Privacy Policy

We are accountable and open about our privacy principles

The Bank is responsible for all Personal Information under its control, including any Personal Information the Bank transfers to its third parties. The Bank has implemented measures to ensure it complies with the privacy principles outlined in this Privacy Policy, along with any other applicable privacy legislation, including:

1. implementing policies and procedures to protect Personal Information;
2. training its staff on the Bank’s privacy policies, procedures, practices, and obligations; and
3. designating one or more individuals within the Bank who are responsible to ensure the Bank complies with this Privacy Policy.

The Bank will make information about our policies and practices related to the management of Personal Information readily available. You may obtain such information with reasonable effort and/or without delay.

Information about our privacy policies and practices will be presented in clear and easy-to-understand language and will include:

• the contact information for the person(s) responsible for the Bank’s compliance with this Privacy Policy;
• the principles that govern our privacy practices;
• how to request access to your Personal Information; and
• how to complain to the Bank about any privacy-related issues or concerns.

Our Chief Privacy Officer is responsible to ensure the Bank complies with this Privacy Policy. Our Chief Privacy Officer may be contacted using the information provided in “How to Contact Us.”

We identify the purpose for collecting Personal Information

The Bank will identify its purpose(s) for the collection of Personal Information, before, or at the time of, collection, either orally, electronically, or in writing. Except where permitted by law, if a new purpose for using your information develops (i.e., one that is not previously made known to you or currently outlined in this Privacy Policy), we will notify you, obtain your consent and/or let you opt out before we use your Personal Information for such new purpose.

You may request more information about the purposes for which we collect Personal Information by contacting our Chief Privacy Officer using the information provided in “How to Contact Us.” For further information on how we use the Personal Information we collect, please refer to “How we use your Personal Information.”

We obtain appropriate consent for the collection, use, or disclosure of Personal Information

Except where permitted by law, the Bank is required to obtain your consent for its collection, use, or disclosure of Personal Information. For example, the Bank may disclose Personal Information without your consent or knowledge to co-operate with organizations, such as law enforcement or regulators, in the investigation of breaches of agreements or contraventions of laws, and where it is reasonable to expect that obtaining consent would compromise the investigation.

To determine the appropriate form of consent, the Bank will consider the sensitivity of the Personal Information and the reasonable expectations of its clients. Depending on the situation, sensitivity, and type of Personal Information involved, we may obtain your consent in different ways, including verbally, online, in writing, or through your use of the Bank’s products or services.

The Bank will not require you to consent to the collection, use or disclosure of Personal Information as a condition to obtaining a product or service beyond that required to fulfil the purposes identified to you.

Subject to any legal or contractual restrictions, you may withdraw consent at any time by providing the Bank with reasonable notice, and we will inform you of any implications of the withdrawal of consent. If you wish to withdraw your consent, please contact our Customer Service team using the information provided in “How to Contact Us” below.

We limit the collection of Personal Information

Personal Information will be collected by fair and lawful means. We limit the collection of Personal Information to that which is necessary for the purposes identified by us or permitted by law. These may include:

• details about you and your background, including your name, address, contact information, date of birth, occupation, and other identification;
• records that reflect your dealings with us; and
• financial information and credit records (including credit history).

We collect Personal Information primarily from you, however, we may, with appropriate consent, collect Personal Information from external sources including credit bureaus, employers, personal references, financial institutions, law enforcement, or other third parties who properly represent that they have the right to disclose information.

The Bank will collect and treat your Personal Information in accordance with applicable privacy legislation and any written agreement between you and the Bank.

We use Personal Information for disclosed purposes

Without your consent or when permitted by law, your Personal Information will not be used for purposes other than those for which it was collected.

In accordance with applicable privacy legislation and only to fulfil our business relationship, our use of your Personal Information may include to:

• verify your identify;
• assess initially and ongoing, your eligibility for credit and for the Bank’s products and services;
• transfer your Personal Information to a third party as permitted by any agreement between you and the Bank;
• confirm ownership or description of any collateral;
• service, monitor, or maintain your account, products, and services;
• report any account irregularities to any credit reporting agency or other institutions as required or permitted by law;
• help identify you with credit reporting agencies and other financial institutions to ensure the accuracy of information collected and reported for credit data-matching purposes;
• provide you with notices that serve the interests of customers of the Bank; and
• for any purpose related to the provision of products and services you request from the Bank.

We will share Personal Information for disclosed purposes

Personal Information will not be disclosed for purposes other than those for which it was collected, except when you have otherwise consented, or as required or permitted by law.

Circumstances in which the Bank will disclose your Personal Information only in accordance with applicable privacy legislation, may include:

• with your consent;
• in response to a court order, search warrant or other demand or request, which we believe to be valid;
• to meet requests for information from regulators, including self-regulatory organizations of which we are a member or participant;
• to satisfy legal and regulatory requirements applicable to us;
• to facilitate investigations by law enforcement, or disclosure to government agencies;
• to third parties the Bank has contracted with to perform services on our behalf, to manage our relationship with you;
• sharing it with credit reporting agencies, mortgage insurers, or other financial institutions to obtain credit bureau reports or verify your credit score;
• to help us collect a debt or enforce an obligation owed to us by you; and
• where permitted by law.

When we share Personal Information with third parties, we require them to protect the Personal Information in a way that is consistent with our privacy requirements.  Some of our service providers may store data outside of Canada. Personal Information held and controlled by a third party in another country may be subject to the laws of that jurisdiction, and may be collected, used, or disclosed without your knowledge or consent where required or permitted by the laws of that jurisdiction