Haventree Bank (Haventree Bank) is committed to maintaining the accuracy, confidentiality and security of your personal information. We value the trust you have placed in us and wish to provide assurance that nothing is more important to us than the security and appropriate use of your personal information.
This Policy Statement is designed to inform you of the policies and practices we have put in place to manage your personal information. We encourage you to read this Statement so that you can better understand how we collect, use, share and protect your personal information.
P.O. Box 1160, Station TD
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;
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).
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 where one (or more) of the following apply:
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;
Mortgage Servicing Department
P.O. Box 22248, Bankers Hall
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: www.haventreebank.com/privacy-statement/.
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;
Office of the Privacy Commissioner of Canada (OPCC)
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3
Information about our Website
www.haventreebank.com gathers information about visitors who are not personally identified. This information includes the type of internet browser and operating system you are using, IP (Internet Protocol) addresses and other related information such as page requests and average time spent on our website. Please note the information will only be gathered while the visitor is on the site. No information is gathered about other third-party sites the visitor has accessed. The information collected is analyzed to help us understand trends and patterns, and to improve the content, design and user experience of www.haventreebank.com.
In certain sections of the site, Haventree Bank may invite you to contact us, request information or complete a registration form. In these cases, we request contact and other related information. If you choose to provide this information, we will use it only to contact you as requested, or to register you to access certain sections of our website or for specified events.
Cookies: Our website uses a technology called “cookies”. A cookie is a tiny element of data that our website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. You may set your web browser to notify you when you receive a cookie. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all of the features of our website.
Tracer Tags & Web Beacons: Some areas of the www.haventreebank.com website may also use “web beacon” technologies. Web beacons work in conjunction with cookies and let us know what portions of our site are of interest to our visitors and to help us provide you with tailored information from our website. If you turn off cookies, web beacon technologies will still detect anonymous visits, but the notices they generate cannot be associated with other information that is collected and are disregarded.
Customer Testimonials/Case Studies/Reviews: We post customer testimonials/comments/reviews on our website, which may contain information about the customer. We obtain each customer’s consent via email prior to posting the customer name and testimonial.
This Privacy Statement does not create or confer upon any individual any rights, or impose upon Haventree Bank any obligations outside of, or in addition to, any obligations imposed by Canada’s federal privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Disclosure and Canada’s federal privacy laws, this Statement shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.