Your Privacy Is Protected
At CA Lending®, an important part of our commitment to you is respect for your right to privacy when applying for a car loan. Keeping your information and affairs in strict confidence is a cornerstone of our business and an integral part of our commitment to service excellence. This policy will help you better understand how CA Lending® protects, collects, uses and discloses your personal information and your right to access your information. This policy applies to CA Lending®‘s clients (including potential clients) in Canada. To understand the meaning of “personal information” and other terms used throughout this policy, please refer to the Important Terms section.
Important Terms Used in This Policy
When reading this policy you should be aware of the meanings we give to the following terms.
When we refer to “personal information” or “information” it means information about an identifiable individual. This includes details such as your age, marital status, education, employment history, identification numbers, financial information and credit records. Personal information does not include most of the information that appears on a business card.
When we refer to “CA Lending®”, “we”, “our” or “us” or “CALC” it means the “CANADIAN AUTOMOTIVE LENDING CORPORATION” and each of its subsidiaries that offer loans, or other products and services.
When we refer to “you” and “your” it includes co-applicants, guarantors, or personal or authorized representatives.
When we refer to “permitted or required by law”, and “legal and regulatory” requirements, authority or restrictions, this includes law, regulation, rules or requests of the regulators or self-regulatory organizations which apply to CA Lending®.
At CA Lending®, keeping your information and affairs in strict confidence is an integral part of our commitment to you.
Our Privacy Principles
CA Lending® respects the following principles when collecting, using, disclosing and protecting your personal information.
I. Identifying Purposes and Obtaining Your Consent
We identify the purposes for collecting personal information at or before the time it is collected. We obtain your consent before collecting, using or disclosing personal information, except where permitted or required by law.
II. Limiting the Collection, Use and Disclosure of Your Information
We limit the personal information we collect to what is necessary for the purposes we have identified. We collect information only by fair and lawful means. We do not use or disclose personal information for purposes other than those for which it was collected, except with your consent, or where permitted or required by law. We retain personal information only as long as necessary for these purposes.
III. Keeping Your Information Accurate and Providing Access to Your Information
We take care to keep personal information as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Upon request, we provide you with access to your personal information. You can ask how your information is used or disclosed, can ensure it is accurate and complete, and can update it if necessary.
IV. Protecting Your Information
We safeguard the privacy of personal information through security measures appropriate to the sensitivity of the information. We are responsible for personal information under our control. There are designated individuals within CA Lending® who are accountable for compliance with these privacy principles. We make available to you, information about our policies and practices related to managing your personal information. We address your concerns. We have steps you can follow if you have questions or concerns about your privacy.
Identifying Purposes and Obtaining Your Consent (Section I.)
We identify why we collect personal information and how we use it
We collect, use and disclose personal information about you throughout our relationship so we can:
(a) establish your identity
(b) protect you and us from error and fraud
(c) understand your needs and eligibility for products and services
(d) recommend particular products and services to meet your needs
(e) provide ongoing service
(f) comply with legal and regulatory requirements
If we need your information for any other purpose, we will identify that purpose. We obtain most of your personal information directly from you and through the products and services you use. Some information may be obtained from other sources. For example, with your consent, we may verify some of the information you give us with your employer or your references. Generally, when we obtain information from someone other than you, such as a credit bureau, we record the source of that information. We may review and analyze your applications, transactions and other personal information. We may do this to offer solutions that help meet your needs, and to develop new products and strategies to meet the needs of our clients. We may also do this to help us identify various types of risks such as credit, fraud, and money laundering.
We may monitor and record telephone calls
We may monitor and record telephone calls between you and our representatives to ensure accuracy, security, service quality and for training purposes.
Your information is collected, used or disclosed with your consent
When you apply for a product or service, we tell you about this policy and will obtain your consent. Depending on the product or service, this allows us to:
(a) check your employment
(b) obtain a credit report and exchange information with a credit bureau
(c) offer you other products and services
(d) send you information about products and services by means of direct marketing
If you have a product or service where ownership or liability is shared with others (for example, you have a joint account or you have a guarantor for your loan), we may share your information with them in connection with the product or service. Also, if you authorize us, we may provide your information to your lawyer, accountant, or others you’ve identified. Except as explained in “There are exceptions to obtaining consent” under Part II. of this policy, we don’t disclose information about you to anyone outside of CA Lending® without your consent. Similarly, if we intend to use your information for a purpose we didn’t tell you about previously, we will obtain your consent.
There are many ways we may obtain your consent
CA Lending® may obtain your express consent in writing, through electronic means, or verbally. Alternatively, your consent may be implied through an action you’ve taken or when you continue to use a product or service after we’ve notified you of a change. In some cases, we are required by law to obtain your express consent, in which case we ensure that we do so.
Examples of express consent:
Written – You may sign an application that states “I agree to the Terms on the reverse.”
Electronic – You may be asked to electronically acknowledge that you will be bound by legal terms. Clicking “Submit” is your electronic consent.
Verbal – A CA Lending® representative asks whether you agree to us obtaining your credit bureau information. Saying you agree is your verbal consent.
Common consents and your options
There are several common consents that may apply in your relationship with us. They are described below to help you understand when you can refuse or withdraw your consent and when this right is limited. Refusing or withdrawing your consent will generally not affect your eligibility for CA Lending® offers. However, if you refuse or withdraw your consent, we may not be able to provide you with a particular product or service. We’ll explain the impact on you at the time, to help you with your decision.
You can choose not to receive direct marketing
From time to time, we may offer you products and services – including special promotions – that we believe will be of interest to you through various channels including direct mail, telephone, electronically or other means. This consent is optional and you can decide to withdraw it at any time. If you withdraw your consent to receive direct marketing, this will not limit the information provided to you through discussions with a CA Lending® representative or information we may send you that is permitted or required by law or related to your existing products or services.
We share information within CA Lending®
We may share information about you within CA Lending® for legal and regulatory purposes, to manage credit risk and other business risks, to perform analytics, and to ensure we have correct and up to date information about you, such as your current address, date of birth, etc. You may not withdraw consent for this sharing.
We ask for your consent before using your Social Insurance Number
When we receive information from or update your information with a credit bureau, your SIN is the best way to make sure that the information actually refers to you. Wrong information could lead us to draw wrong conclusions about you. You should be aware, though, that permitting us to use your SIN in this way is voluntary for you. If you choose not to give us your SIN when its collection is optional, or tell us you do not want us to use it for credit bureau purposes, this by itself will not prevent you from getting any products or services.
We may exchange information with credit bureaus
When you apply for certain products and services, we obtain your consent to exchange information about you with credit bureaus. In order to maintain the integrity of the credit reporting system, we may periodically update your information with credit bureaus as long as you have the product or service with us and for a period of time afterwards. Your consent to the exchange of information cannot be withdrawn during that time.
Limiting the Collection, Use and Disclosure of Your Information (Section II.)
We limit the personal information we collect
While we collect various types of personal information from you and other sources, we limit the information to what is necessary for the purposes we’ve identified. The information we ask for depends on the product or service requested. As well, we may need to ask new questions because of changes in legal and regulatory requirements.
Types of personal information we collect
Here are some examples of information we are required to collect to provide our products and services:
“Know your client” information:
We require information to meet our various “know your client” legal and regulatory requirements. For example, we need your name, address, birth date, occupation, citizenship and identification for many products and services to meet anti-money laundering requirements. We may also be required to ask for information on how you use our products or services.
We require financial information to assess your eligibility for products and services, and to assess credit and other limits. Financial information may include account records, tax returns, financial statements, employment income and credit information.
Social Insurance Number (SIN):
We may be required to collect and disclose your SIN to comply with legal or regulatory requirements. Further, if you have provided your SIN it may also be used as an internal identification number to accurately identify customers having the same or similar names.
Using, disclosing and retaining your personal information
We do not use or disclose personal information for purposes other than those for which it was collected, except with your consent, or as described below. We retain personal information only as long as necessary for these purposes.
There are exceptions to obtaining consent.
There are exceptions where we may collect, use or disclose information without consent:
If we use an outside supplier to do work for us.
At times we may use outside suppliers to do work for us involving some of your information. For example, we may use suppliers to print statements, conduct telemarketing, collect accounts or process transactions on our behalf. We select suppliers carefully and insist they have privacy and security standards that meet CA Lending®‘s strict requirements.
If we are permitted or required by law.
We may be compelled to release information by a court or other legal or regulatory authority. If so, our policy is to release information only to the extent that we are required to do so. We may also collect, use or disclose information without consent where permitted by law. For example, we may collect and use publicly available information like information in the telephone book for marketing or customer service purposes. Further, for legal, medical or security reasons, it may be impossible or impractical for us to obtain your consent.
If we have to protect the interests of CA Lending®.
In certain circumstances, CA Lending® may have to collect, use or release information without consent for its protection. For example, we may do so when collecting an overdue account, when realizing on security pledged for a loan, or to detect or prevent fraud. If we cannot locate you, we may obtain contact information from other sources, such as government agencies and registries, and public records.
We may share information for business transactions.
From time to time, we may sell parts of our business, insure, sell or securitize assets, or merge or amalgamate parts of our business with other parties. Since client and account information will normally be a part of the transaction, we may disclose this information to other parties in the transaction, as part of due diligence and on completion of the transaction. We require that the other parties keep this information confidential and limit its use to the purposes of the transaction.
Information may be located outside of Canada.
CA Lending®, its outside suppliers and other third parties to whom we disclose information under this policy (such as credit bureaus) may perform activities outside of Canada. As a result, your information may be securely 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 these countries.
We retain your information
The length of time we keep your information will vary depending on the product or service and the nature of the personal information. We have retention standards that meet customer service, legal and regulatory needs. For these reasons, we may keep your information beyond the end of your relationship with us. When your information is no longer required, we securely destroy it or delete personally identifiable information.
Keeping Your Information Accurate and Providing Access to Your Information (Section III.)
We work with you to keep your information accurate
We take care to keep the information in our records as accurate, complete and up to date as necessary for the purposes for which it is used. However, we also rely on you to tell us when your personal information changes. It is important to ensure your personal information at CA Lending® is accurate and complete. This allows us to continue to offer the highest quality service and to suggest products and services that best meet your needs.
To update your address and other personal information:
Contact the office where your account is held talk to your CA Lending® representative.
You can access your information
Your personal information is available to you through by visiting the office you deal with. If you require further information, please request this by contacting the office you deal with. We will ask that you put your access request in writing (usually, by completing a form) and that you provide us with enough specific details in order to help us understand your request and conduct our search for your information. We will need you to verify your identity before searching for or providing you with access to your information. We will respond to your access request within 30 days upon receiving all necessary information, or advise you in writing if we require additional time. We may charge a fee to provide access to your information. We will let you know in advance if there is a charge. If you have a sensory disability you may request your information to be made available in an alternative format. If we already have that format, we will provide it. Otherwise we will convert the information into the requested format if it is reasonable and necessary under legislation to enable access.
There may be limits on your right to access your information
It may not be appropriate for us to release certain types of information to you. For example, our records may contain information about other clients, information that is confidential or proprietary to CA Lending®, or information that is subject to legal privilege. Because we must protect everyone’s confidentiality and legal rights, we cannot make this information available to you. However, where possible, we will suppress this information and provide you with access to the remaining records. If we are unable to provide access or disclose information to you, we will explain why, subject to any legal or regulatory restrictions.
Your information and other parties
If we have obtained information about you from others, you can ask us for the source of that information. On request, and where legally permitted, we’ll provide you with the names of outside companies or organizations to whom we’ve given or may have given your personal information. However, this won’t include outside suppliers we’ve used to do work for us, such as conducting telemarketing, or processing information for us. This also won’t include reports to the Canada Revenue Agency, or information that has been provided for legal or regulatory reasons.
You can have your information corrected
If you tell us that we have information about you that is obsolete or incorrect, we will update our records with the proper information. When appropriate, we’ll correct any information which we may have given to an outside organization.
Accessing and correcting credit reports
If you request access to a credit report we obtained about you from a credit bureau, we will give you a copy if we still have it on file. We will provide you with the name and address of the credit bureau we used. They will have the most current information and they can provide you with information on how to read the report. You have the right to access and correct the credit report directly with the credit bureau.
Protecting Your Information (Section IV.)
How we protect your information
We limit access to your personal information and store it securely. Depending on the nature of the information, it may be stored in the office you deal with, in various secure computer systems, or the record storage facilities of CA Lending® or our outside suppliers. In addition to the physical and electronic security devices we use to protect your information, we have security standards to protect our computer systems and your information from unauthorized use or access. Our systems also protect your information when it is electronically transmitted. We regularly audit our information security procedures and assess that they remain effective and appropriate. Employees who have access to your information are made aware of how to keep it confidential. Each employee must sign an agreement stating that maintaining confidentiality is a condition of employment with CA Lending®. Also, each year employees undergo a review of our Code of Conduct and certify they will abide by CA Lending®‘s ethical and professional standards including the obligation of confidentiality and privacy. We use contracts and other measures with our outside suppliers to maintain the confidentiality and security of your personal information and to prevent it from being used for any unauthorized purpose. Access to your personal information is only given to those who require it to provide our products or services, or where permitted or required by law.
Ensure your contact information is up-to-date
Making sure that CA Lending® has your most up-to-date address or contact information will help protect your personal information from being misdirected. In “We work with you to keep your information accurate” under Part III. of this policy, we explain how to check and update your personal information.
Protect your privacy online
To protect your privacy online, you should clear your browser’s cache after each session, use a firewall, and use up to date software to protect your computer from viruses and spyware.
Reduce your risk of identity theft:
Shred documents that contain personal or financial information before you throw them out request a copy of your credit bureau report periodically visit www.safecanada.ca and look for more identity theft information under the “Financial Safety” section don’t give out personal information over the phone unless you have initiated the call or know who you are dealing with
If you receive a suspicious phone call, e-mail or letter, contact us.
If you think someone is impersonating CA Lending®, or believe you have been the victim of a fraud or attempted fraud through telephone, mail or e-mail, call CA Lending® at 1.855.888.LEND (5363) or e-mail firstname.lastname@example.org