Privacy Statement

Accountability

We have appointed a Privacy Officer to oversee compliance with our privacy obligations and commitments. If you elect to contact our Privacy Officer, you may use one of the following methods;

What is Personal Information?

Personal information is any factual or subjective information, recorded or not, about an identifiable individual such as, but not limited to, your name, address, age, date of birth, marital status, income, social insurance number, other information of a personal nature such as ethnicity, religion or political affiliations, and any information about our relationship with you including account numbers and the status of your accounts.

What We Collect and How We Collect It

We collect personal information about you in order to:

• Confirm your identity;
• Determine your eligibility for our products and services;
• Set up your accounts and provide ongoing service;
• Meet legal and regulatory requirements; and
• Protect you from error and fraud.

The information we collect includes but is not limited to:

• Name and address;
• Identification documents;
• Credit and financial information such as your employment history, income sources, assets, liabilities, credit history, bank accounts, payment preferences and social insurance number; and
• Any additional information required in respect of a specific product or service that you have applied for.

This information may be obtained, with your consent:

• Directly from you by phone, in writing, application forms or email;
• From a broker or other intermediary acting on your behalf;
• From third parties such as credit agencies, your employer or others outside our organization; or
• May be generated directly by us in the process of setting up and servicing your account(s).

Consent

Haventree Bank will, in most instances, obtain your consent to collect, use or disclose personal information. The method to which the consent will be obtained will be applicable to the type of personal information being collected, used or disclosed. Haventree Bank will obtain your express consent (verbal, written or electronic) to collect, use or disclose personal information such as personal financial information.

Haventree Bank will rely on implied consent to collect, use or disclose your personal information in situations where you may reasonably expect us to require your personal information in order to provide services to you:

Haventree Bank shares information within our organization to manage our credit and business risks and operations, comply with legal or regulatory requirements, and service your account. We may release your information to third parties outside of Haventree Bank, such as regulators, and our suppliers and agents who assist us in serving you and who may be in Canada or other jurisdictions or countries and may disclose information in response to valid demands or requests. We do not sell or rent customer lists or personal information to others.

We endeavour to obtain your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Statement or separately), we will endeavour to advise you of that purpose before such use or disclosure.

Where we have obtained your personal information from third parties who have collected it in the course of performing a service for us or otherwise, we will take reasonable steps to ensure that such third parties have your consent to disclose your personal information to us.

We may collect information about you without your knowledge or consent where permitted or required to by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer in writing using the contact information above. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.

Use and Disclosure of your Personal Information

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including third parties that assist Haventree Bank in the provision of services to you and third parties whose services we use to conduct our business. As such, we, or our business partners, may send you product information that we believe may be of benefit to you. You may opt out of receiving this information at any time.

We may share your personal financial information with:

• Credit bureaus, credit reporting agencies, financial institutions and others to confirm your financial and employment status and your initial and ongoing eligibility for credit;
• Persons retained to administer or service your account for the purpose of such administration or servicing; and
• Other persons as necessary for the provision of credit services to you and the protection of any security interest in any loans we may have with you.

Further, your personal information may be disclosed

• As permitted or required by applicable law or regulatory requirements;
• To comply with valid legal processes such as search warrants, subpoenas or court orders;
• In order to administer or service your account or other credit product;
• To protect the rights and property of Haventree Bank;
• During emergency situations or where necessary to protect the safety of a person or group;
• Where the personal information is publicly available; and
• For any additional purposes for which we have obtained your consent.

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

Access to your Personal Information

Haventree Bank strives to keep your personal information accurate, up to date and relevant for its intended use. You can assist us by updating your personal information with us (e.g. change of address) as changes occur.

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Customer Service department, and if our Customer Service department is unable to help you, please contact our Privacy Officer in writing using the contact information above.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. We will respond to your request within 30 days.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

Updating your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please inform our Customer Service department using one of the following methods;

If our Customer Service department is unable to help you, please contact our Privacy Officer using the contact information above.

In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Security of Your Personal Information

Haventree Bank endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Haventree Bank will take every necessary step to ensure the protection of your personal information, including:

• Shredding of documents containing personal information;
• Physical security measures – restricted access to facilities and locked filing cabinets;
• Electronic security measures for computerized personal information – password protection, database encryption, personal identification numbers;
• Organizational processes and procedures including limiting access to your personal information to individuals on a need-to-know basis;
• Destroying, erasing or masking your information in accordance with our records retention policy; and
• Ensuring that third parties who are given access to your personal information protect and secure your personal information in similar manner.

Retention of Your Personal Information

Haventree Bank only retains your information for as long as necessary to fulfill the purpose for which it was originally collected or as required by law.

Respecting and Responding to Your Privacy Concerns/Complaints

Your privacy concerns matter to us. If you have any questions or concerns about your privacy rights or how we manage your personal information, please contact our Customer Service department using the contact information provided above.

We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If our Customer Service department is unable to help you, please contact our Privacy Officer using the contact information provided earlier. Please refer to our Privacy Complaint Procedures under “Contact Us” or follow this link: undefined/contact-us/complaints-handling/

If, after following these procedures, you remain dissatisfied with our response, you are entitled to make a written submission to the Privacy Commissioner of Canada using the following methods;

Information about our Website

Legal Disclaimers