PRIVACY POLICY AND GUIDELINES
PURPOSE:
The purpose of this Privacy Policy is to help employees and customers understand the procedures that we have implemented regarding the collection, storage, use, disclosure, protection, and accuracy of personal information that we collect and control. This Privacy Policy balances a customers’ right to privacy with our need to collect, use, and/or disclose the information for legitimate business purposes.
This Privacy Policy is current as of the “last revised” date set out on the last page of this document. We will continue to review this privacy policy to ensure that it is relevant and remains current with changing laws, regulations, and technologies, and the evolving needs of our customers.
RATIONALE:
Getautocreditnow.ca has a commitment to integrity, and one way to live up to this commitment is to be responsible for the protection and fair handling of personal information at all times and in dealing with third parties. Our care in collecting, using, and disclosing personal information is essential to continued customer and employee confidence and goodwill.
Getautocreditnow.ca is respectful of the Personal Information Protection & Electronics Documents Act, otherwise known as PIPEDA.
DEFINITIONS:
Personal Information—including health and financial information—is any information relating to an identified or identifiable individual that is controlled or managed by businesses or organizations engaged in commercial activities.
Personal information includes:
• age, name, ID numbers, income, ethnic origin, or blood type;
• opinions, evaluations, comments, social status, or disciplinary actions;
• employee files, credit records, loan records, medical records, existence
of a dispute between a consumer and a merchant, intentions (for
example, to acquire goods or services, to change jobs)
Personal information excludes:
• name, title, business, address, and telephone number of an employee
of an organization.
Commercial activities are any particular transaction, act, or conduct or any regular course of conduct that is of a commercial character.
Collection is the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means.
Consent is voluntary agreement with what is being done or proposed. Consent may either be implied or express.
Express consent is given in an explicit manner, either verbally or in writing.
Implied consent arises in situations where consent may be reasonably inferred by the action or inaction of the individual.
Disclosure is making personal information available to other persons outside of getautofinance.com.
GUIDELINES:
Under PIPEDA, there are 10 principles, which our organization follows:
1. Accountability
2. Identify Purposes
3. Knowledge and Consent
4. Limiting Collection
5. Limiting Use, Disclosure, and Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging Compliance
Accountability—
All employees are responsible for personal information under their control.
Our Senior Team is accountable and responsible for compliance with this Privacy Policy.
We have designated individuals as “Privacy Officers” for getautocreditnow.ca. It is the Privacy Officers responsibility to ensure that only necessary personal information is being collected and that it is not being used or disclosed to others in ways that the individual has not consented to. The Privacy Officers will also be responsible for dealing with any customer inquiries and complaints relating to personal information.
Identify Purposes—
We identify the purpose or purposes for which personal information is collected at, or before, the time the personal information is collected. For example, we shall collect personal information for the following reasons:
• to identify and communicate with individuals who are interested in
receiving information about getautocreditnow.ca services
and other marketing purposes;
• to comply with government regulations and legal requirements,
including recall notifications;
• to operate the web-site getautocreditnow.ca;
• to provide information regarding special events and promotions; and
• for other reasonable business purposes, which we believe may be of
interest, or of benefit, to our customers.
Knowledge and Consent—
We obtain the consent of our customers or employees concerning the collection, use, or disclosure of personal information. We make reasonable efforts to ensure that customers and employees understand how personal information will be used and disclosed.
The adequacy of the form of consent will depend upon the circumstances and the type of information that is being collected. Generally, the more sensitive the information (banking, health, etc) the more explicit the consent that is required.
Limiting Collection—
We limit the collection of personal information to that which is necessary for the purposes identified.
Limiting Use, Disclosure, and Retention—
We do not use or disclose any personal information for purposes other than those for which it is collected, except with additional consent or as required by law.
We do not sell any personal information provided by our customers.
We retain personal information only as long as it is necessary for the fulfillment of the stated purposes.
Personal information that is no longer required to fulfill the identified purposes is destroyed, erased, or made anonymous.
Employees of working with the web-site getautocreditnow.ca with access to personal information shall only be those whose function and responsibility specifically includes the handling of such personal information. The right of access is restricted according to the nature and scope of the individual function and responsibility.
Accuracy—
We use our best efforts to maintain personal information as accurately, completely, and up-to-date as necessary for the purposes for which we have received consent.
Customers and employees are responsible for informing us about changes to personal information that is necessary to fulfill the identified purposes, such as, but not limited to, if a customer or employee’s name or address have changed, if a customer has died, if the customer changes employer, or if a proceeding in bankruptcy, receivership, or insolvency is started by the customer or against the customer, or a garnishee is levied against the wages of an employee.
Safeguards—
We protect personal information by security safeguards appropriate to the sensitivity of the information.
We protect personal information (regardless of the format in which it is held) against loss or theft, unauthorized access, disclosure, copying, use, or modification, through appropriate safeguards.
The methods of protection we use to protect personal information include:
a) physical measures, for example, locked filing cabinets and restricted
access to offices;
b) organizational measures, for example, staff training,
security clearances, and limited access on a need-to-know basis; and
c) technological measures, for example, the use of passwords,
encryption, firewalls, anonymizing software.
Each employee is responsible for the use of information within their job function, and
our employees are aware of the importance of maintaining security and confidentiality of personal information.
We dispose and destroy personal information with care in order to prevent unauthorized parties from gaining access to the information.
Openness—
We make specific information about our policies and practices relating to the management of personal information readily available to customers and employees.
Individual Access—
Upon written request, we give customers and employees access to their personal information holdings and an account of their use and disclosure. A customer or employee is entitled to challenge the accuracy and completeness of personal information and to have it amended as appropriate. Where a customer informs us that they require assistance in making such a written request, we will provide the customer with assistance. We may require a customer to provide sufficient information to permit us to respond to his or her request, but such information shall only be used or disclosed for this purpose. We will supply the information in a form that is generally understandable.
We respond to a customer’s request for personal information not later than 30 days after receipt of a written request. More than 30 days may be required when:
a) responding within 30 days would unreasonably interfere with our
activities;
b) the time required to undertake any consultations necessary to
respond to the request would make the 30 days impractical to meet; or
c) additional time is required in order to convert the personal information
into an alternative format, which has been requested by the customer.
We respond to each such request:
a) at no cost to the customer for access; or
b) at a minimal cost to the customer for access where we provide the
customer with an estimate of the approximate cost within the 30 day
period. Upon receipt of the estimate, the customer must advise us
within the 30 day period that he or she wishes to continue with the
request, otherwise we will deem the request withdrawn.
When an individual successfully demonstrates inaccuracies or incompleteness of information that getautocreditnow.ca holds, getautocreditnow.ca will amend the information as required. Depending on the nature of the challenge, amendment could involve the correction, deletion, or addition of information. When appropriate, the amended information will be transmitted to third parties.
Challenging Compliance—
Our customers, prospects, and employees can challenge our organization’s compliance with the privacy principles to the Privacy Commissioner of Canada.
We have procedures in place to receive and respond to customer or employee challenges or complaints about the handling of his or her personal information or this Privacy Policy and our practices relating to this policy.
1. Customers or employees who have further inquiries regarding his or
her personal information, or who wish to address a challenge regarding
our compliance with this Privacy Policy, may contact one of our Privacy
Officers in writing at the address listed below:
Privacy Officer, getautocreditnow.ca, PO Box 1300, St. Catharines,
ON L2R 7A7
2. We will inform customers who make inquiries or who lodge complaints
of the existence of relevant complaint procedures, and we will
investigate all written complaints. If we find a complaint to be justified,
we will take all appropriate measures, including, if necessary, amending
our policies and practices.
CHANGES:
From time to time, getautocreditnow.ca may make changes to this policy to adapt to changing business conditions and for other reasons. In the event that such changes will allow getautocreditnow.ca to make materially greater use and/or disclosure of any personal information, the individuals affected by the changes will be clearly and concisely notified of the changes and their proposed effect and will be provided with an opportunity to withdraw their consent to the collection, use and/or disclosure of their personal information.
QUESTIONS:
If you have any questions about our Privacy Policy, you may contact our Privacy Officer at 1-866-353-5786
Getautocreditnow.ca Privacy Policy, Last revised October 2007.
Kaitlyn & Ryan G., St. Catharines