celmarionis

Data Stewardship Statement

Effective from March 1, 2026

celmarionis operates as a provider of investment analysis and strategic guidance within the Canadian financial sector. This statement explains how we handle identifying details, operational records, and communication patterns entrusted to us by clients and visitors.

Our approach centers on the principle that every piece of identifying detail exists for a defined operational purpose. We don't request, record, or retain anything beyond what directly serves the analytical and educational functions you engage us for.

Questions? Reach Kirby McLeod, our stewardship coordinator, at help@celmarionis.com or call +1 705 324 7314. Mail correspondence to 47 West Street N, Orillia, ON L3V 5C1, Canada.

Information Intake Across Service Touchpoints

Details about users emerge at different stages of interaction. Here's what gets captured and when it enters our operational environment.

Account Registration Phase

When someone sets up an account to access learning materials, portfolio analysis tools, or strategy consultations, we record identifying elements needed to maintain that relationship. This includes full name, email address, and phone contact if consultation scheduling is involved. Payment credentials never touch our servers directly — they're processed through external payment handlers, and we receive only transaction confirmations stripped of card specifics.

Educational Program Enrollment

Participants in structured learning programs provide professional background details — current employment sector, prior investment experience level, specific analytical challenges they're facing. These contextual details shape how we customize curriculum delivery and case study selection. Geographic location within Canada matters here because tax treatment examples and regulatory context differ between provinces.

Consultation Interactions

During one-on-one strategy sessions, notes get recorded about portfolio composition questions, risk tolerance indicators expressed during conversation, and analytical frameworks discussed. These notes exist solely to maintain continuity between sessions and to track which methodologies have been introduced to which clients. No investment positions or account balances get stored in our systems.

Platform Navigation Patterns

Technical logs capture which educational modules get accessed, how long users spend reviewing specific analytical tools, and which resource downloads occur. Browser type, device category, and timestamp data create a usage footprint that helps us identify confusing interface elements or neglected content areas.

We don't acquire sensitive authentication credentials, full financial account details, or social insurance identifiers. Those elements fall outside the operational boundaries of what we actually do.

Operational Application and Internal Access Parameters

Once details enter our operational sphere, they serve specific functions tied to service delivery. Different categories of identifying information remain accessible only to staff members whose job responsibilities require that access.

Service Delivery Functions

Educational coordinators reference profile details to match participants with appropriate program difficulty levels. Consultation schedulers access contact information to coordinate session timing and send preparatory materials. Financial analysts review disclosed experience levels before tailoring methodology discussions to appropriate complexity.

Usage pattern data helps our curriculum designers identify which topics generate confusion or disengagement. If completion rates drop sharply midway through a module on derivatives analysis, that signals a need to restructure explanations or add foundational context.

Communication Continuity

Email addresses enable delivery of program updates, notification of new analytical resources, and confirmation of consultation bookings. Phone contacts come into play when urgent schedule changes require immediate coordination. These aren't promotional channels — they exist for operational correspondence tied to services already engaged.

Internal Segmentation Logic

Administrative staff can view identification details and contact mechanisms. Curriculum developers see aggregated behavioral patterns but not names attached to those patterns. Financial consultants access client-provided context about experience and objectives but not payment transaction histories.

This compartmentalization means that someone troubleshooting a technical platform issue doesn't automatically gain visibility into what specific users discussed during private consultations. Access boundaries exist at the task level, not the department level.

  • Account authentication systems remain isolated from consultation note repositories
  • Payment processing confirmations flow through separate pathways from curriculum access logs
  • Aggregated analytics dashboards strip individual identifiers before reaching content development teams

External Information Movement and Partner Relationships

Certain operational necessities require limited transmission of identifying details beyond our direct control. These movements occur under specific constraints and never for purposes unrelated to service provision.

Payment Processing Infrastructure

Financial transaction execution depends on specialized payment processors who handle card authentication and charge processing. We transmit enrollment fees and consultation payment amounts alongside minimal identification — typically just email and name — sufficient for receipt generation. The actual card verification happens entirely within the processor's environment. We receive confirmation codes and timestamp records, nothing more.

Platform Hosting and Technical Infrastructure

Our learning platform and consultation scheduling system operate on cloud infrastructure maintained by technical service providers. These providers store the data that makes those systems function but contractually can't examine, extract, or repurpose any client-identifying content. Their access extends only to system maintenance and security patching activities.

Regulatory and Legal Requirements

Canadian financial services regulations occasionally compel disclosure of client interactions when regulatory inquiries occur. Tax authorities might request transaction records during audits. Court orders can mandate production of communication records. These disclosures happen exclusively in response to formal legal demands, not routine business operations.

Situations We Don't Create

Client lists don't get sold to marketing aggregators. Email addresses never migrate to third-party promotional platforms. Usage behavior patterns aren't packaged for advertising networks. We don't participate in data brokerage ecosystems because that operational model contradicts the stewardship principles outlined here.

Before any external entity gains access to client-identifying details, contractual constraints establish permitted usage boundaries and prohibit unauthorized secondary applications.

Security Infrastructure and Acknowledged Exposure

Protecting stored details involves multiple defensive layers, but no security configuration eliminates risk entirely. We're transparent about both protective measures and inherent vulnerabilities.

Technical Safeguards In Place

Transport encryption protects data moving between user devices and our servers. At-rest encryption scrambles stored records so that raw database access doesn't immediately expose readable content. Access authentication requires multi-factor verification for administrative accounts with elevated privileges.

Regular security audits probe for configuration weaknesses, outdated software components, and potential intrusion pathways. Penetration testing simulates adversarial attacks to identify defensive gaps before actual threats exploit them.

Operational Security Practices

Staff members undergo training about social engineering tactics, phishing recognition, and secure credential management. Access permissions get reviewed quarterly and revoked when job responsibilities change. System activity logs capture who accessed what information and when, creating audit trails for anomaly detection.

Persistent Vulnerabilities

Sophisticated attackers sometimes breach even well-defended systems. Human error occasionally exposes credentials or misconfigures access controls. Third-party infrastructure providers face their own security challenges that could cascade into our environment. While we work to minimize these risks, they can't be eliminated entirely.

If a data breach occurs, affected individuals receive direct notification within 72 hours of breach discovery, along with specific details about what information was exposed and what protective steps they should consider.

  • System backups undergo encryption and geographic distribution to prevent catastrophic loss
  • Terminated employee access gets revoked immediately upon departure
  • Vendor security assessments occur before establishing new service provider relationships

User Authority Over Recorded Details

Individuals maintain several forms of control over information we hold about them. These aren't just theoretical rights — they're operational capabilities we've built into our systems.

Inspection and Verification

At any point, you can request a comprehensive export of what details we've recorded about you. This includes profile information, consultation notes, communication logs, and usage behavior summaries. The export arrives in portable format within two weeks of request submission. No fee applies for this access unless requests become excessive — more than four times annually qualifies as excessive.

Correction and Updates

Inaccurate details get corrected upon notification. If your professional background information becomes outdated or was initially recorded incorrectly, you can submit corrections through your account settings or by contacting our stewardship coordinator. Changes take effect within five business days.

Deletion and Account Closure

Account termination triggers systematic removal of associated identifying details. Most content disappears immediately — profile information, contact details, and preference settings. Consultation notes and educational progress records linger for six months to handle potential disputes or completion certificate requests, then undergo permanent deletion.

Some records persist due to legal retention requirements — transaction histories related to paid services remain archived for seven years to satisfy tax authority requirements. These archived records exist in isolated storage without connection to active operational systems.

Processing Objections

If you believe certain details shouldn't be processed for particular purposes, you can formally object. We evaluate these objections against operational necessity and legal requirements. When the objection has merit and doesn't prevent basic service delivery, we accommodate it. If we can't honor the objection, we explain specifically why that limitation exists.

Escalation Pathways

Disputes about how we handle these requests can escalate to the Office of the Privacy Commissioner of Canada. That's an independent regulatory body empowered to investigate complaints and compel corrective action when warranted. Their contact information: 30 Victoria Street, Gatineau, QC K1A 1H3, or via their website at priv.gc.ca.


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