FinanceIt Canada Inc. (“Financeit”) is committed to keeping personal information accurate, confidential, secure and private. Your personal information is handled in accordance with this policy and all federal privacy laws and regulations including the Personal Information Protection and Electronic Documents Act (“PIPEDA”). Ten Principles guide our privacy practices. Click on any of the Principles below or scroll down to know more.
Principle 1 — Financeit’s Accountability
Principle 2 — Identifying The Purposes of Collecting Personal Information
Principle 3 — Obtaining Consent
Principle 4 — Limits On The Collection Of Personal Information
Principle 5 — Limits On Using, Disclosing And Keeping Personal Information
Principle 6 — Keeping Personal Information Accurate
Principle 7 — Safeguarding Personal Information
Principle 8 — Making Information About Policies And Procedures Available To Individuals
Principle 9 — Access To Personal Information
Principle 10 — Handling Individuals’ Complaints And Questions
Customer Service Representatives (CSR)
The public is encouraged to address their initial questions and concerns about any Financeit product or service to our Client Services Representatives (“CSRs”). CSRs may be reached by telephone at: 1 888 536 3025 or email at: email@example.com
“Financeit” is the operating name of FinanceIt Canada Inc.
Personal Information is information about an identifiable individual, but does not include the name, title or business address or business telephone number of an employee of an organization for the purpose of communicating with the individual in relation to their work.
Financeit’s Privacy Office is responsible for ensuring the protection of personal information at Financeit. To request access to, or correction of, your personal information, or to make other inquiries regarding your personal information, you may contact our Privacy Office at:
Attention: Chief Privacy Officer
FinanceIt Canada Inc.
Suite 500, 296 Richmond Street West
Toronto, Ontario, M5V 1X2
Tel: 1 888 536 3025
A word about your personal information
We use personal information to arrange to provide credit to you and otherwise administer our business, including to: open, administer, enforce and collect on your loan; verify your identity in compliance with requirements under anti-money laundering legislation (which may include checking identity against watch lists established by regulatory agencies and similar bodies in Canada and foreign countries); verify your current and ongoing creditworthiness; protect you and us from theft, fraud or other unlawful activities.
The Ten Principles of Privacy in Summary
These ten principles are interrelated and must be read in conjunction with the accompanying commentary.
1. Financeit’s Accountability
2. Identifying The Purposes Of Collecting Personal Information
Financeit will inform individuals of the purpose for which personal information will be used before or when they consent to its collection.
3. Obtaining Consent
An individual can provide consent to the collection, use and disclosure of personal information about them expressly, implicitly, or through an authorized representative. An individual can withdraw consent at any time, with certain exceptions.
Financeit will collect, use or disclose personal information without an individual’s consent only in limited circumstances as permitted by law.
4. Limits For Collecting Personal Information
5. Limits For Using, Disclosing And Keeping Personal Information
Financeit will use or disclose personal information only for the reasons it was collected, unless an individual gives consent to use or disclose it for another reason. Under certain circumstances, Financeit may have a legal duty or right to disclose personal information without consent.
Financeit will keep personal information only as long as necessary for the identified purposes.
6. Keeping Personal Information Accurate
Financeit will keep the personal information in its possession or control accurate, complete, current and relevant, based on the most recent information available to Financeit.
Individuals may challenge the accuracy and completeness of personal information about them and have it amended as appropriate by contacting the Privacy Office located at:
Attention: Chief Privacy Officer
Financeit Canada Inc.
Suite 500, 296 Richmond Street West
Toronto, Ontario, M5V 1X2
Tel: 1 888 536 3025
7. Safeguarding Personal Information
Financeit protects personal information with safeguards appropriate to the sensitivity of the information.
8. Making Information About Policies And Procedures Available
9. Providing Access To Personal Information
When an individual requests it, when possible, Financeit will advise or provide access to the individual what personal information Financeit has in its possession or control about the individual, what it is being used for, and to whom it has been disclosed. In certain situations, however, Financeit may not be able to give individuals access to all of their personal information.
10. Handling Complaints And Questions
Principle 1: Financeit’s Accountability
Financeit is accountable for all personal information in its possession or control, including any personal information transferred to third parties for processing on our behalf. Senior management have ultimate accountability for protecting personal information, and they in turn delegate the day-to-day management of procedures involving personal information protection to the Chief Privacy Officer and the Chief Compliance Officer.
- has established procedures to protect the privacy of personal information;
- has established procedures to receive and respond to questions and complaints;
- has trained Financeit staff to understand and follow Financeit’s privacy procedures.
Financeit is also accountable for personal information that has been transferred to a third party for processing. Financeit’s policies for safeguarding personal information transferred to third parties are set out in sections 7.4 and 7.5 below.
Principle 2: Identifying The Purposes of Collecting Personal Information
1. Financeit collects personal information (which may include credit, employment and other financially-related or identification-related information) for the following purposes:
- to identify clients
- to review creditworthiness
- to assess risk
- to set up and manage products and services that meet an individual’s needs;
- to offer products and services to meet those needs
- to provide ongoing service, and
- to meet legal and regulatory requirements, such as requirements under the Income Tax Act, anti-money laundering, anti-bribery and credit reporting requirements.
2. In addition, Financeit may collect, disclose and use personal information for some or all of the following purposes:
- to verify information on an application
- to help verify a new client’s identity
- to verify the identity of a client when corresponding with that client, and to protect the client and Financeit from error or fraud
- to investigate specific transactions or patterns of transactions for the purpose of detecting unauthorized or illegal activities
- to ensure that a client’s instructions can be properly verified, and,
- to investigate client complaints.
3. Personal information is:
- exchanged with credit bureaus, credit reporting agencies, credit insurers, telecommunications providers, and other financial institutions, to maintain the integrity of the credit- granting process and to determine eligibility for financial products and services (in certain cases, individuals have a right to access their personal information in the control of these institutions; contact our CSRs to find out how to access their personal information in the control of these institutions)
- used by Financeit to determine initial and ongoing eligibility for financial products and to notify clients of such products by website, mail, email or phone
- may be used by Financeit and disclosed to affiliates to satisfy regulatory reporting requirements and international banking standards
- may be collected, used and disclosed for the purpose of legal, regulatory and/or governmental requirements in accordance with law
may be collected, used and disclosed for the purpose of conducting risk assessments
- may be collected, used and disclosed to provide specific services associated with an account; and,
- may be disclosed to a joint account holder.
4. When an individual applies for a product or service:
- Financeit will make the individual aware of the purposes for which Financeit is requesting the personal information.
- If Financeit identifies other purposes for which the personal information
may be used, Financeit will seek the individual’s consent prior to starting these uses.
- Financeit will explain that it is the individual’s right to refuse permission for Financeit to use personal information for any such other purposes.
5. You may provide us with a Social Insurance Number (“SIN”) at your option, which we may use to match credit bureau information.
6. Should you open an account to be operated on behalf of a third party, personal information of that third party will be collected from you in accordance with money laundering legislation.
7. Individuals can ask for information about the purposes for which Financeit collects personal information when they phone Financeit or by writing the Privacy Office.
Please note that the purposes for collecting a name or address are sometime obvious and therefore do not need to be explained (such as when applying for a loan), but on occasion the purposes for collecting other information may not be as self-evident and when this is so, we will do our best to identify those purposes. Further, in some cases, Financeit will not explain those purposes or obtain the individual’s consent. (See section 3.4 and section 5.1 for details).
Principle 3: Obtaining Consent
Financeit obtains consent when or before it collects, uses or discloses personal information. Generally, Financeit will seek consent to use and disclose personal information at the same time it collects the information. In some circumstances, Financeit may identify a new purpose and seek consent to use and disclose personal information after it has been collected.
Financeit will collect, use or disclose personal information without an individual’s consent only in limited circumstances as permitted by law (see below.)
Subject to certain legal and contractual restrictions and reasonable notice, an individual can refuse or withdraw their consent to the collection, use or disclosure of personal information about them at any time.
1. Consent to the collection, use and disclosure of personal information can be expressed, implied, or given through an authorized representative of the individual.
- Individuals can express consent verbally, such as when information is collected over the telephone, in writing, such as when completing and signing an application, or electronically, such as when applying through a computer.
- Individuals can also imply their consent, for example, by using a Financeit product or service. In such a case, Financeit may assume that the individual consents to the use of the personal information.
2. Financeit may collect, use or disclose personal information without the individual’s knowledge and consent only in limited circumstances as permitted by law. For example:
- Financeit may collect, use and disclose personal information without the individual’s knowledge or consent if it is clearly in the individual’s best interests to do so and consent cannot be sought in a timely manner. An example of such a circumstance is when an individual is seriously ill.
- Financeit may collect, use and disclose personal information without an individual’s knowledge or consent in certain circumstances where the information is publicly available. An example would be the name, address and phone number of a subscriber to a telephone directory that is available to the public where the subscriber can refuse to have their personal information appear in the telephone directory.
- Financeit may collect, use and disclose personal information without the individuals’ knowledge or consent in accordance with law or upon the lawful request of a government institution or part of a government institution. An example would be when a government institution lawfully requests the information for the enforcement of any law of Canada, a province or a foreign jurisdiction.Subject to certain legal or contractual restrictions and reasonable notice, an individual may refuse or withdraw consent at any time.
- Financeit will inform individuals of the consequences of refusing or withdrawing consent when individuals seek to do so. Refusing or withdrawing consent for Financeit to collect, use or disclose personal information could mean that Financeit cannot provide the individual with a product, service or information of value to the individual. For example, if an individual does not allow Financeit to obtain a credit history report, Financeit may not be able to lend money to the individual due to prudent lending practices, or other regulations. However, Financeit will not unreasonably withhold products, services or information from individuals who refuse to give consent or who withdraw consent.
- Withdrawal of consent is not permitted in relation to a credit product where Financeit must collect and report information after credit has been granted. This is to maintain the integrity of the credit system.
- Financeit is required by law to collect certain types of personal information in order to verify the identity of its clients. If an individual does not allow Financeit to collect and use this information, or if the client later attempts to withdraw their consent, Financeit may not be able to open an account or maintain the account on behalf of that client.
- Financeit will not deny credit to an individual solely because the individual does not provide a SIN for this purpose. However, a SIN may be required where the individual is not able to provide any other adequate means of identification.
Principle 4: Limits On The Collection Of Personal Information
Financeit limits the amount and type of personal information it collects. Financeit will collect personal information only for purposes it has already identified to the individual or as permitted by law. Financeit will collect personal information about an individual primarily from that individual.
Principle 5: Limits On Using, Disclosing And Keeping Personal Information
Financeit will use or disclose personal information only for the reasons it was collected, unless consent is given to use or disclose it for another reason.
Under certain exceptional circumstances, Financeit may have a legal duty or right to disclose personal information without the individual’s knowledge or consent.
Financeit will keep personal information only as long as necessary for the identified purposes.
1. Financeit may disclose personal information without consent when required or permitted by law. Examples of such disclosure include:
- subpoenas, search warrants and other court and government orders;
debt collection or demands from other parties who have a legal right to personal information; and
- disclosure of personal information to a lawyer (or, in Quebec, a notary or an advocate) who represents Financeit.
2. In any of the circumstances referred to in Principle 5.1, Financeit will protect the interests of its clients by making sure that:
- orders or demands appear to comply with the laws under which they were issued — Financeit does not comply with casual requests for personal information from government or law enforcement authorities.
Note that when permitted by law, Financeit may notify individuals that an order or demand has been received. Financeit may notify individuals by telephone, or by letter to the client’s usual address.
3. Financeit may want to use personal information in its possession or control to market products and services to individuals, either directly through Financeit or through our approved network of independent merchants. In this regard, Financeit complies with the requirements of Canada’s anti-spam legislation (commonly known as “CASL”), and will only send commercials electronic messages (“CEMs”) of a promotional nature with a client’s express or implied consent. Such messages will include an unsubscribe mechanism, allowing clients to opt-out of such emails. However, clients cannot opt-out of all CEMs: transactional messages such as those relating to terms and conditions of products or services, amounts owing, missed payments and annual statements, are mandatory.
4. If personal information has been used to make a decision about an individual, Financeit will keep the personal information long enough for the individual to have access to it after the decision has been made, or for as long as required by law.
5. Personal information and non-personal information is primarily stored in Canada. Financeit may transfer and/or store such information with Financeit’s service vendors, which may be located in the United States. In the event that a service vendor is located in the United States, the personal information on file may be processed and stored in the United States, and the United States governments, courts of law enforcement or regulatory agencies may be able to obtain disclosure of this information through the laws of the United States.
6. Financeit will destroy, erase or make anonymous any personal information no longer needed for its identified purposes or for legal requirements.
Principle 6: Keeping Personal Information Accurate
Financeit will keep the personal information in its possession or control as accurate, complete, current and relevant as possible, based on the most recent information available to Financeit.
Individuals may question the accuracy and completeness of personal information about them and have it amended as appropriate.
1. Financeit will make reasonable efforts to minimize the possibility of using inaccurate, incomplete or outdated personal information to make a decision about the individual.
2. Financeit will update personal information only if it is necessary for the purposes for which it was collected.
3. Financeit will make reasonable efforts to keep personal information in its possession and control accurate and current if the information is used on an ongoing basis, unless limits on the need for accuracy are clearly set out by Financeit.
4. Financeit will also rely on individuals to keep certain personal information relating to them accurate, complete and current. If an individual demonstrates to Financeit that personal information relating to them is inaccurate, incomplete, out of date or irrelevant, Financeit will revise or delete the personal information. If necessary, Financeit will disclose the revised personal information to third parties to whom Financeit disclosed wrong or outdated information in order to permit them to revise their records.
5. If Financeit does not agree to revise personal information as requested by the individual, the individual may challenge Financeit’s decision. Financeit will make a record of this challenge, and, if necessary, disclose the challenge by the individual to any third parties to whom Financeit has disclosed the personal information.
Principle 7: Safeguarding Personal Information
Financeit will protect personal information with safeguards appropriate to the sensitivity of the information.
1.Financeit will safeguard personal information in its possession or control from loss or theft and from unauthorized access, disclosure, duplication, use or modification.
2. The safeguards employed by Financeit to protect personal information will vary depending on the sensitivity, amount, distribution, format and storage of the personal information. Financeit stores much of your information electronically. Recent paper records containing individuals’ personal information are stored in files kept onsite at our Toronto head office or offsite though our secure data centre, and older records containing individuals’ personal information may be stored at an offsite storage facility. Financeit will give the highest level of protection to the most sensitive personal information.
3. Financeit will safeguard personal information in its possession or control through security measures. For example:
- physical security, such as secure locks on filing cabinets and restricted access to offices;
- organizational security, such as controlled entry in data centres and limited access to relevant information; and
- electronic security, such as passwords, personal identification numbers and encryption.
4. Financeit may disclose personal information to businesses such as credit bureaus, credit insurers and lenders with the individual’s consent. Financeit relies on the added protection of credit reporting legislation to ensure that credit bureaus protect personal information which is disclosed to them.
5. Financeit will use care when disposing of or destroying personal information in order to prevent unauthorized access to the information.
Principle 8: Making Information About Policies And Procedures Available To Individuals
3. Financeit may make information about its procedures available in a variety of ways, depending on the nature of the services individuals are using and the sensitivity of the personal information.
- Financeit may mail, or email information to its clients, establish a toll-free telephone service or provide online access.
Principle 9: Access To Personal Information
When an individual requests it, Financeit will advise what personal information Financeit has in its possession or control about the individual, what it is being used for and to whom it has been disclosed.
When an individual requests it, Financeit will give the individual access to personal information about them which is in the possession or control of Financeit. In certain exceptional situations Financeit may not be able to give individuals access to all of the personal information about them.
1. An individual has the right to know, on request, what personal information about the individual Financeit has in its possession or control, a right to access that personal information and to know to which third parties Financeit has disclosed that information. Individuals may direct their requests by telephone to the CSR or, in writing, to the Privacy Office.
2. Financeit has established procedures for responding to requests for access to personal information. Financeit will respond to requests within a reasonable period of time. Individuals must be specific about the personal information that may be in Financeit’s possession or control. In the unlikely event that Financeit determines that there will be a cost to the individual in granting such access, Financeit shall inform the individual of the costs permitted by law prior to granting such access.
3. Financeit will identify from whom it collected the personal information, to whom it has disclosed the personal information, and how and when the information was disclosed. Financeit will take this data from its records, and will provide it to the individual.
4. In some cases, Financeit may not provide access to personal information that is in its possession or control. For example, this may occur when:
- providing access to personal information would be likely to reveal personal information about a third party;
- providing the personal information could result in a threat to the security of another individual;
- disclosing the information would reveal confidential commercial information;
- the personal information is protected by solicitor-client privilege;
- the information is the result of arbitration or other formal dispute resolution process; or
- the information has been collected for the purposes of a legal investigation.
5. Financeit will not record in individual files when personal information was disclosed to third parties for routine purposes. For example:
regular updating of credit information to credit bureaus
indicating to third parties when payments are returned for NSF (not sufficient funds)
6. If Financeit denies the individual’s request for access to personal information, Financeit will advise the individual of the reason for the refusal. The individual may then appeal Financeit’s decision to the Privacy Commissioner of Canada.
Principle 10: Handling Individuals’ Complaints And Questions
1. Financeit has policies and procedures to receive, investigate, and respond to individuals’ complaints and questions relating to privacy. Individuals are advised to direct their complaints and questions by telephone to the CSR or in writing to the Privacy Office.
2. Financeit will investigate all complaints. If it finds a complaint justified, Financeit will attempt to resolve it. If necessary, Financeit will modify its policies and procedures to ensure that other individuals will not experience the same problem.
3. If individuals are not satisfied with the way Financeit has responded to their complaint, they can contact the Privacy Commissioner of Canada.
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