it in accordance with applicable requirements.

12. Data security

Family First Financial uses reasonable administrative, technical, organizational, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, loss, theft, misuse, alteration, or destruction.

Safeguards may include:

• access controls;
• password protection;
• encryption;
• secure hosting and storage;
• technical security safeguards;
• confidentiality requirements; and
• limiting access to individuals with a legitimate business need.

No electronic transmission or storage method is completely secure, and absolute security cannot be guaranteed.

13. Cross-border processing

Family First Financial may use service providers, technology platforms, Business Partners, or infrastructure located outside your province, state, or country.

Personal Information may therefore be transferred to, stored in, or processed in Canada, the United States, or other jurisdictions.

Information processed in another jurisdiction may be subject to the laws of that jurisdiction and may be accessible to courts, law enforcement, or government authorities in accordance with applicable law.

14. Your privacy rights

Depending on your location and applicable law, you may have rights to:

• access your Personal Information;
• request information regarding how it has been collected, used, or disclosed;
• correct inaccurate information;
• request deletion, subject to legal exceptions;
• withdraw consent where processing is based on consent;
• opt out of certain marketing communications;
• opt out of certain sales, sharing, or targeted advertising;
• request information regarding categories of third parties receiving information;
• obtain a portable copy of certain Personal Information where required; and
• make a complaint concerning our privacy practices.

We may need to verify your identity before fulfilling a privacy request.

15. Canadian privacy rights

Where applicable, Family First Financial handles Personal Information in accordance with Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

Our privacy practices are guided by principles of:

• Accountability;
• Identifying purposes;
• Consent;
• Limiting collection;
• Limiting use, disclosure, and retention;
• Accuracy;
• Safeguards;
• Openness;
• Individual access; and
• Challenging compliance.

Individuals may request access to Personal Information under our control, ask how it has been used or disclosed, challenge its accuracy, and request corrections, subject to applicable legal exceptions.

16. United States privacy rights

Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws.

Depending on the jurisdiction and applicability of the relevant law, these rights may include:

• access;
• correction;
• deletion;
• data portability;
• opting out of certain sales or sharing;
• opting out of targeted advertising;
• limiting certain uses of sensitive Personal Information; and
• protection against unlawful discrimination for exercising privacy rights.

17. California privacy notice

If you are a California resident and the California Consumer Privacy Act, as amended ("CCPA"), applies to Family First Financial's processing of your Personal Information, you may have additional rights.

Depending on your interaction with us, categories of Personal Information collected may include:

• identifiers such as name, address, email address, telephone number, IP address, and online identifiers;
• internet or electronic network activity;
• approximate geographic information;
• commercial information and information regarding products or services in which you expressed interest;
• professional or employment-related information where relevant;
• inferences relating to your interaction with a campaign or Service; and
• other Personal Information voluntarily provided.

Subject to applicable exceptions, eligible California consumers may have the right to:

• know what Personal Information is collected;
• access specific Personal Information;
• request correction;
• request deletion;
• know the sources and purposes of collection;
• know categories of third parties receiving Personal Information;
• opt out of applicable sale or sharing;
• limit certain uses of sensitive Personal Information where applicable; and
• receive equal service without unlawful discrimination for exercising privacy rights.

Where required, applicable opt-out mechanisms will be made available through our website or by contacting us.

18. Children's privacy

Family First Financial's Services are intended for adults unless a particular Service expressly states otherwise.

We do not knowingly solicit Personal Information directly from children where parental or guardian consent is required.

Some campaigns may concern products, resources, or services relating to children. In these circumstances, information concerning a child may be provided by a parent or legal guardian.

If you believe a child has submitted Personal Information directly to Family First Financial contrary to this policy, please contact us.

19. Third-party websites

Our Services may contain links to independently operated third-party websites or services.

Family First Financial is not responsible for the privacy, security, content, or practices of third-party websites. Users should review the privacy policies of third parties before providing Personal Information.

20. Business transfers

If Family First Financial is involved in a merger, acquisition, financing, reorganization, sale of assets, or other corporate transaction, Personal Information may be disclosed or transferred as part of that transaction where permitted by law.

Any recipient will be required to handle Personal Information in accordance with applicable privacy obligations.

21. Privacy requests and complaints

To exercise an applicable privacy right, request access or correction, withdraw consent, or submit a privacy-related question or complaint, contact:

We may request information reasonably necessary to verify your identity before responding.

Nothing in this Privacy Policy limits any right you may have to submit a complaint to an applicable privacy or data-protection regulator.

22. Changes to this Privacy Policy

Family First Financial may update this Privacy Policy periodically to reflect changes to our Services, business practices, technologies, or legal obligations.

Updates will be posted with a revised "Last Updated" date. Where required by law, we will provide additional notice or obtain consent before materially changing how Personal Information is collected, used, or disclosed.

23. Contact Family First Financial Inc.

Questions regarding this Privacy Policy or Family First Financial's privacy practices may be directed to: