Privacy Policy

Griffin Financial
PO Box 5, Burin, NL A0E 1E0
Last updated: 1 September 2026

This policy describes how Griffin Financial collects, uses, and discloses personal information in our insurance and investment practice and on griffinfinancial.ca. It is written to meet the openness, consent, and access rules in Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Canada's Anti-Spam Legislation (CASL), Newfoundland and Labrador insurance consumer-protection rules, and Google's advertising disclosure rules for sites that use Google Ads.

Bob Griffin is the person accountable for this policy (our privacy officer). Questions, access requests, and complaints go to bob@griffinfinancial.ca, (709) 325-0262, or PO Box 5, Burin, NL A0E 1E0.

Who we are

Griffin Financial is a Newfoundland and Labrador financial security practice. We advise business owners and families on life insurance, accident and sickness coverage, group health and retirement benefits, corporate-owned coverage, and insurance-based investments such as segregated funds and registered plans. Our advisors are licensed in Newfoundland and Labrador. We are representatives of Canada Life and other insurers. Products are issued by those insurers, not by Griffin Financial. We are not a bank, trust company, or deposit-taking institution.

We only accept clients who reside in Newfoundland and Labrador. We do not open or service files for residents of other Canadian provinces or of the United States. If you contact us from outside Newfoundland and Labrador, we will not take you on as a client. This website may still be reachable from elsewhere. That does not expand where we are licensed or where we offer advice.

This website is hosted by Squarespace. Appointments are booked through TidyCal. We send practice email through Google Workspace (Gmail) and, where you have consented, through our email platform. We run Google Ads on this site, including conversion measurement (Google Ads ID AW-897402912).

The information we collect

We collect only what we need for the purpose we state at the time, or a purpose a reasonable person would expect in an insurance and investment relationship.

From the website, a booking, or a first conversation we may collect:

  • name, email, phone, mailing address, and the company you own or work for
  • the reason for the meeting (company coverage, group benefits, personal file, or an existing client review)
  • appointment times and messages you send us
  • technical data such as IP address, browser, device, pages viewed, and referring site

Once you become a client, or ask us to prepare a recommendation, we may also collect information that insurance and investment work requires:

  • date of birth, occupation, income, and family or beneficiary details
  • health and lifestyle information for underwriting (collected with your consent, often on the insurer's forms)
  • social insurance number where tax reporting or a registered plan requires it
  • existing policy, group-plan, and investment account details, including statements you give us
  • corporate information for owner-managed companies (share structure, buy-sell terms, key person roles) when that is the file we are reviewing

We do not use this site to open online accounts, take premium payments, or collect full banking details. We do not knowingly collect personal information from children under 18 for an advisory relationship.

Why we use it

  • to schedule and hold the 30-minute business-owner checkup and later client meetings
  • to identify you, understand your needs, and make a suitable recommendation
  • to place, service, and review insurance contracts and investment accounts with the insurers and product manufacturers we represent
  • to meet KYC, suitability, anti-money-laundering, tax, and licensing record-keeping rules
  • to send service messages about your file, and commercial electronic messages only where CASL allows
  • to operate, secure, and improve griffinfinancial.ca
  • to measure advertising and, if you consent, to show you Griffin Financial ads on other sites (see Advertising and cookies)

We do not sell personal information. We do not use health information or social insurance numbers for marketing.

Consent

PIPEDA requires consent to be meaningful. We explain the purpose before or when we collect. You can refuse or withdraw consent, subject to legal or contractual limits (for example, we cannot keep a policy in force if the insurer requires information you will not provide).

Express consent is used for sensitive information (health, SIN, detailed finances), for placing a policy or opening an account, and for advertising or analytics cookies that are not strictly necessary. Implied consent may apply to information a reasonable person would expect us to use to answer an enquiry you started, or to service a policy you asked us to place.

Commercial email, text, or similar messages are sent only with CASL consent (express, or implied where the law still allows, such as an existing client relationship). Every commercial message includes sender identification and a working unsubscribe. You can also write bob@griffinfinancial.ca and ask to be removed.

Who we share it with

We share personal information only as needed for the purpose, including:

  • life, health, and group insurers and their reinsurers, for quoting, underwriting, issuing, claims, and administration (including Canada Life and other insurers we represent)
  • group-plan administrators and record-keepers when we place or service a workplace plan
  • the managing general agency and licensing platforms that support our Newfoundland licences
  • professional advisors you ask us to speak with (your lawyer or accountant), with your direction
  • regulators, courts, or a law-enforcement body when required by law
  • service providers who process information for us: Squarespace (website), Google (email, Analytics if enabled, and Ads), TidyCal (booking), and our email platform. Some of these providers store or access information in the United States. PIPEDA still applies to us. We use providers we believe have reasonable safeguards, and we remain accountable for the information.

We may also disclose information if we transfer the practice, with notice to affected clients.

Advertising and cookies (Google Ads)

This site uses cookies and similar technologies. The cookie banner lets you accept, decline, or manage non-essential cookies. Strictly necessary cookies (for example, remembering your cookie choice, or running the booking page) may still be used.

We use information from this website to advertise Griffin Financial online, including measuring whether an ad led to a visit or a booking.

Third-party vendors, including Google, show Griffin Financial ads on sites across the internet.

Third-party vendors, including Google, use cookies and/or device identifiers to serve ads based on someone's past visits to griffinfinancial.ca.

You can opt out of Google's use of cookies or device identifiers for ads in Google Ads Settings. You can also opt out of many third-party vendors through the Network Advertising Initiative opt-out page. Device-level ad settings on your phone or tablet also apply.

Declining advertising cookies does not stop every Griffin Financial ad. It stops us using your visit to this site to personalize those ads.

How Google uses information from sites that use its services is described at Google's Privacy Policy and Google's Business Data Responsibility page.

Retention and safeguards

We keep client files for as long as the relationship lasts and for the period insurance, tax, and licensing rules require after it ends, generally at least seven years. Website logs and advertising data are kept for a shorter operational period unless the law requires longer.

We use office, password, and provider-side access controls. No internet transmission is perfectly secure. If a breach creates a real risk of significant harm, PIPEDA requires us to report it to the Office of the Privacy Commissioner of Canada and to notify affected individuals.

Access, correction, and complaints

You may ask what personal information we hold about you, how we use it, and to whom we have disclosed it. Write bob@griffinfinancial.ca. We respond within 30 days, at little or no cost, unless PIPEDA allows us more time or an exception (for example, another person's information, or solicitor-client privilege).

If something is inaccurate or incomplete, we will correct it and, where appropriate, send the correction to parties we had disclosed it to. If we disagree, we will note your challenge on the file.

If you are not satisfied with our response, you may complain to us first, then to the Office of the Privacy Commissioner of Canada, priv.gc.ca.

Insurance product complaints can also follow the insurer's process and, for life and health products, the OmbudService for Life & Health Insurance. Licensing complaints about an advisor may be made to the Superintendent of Insurance, Financial Services Regulation Division, Government of Newfoundland and Labrador, gsinfo@gov.nl.ca.

Changes

We will post updates on this page and change the date above. Material changes to how we handle personal information will be highlighted on the site or sent to affected clients.