OUR PRIVACY PHILOSOPHY
This Policy explains how we collect, use, disclose and safeguard the personal information that you or a third party provide. Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to CCC’s collection, use and disclosure of your personal information in accordance with this Policy.
For the purposes of this Policy, “personal information” means information that can identify an individual directly or through other reasonably available means. The meaning of “personal information” shall be interpreted in a manner that conforms with the minimum requirements of applicable privacy legislation.
OUR PRIVACY PRINCIPLES
Identifying Purposes and Obtaining Your Consent
We identify the purposes for collecting your personal information at or before the time it is collected. We will not collect, use or disclose your personal information without your consent, unless we are required or permitted to do so by law.
- We collect, use and disclose personal information about you so we can:
- respond to your application
- provide financing to you by determining your financial situation through collection of credit and related financial information from our affiliates, strategic partners, credit agencies, other financial institutions and from references you provide
- facilitate the financing by sharing your information with our third party service providers, financial institutions, funders, credit agencies and similar parties connected to our financing offering
- for the collection and servicing of the financing provided to you
- investigate potentially fraudulent or questionable activities regarding your application to us or financing provided to you
- report under any applicable rules or regulations to regulators, financial institutions or other related entities
- offer you related products and services that might be of interest to you
We will also use your personal information to communicate with you. If we require your information to fulfill a purpose that is not identified in this Policy we will obtain your consent,
Limiting the Collection, Use and Disclosure of Your Personal Information
The information we collect
We collect personal information by fair and lawful means and limit collection to that information which is necessary for the purposes identified in this Policy. The types of personal information that we collect from time to time include:
Contact information that allows us to communicate with or contact you (e.g., address, telephone number, e-mail or other electronic address, social media account name and fax number).
Identity information that allows us to identify you or to meet tax, anti-money laundering and other "know your client" legal and regulatory obligations (e.g., name, Social Insurance Number (SIN), date of birth, occupation, and government-issued identification).
Financial information that allows us to determine creditworthiness or eligibility for or appropriateness of products or services (e.g., employment and financial history with others, income, net worth, credit reports, and details of security provided for loans).
Transactional information about how you use different products or services or otherwise do business with us (e.g., purchase and payment history).
Relationship information that helps us to understand more about you including how you like to do business and what types of products, services or offers you may like (e.g., language and communication preferences, location, demographics and interests).
The choice to provide us with your personal information, either directly or through a third party, is always yours. However, your decision to withhold particular information may limit our ability to provide you with some of our products or services.
How your information is collected
Personal information may be collected in a number of ways, including: in person, over the phone, by mail, by fax, over the Internet, and from third parties who you have authorized to disclose personal information to us.
We make every reasonable effort to ensure that those third parties that disclose your personal information to us have first obtained your consent. If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.
Your personal information will only be used or disclosed in accordance with the purposes for which it was collected, unless you have otherwise consented or except where required or permitted by law.
We may monitor and record telephone calls
For the purpose of obtaining consent and maintaining quality service, our telephone calls with you may be recorded.
Disclosure to third parties
The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose your personal information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the disclosure request have legitimate grounds to do so.
Your personal information may be disclosed in situations where we are legally permitted to do so, such as in the course of employing reasonable and legal methods to enforce your rights, our rights or to investigate suspicion of unlawful activities. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property and safety of ourselves and others.
You also understand and agree that we may use your personal information and disclose your personal information to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing an actual or proposed transaction. These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing personal information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use and disclose your personal information for substantially the same purposes as those set out in this Policy. In the event the transaction does not go through, we will require, by contract, the other party or parties to the transaction not to use or disclose your personal information in any manner whatsoever for any purpose, and to return or destroy such personal information.
Protecting Your Personal Information
Access to your information within CCC
Access to private, sensitive and confidential information, including your personal information, is restricted to authorized employees with legitimate business reasons. For example, when responding to customer enquiries, employees will need to access your information to verify your identity and to properly assist you.
We require all of our employees to abide by CCC’s privacy standards. Our employees understand the importance of keeping your information private. For this reason, our employees are required to agree to a code of conduct that prohibits the disclosure of any customer information to unauthorized parties. Employees are strictly prohibited from accessing or disclosing personal information without authorization. All employees are expected to maintain the confidentiality of personal information at all times and failure to do so will result in appropriate disciplinary measures including dismissal.
Disposal and Retention
Except as otherwise permitted or required by law, your personal information will be retained for so long as is reasonably necessary to fulfil the purposes for which it was collected.
Safeguarding your information
To ensure that your personal information is protected, we employ security safeguards that are on par with industry standards. We use modern technologies to ensure that your confidential information is not compromised. Our server environment and firewall infrastructure are well-maintained and our security practices are reviewed on a regular basis.
We keep electronic customer files in a highly-secured environment with restricted access. Paper-based files are stored in locked filing cabinets to which access is also restricted. When you call our customer service centre, you will be required to verify your identity.
We use Secure Socket Layer (“SSL”) and 128-bit encryption technologies to enhance security for the secured areas of our website. SSL protects and maintains the security of messages transmitted over the Internet. SSL scrambles your data into an unreadable format, preventing unauthorized access by others.
Addressing Your Inquiries and Concerns
We are happy to provide you with a copy of this Policy and to discuss any of its content with you.
Upon request, we will also inform you of: the type of personal information we have collected; how your personal information has been used; and any third parties to whom your personal information has been disclosed.
Please direct all questions or enquiries about this Policy to the attention or our Privacy Officer by email at email@example.com or by mail at PO Box 980, Station A, Toronto, ON M5W 1G5
Any changes to our privacy standards and information handling practices will be reflected in this Policy in a timely manner. CCC reserves the right to change, modify, add, or remove portions of this Policy at any time. Please check this page periodically for any modifications. To determine when this Policy was last updated, please refer to the modification date at the bottom of this Policy.
Our website at www.consumercapitalcanada.ca is governed by the provisions and practices stated in this Policy. Our website may contain links to third party sites that are not governed by this Policy. Although we endeavour to only link to sites that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our website and that we are not responsible for the privacy practices of third party sites. We therefore suggest that you closely examine the respective privacy policies of third party websites to learn how they collect, use and disclose your personal information.
This Policy and all related matters are governed solely by the laws of the province of Ontario and the applicable federal laws of Canada.
CCC may perform activities outside of Canada through third parties. You acknowledge and agree that, as a result, your personal information may be processed, used, stored or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.
Last revised June 28, 2018