Privacy Policy

Effective and Last Updated: September 2023

1. Introduction

The Raymond James Living Wealth newsletter and content website platform is operated by Tonic Media. Your privacy is important to Tonic Media Inc., (“Tonic”, “we”, “us” or “our”). This Policy explains how we collect, use, disclose and protect the personal information of individuals who:

1. visit or interact with our website;
2. register to use the products and services which we market for subscription (the “Service(s)”); or
3. attend or register to attend sponsored events or other events at which Tonic participates.

2. Information That You Provide to Us

Account and Registration Information:

When you choose to complete the registration process and create an account, we may collect the following personal information:

• your first and last name;
• your email address;
• your postal code;
• your created username and password; and
• your content category interests.

Other Optional Features

When you register for Services, you consent to receiving standard Tonic member communications. Including, standard welcome messaging from your hosts, weekly email newsletter and special Tonic announcements.

Occasionally, we may ask you to provide us, on a voluntary basis, with your preferences and demographic information. The purpose is to give you the option to receive communications from us tailored to your interests.  

If you communicate with us using our online chat function or our support ticket system, we will collect the information that you choose to provide.

Attendee Information:

We may ask for and collect personal information such as your name and email address when you register for or attend a sponsored event or other events at which any member of the Tonic participates, in order to facilitate your registration or attendance at an event, including sending related communications to you.

Referring Advisors’ End Client and Prospect Information

Membership fees are paid for by your advisor. Your membership is jointly hosted by Tonic and your advisor (your “hosts”). An Advisor who purchases membership on behalf of their client will make a referral to their client by way of an email with a link to the Tonic program. When their client accepts the referral and completes the Tonic registration, they become a Tonic member. We will only collect, and store member data and email addresses provided by the member themselves. Advisors will not send personal information of any kind or email addresses to Tonic.

Tonic does not sell member data / email addresses and does not use them to send any other communication beyond standard member communications. Members may contact Tonic to request the deletion of their personal information from our database at concierge@tonicmedia.ca.

Membership Referrals

The Membership Referability (Share) privilege is available to all Tonic paid members. A paid member is someone who was invited by and paid-for by the advisor. Paid members may invite up to 10 (ten) additional close friends and family to become Tonic members. Referred members cannot complete further subsequent referrals.

If you choose to use the referral feature, you will be asked to complete an e-form providing your friend’s name and email address.  The names provided will then be invited to become Tonic members by way of our system-generated message sent to the email address you provided. This message will inform them that you have invited them to become a Tonic member. If they accept your referral, the referred persons may become Tonic members by registering and opting-in. There are no fees payable, and they will remain a member as long as your membership remains intact or until they unsubscribe themselves. 

Their name and email will only be stored for the purpose of sending the invitation messages (email) and tracking the success of your referral. Follow-up reminder messages will not be sent messages.

After the referred person accepts the membership and upon registration, new members will be encouraged to opt-in for Tonic program communications. Then (and only then) will your hosts communicate directly with them by way of our standard member communications. We will never market / email a referral if they have not opt-ed in.

You may check the status of your referrals by viewing My Account at any time to see who from your referral list has accepted your invitation to become a Tonic member. Advisors may check referrals within their Advisor Dashboard to see who has made a referral and who is a referral. The Host advisor will be notified when a referral stating who has made a referral and who has been referred.

Your referral may contact us at concierge@tonicmedia.ca to request that we remove his/her information from our database.

3. Information That We Collect from You on our Website

Cookies and Other Tracking Technologies

Our Website uses "cookies" and other tracking technologies. We use cookies to provide website functionality, to analyze traffic, and to personalize content. Cookies recognize your computer to enable us to serve secure pages to our users without asking them to sign in repeatedly. If a user's system is idle for a defined time, the cookie will expire, forcing the user to sign in again to continue their session. This prevents unauthorised access to the user's information while they are away from their computer.

Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them. You may choose to block or erase cookies. If you do so, you will need to re‐enter your original user ID and password to gain access to the Website.

In the course of serving subscription content to you on our Website, our third‐party publisher partners may place or recognise a unique "cookie" on your browser.

Essential Website Cookies

These cookies are strictly necessary to provide you with services available through the Website and to use some of the Website features, such as access to secure/membership areas. Because these cookies are strictly necessary to deliver our Service, you cannot refuse them without impacting how our Website functions. You can block or delete them by changing your browser settings.

Provider	Description	Cookie Name(s)
Tonic	These cookies are strictly necessary to provide you with services available through our Website and to use some of its features, such as access to secure areas.	LWAuth __RequestVerificationToken

 

Analytics

These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or to help us customize our program for you in order to enhance your experience. These cookies may be set by us or by third-party providers whose services we have added to our pages.

Provider	Description	Cookie Name(s)
Tonic / Google	These are set by Google Universal Analytics. They are used to calculate visitor and session data for our analytics reports.	_gat _ga

 

Advertising (Targeting) Cookies

These cookies are placed by third party advertising platforms or networks in order to deliver ads and track ad performance outside of the Website and enable advertising networks to deliver ads that may be relevant to you based upon your activities (this is sometimes called “behavioral” “tracking” or “targeted” advertising) on the Website. They may subsequently use information about your visit to target you with advertising that you may be interested in, on the Website and other websites. For example, these cookies remember which websites you have visited.

Provider	Description	Cookie Name(s)
Zendesk (3rd party Help/Chat)	Zendesk core help/chat functionality.	__zlcmid
Google/DoubleClick via Zendesk	Re-targeting, optimization, reporting and attribution of online advertising.	DSID IDE _fbp permutive-id permutive-session

 

4. How We Use Information That We Collect

We use personal information to:

• provide our Services;
• communicate with registered users in relation to our services and/or the information collected;
• provide registered users with content that is relevant to their interests with the delivery of editorials, privileges, experience opportunities;
• deliver weekly newsletters and provide major content updates or announcements;
• provide customer service;
• maintain and operate our Website; and
• improve our Services.

We use non‐identifying and aggregate information to better design our Website as well as for business and administrative purposes.

5. Email Communications

With your consent, we may send you email notifications typically limited to a weekly newsletter. If you no longer wish to receive email updates or notifications, you may unsubscribe through the dedicated link on each email. 

6. Data Sharing

We may use third party service providers (including affiliates acting in this capacity) to perform certain services on our behalf including to: host the Website; operate various features available on the Website; send emails; analyze data; provide search results and links; and assist in fulfilling your orders. Data transfers are subject to contractual agreements that ensure that your personal information is adequately protected. Our service providers will be located inside Canada wherever possible, but in rare circumstances your personal information may be processed outside of Canada.

We may permit certain trusted third parties to track usage, analyze data such as the source address that a page request is coming from, your IP address or domain name, the date and time of the page request, the referring website (if any) and/or other parameters in the URL; if this sharing is for the third parties’ purposes (e.g. marketing) you will be provided with an opportunity to opt-out.

In exceptional cases, we or our service providers may be permitted or required by law (including foreign laws) to share your personal information, for example, pursuant to a warrant or production order or in the context of a lawful investigation.

As permitted by law, we may disclose contact information in special cases where we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms and Conditions of use or may be causing injury or interference with our rights, property, our customers or anyone who could be harmed by such activities.

We may share personal information in other circumstances with your consent.

We will not share personal identifiable data. We may use or share aggregated data that contains no personal identifiable information with third parties.

7. Third Party Links:

Occasionally, at our discretion, we may include links to third party websites or offer third party products or services on our Website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

8. How We Protect Your Information

To protect the information we receive from you, we apply security measures against unauthorised access to or unauthorised alteration, disclosure or destruction of data. These include physical safeguards, electronic tools and managerial procedures to secure the information stored on our system. Please note that no computer system is completely secure, and it is possible that your personal information may be accessed, used or disclosed without authorization.

9. Location of Personal Information   

Tonic stores all personal information collected at Canadian facilities located in Canada wherever possible.

10. Data Retention

The file containing your personal information will be maintained on our servers or those of our service providers and will be accessible by authorized employees, representatives and agents who require access to perform their job functions.

We retain personal information for only as long as necessary to fulfill the purposes for which the information was provided, in accordance with prudent record retention practices or as required by law. When there is no longer a reason to retain it, we will delete it.

11. Managing Your Personal Data

You may request access to or correction of the personal information in our custody or control by contacting us at: concierge@tonicmedia.ca.

Your right to access and correct your personal information is subject to applicable legal restrictions.  We may take steps to verify your identity before providing access or making corrections.

12. Your Consent

We collect personal information with your consent or as permitted or required by law. Generally, by using our Website or providing us with personal information, you consent to the collection, use and disclosure of your personal information as described in our privacy policy. Additionally, members will be asked to opt-in for future communications and will be asked to review and grant their expressed consent to our Terms & Conditions. You may withdraw your consent at any time, subject to contractual and legal restrictions. 

13. Changes to This Policy

This Policy may be updated from time to time to reflect changing legal, regulatory or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices.

If there are any material changes to this Policy, you will be notified by our posting of the revised Policy on our Website.

If you do not accept any changes made to this Policy, please discontinue use of the Website and the Services.

14. Contact Us

If you have any questions or concerns regarding this Privacy Policy, please contact us by email at: concierge@tonicmedia.ca or at:

Tonic Media Inc.
Attn: Privacy Officer
30 Wellington Street West, 5th Floor
Toronto, ON, M5L 1B1