ACCOUNTABILITY AND COMPLIANCE
Debt.ca is responsible for personal information under our control. We have established policies and procedures to effectively safeguard any confidential personal information that we have on file or which we collect, and to deal with complaints and inquiries. We are committed to maintaining the accuracy, confidentiality and security of your personal information, and we will ensure that you have access to information regarding the policies and procedures that we use to manage your personal information.
All questions or concerns regarding this Policy and our compliance with it should be directed in writing, and sent by email to firstname.lastname@example.org or by post to:
City Centre – Royal Bank Building
7th Floor 2010 – 11th Ave.
Regina SK, S4P 0J3
Every complaint regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user.
By using our website and services, you signify your agreement to the terms and conditions of this Policy and to our collection, use and disclosure of your personal information as set out herein. You may change or withdraw your consent to the collection, use or disclosure of your personal information at any time by contacting us in writing at either of the addresses listed above. In some circumstances, a change or withdrawal of consent may affect your ability to use our website or services.
COLLECTION OF INFORMATION
We collect personal information only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information). Personal information that is collected may include, but is not limited to:
- information provided by you during the application process, including your contact information (such as name, email address and telephone number), debt amount, credit rating range, homeowner status, property value, mortgage balance, postal code;
- information provided by third parties that we connect you with through the application process, such as debt companies, credit repair providers and financing entities, relating to your application and any resulting transactions that you are involved in; and
- information about your internet browsing activities and browser (see: Cookies and Web Beacons).
Subject to any legal or accounting requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected. Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media.
Users may visit our website without telling us who they are, or revealing any information about themselves. However, like many organizations’ websites, our web server automatically logs certain non-identifying information related to a user’s visit to the website, including the Internet Protocol (IP) address of the user’s computer, the user’s Internet service provider (ISP), the type and version of the browser that the user is using, the date and time the user accessed our website, the Internet address of the website from which the user linked directly to our site, the operating system that the user is using, and the pages of the website that the user has visited. We make no attempt to link this information with the identity of individuals visiting our website without express permission. We may, however, review server logs and anonymous traffic for system administration and security purposes, for example to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about website usage. The possibility therefore exists that server log data, which contains users’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals. In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches.
If you provide comments or other feedback to us, you agree that such comments or other feedback become the property of Debt.ca, and we may use and disclose them for any purpose provided that we do not associate them with your personally identifiable information.
COOKIES AND WEB BEACONS
A “cookie” is a small piece of information stored on your computer by a web page. It is used to identify you to the web server. It tells the server who you are when you return to a page on the same website. Your browser will only send a cookie back to the domain that originally sent it to you. A cookie cannot run any programs, deliver any viruses, or send back information about your system.
Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or to alert you when cookies are being sent. If you decline cookies, you will still be able to use our website and services, but your ability to access certain features and functions may be affected.
Some of our web pages contain an invisible electronic image known as a “web beacon.” Web beacons are similar in function to cookies, but allow websites on different domains to share information. We may use web beacons to transfer your subscription access information between our websites and domains. Web beacons do not transmit any personal information that we collect to any websites that are not owned by Debt.ca or its affiliates.
USE AND DISCLOSURE OF INFORMATION
We will identify the purposes for which we collect personal information before or when we request the information. We will not collect personal information which is not necessary and, except as specified below, will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected without first obtaining your consent. The information that we collect is used and disclosed only for business purposes. These include:
- to process, track and communicate with you about your application;
- to connect you with debt companies, credit repair providers or financing entities that may be able to assist you in reducing your debt payments;
- to establish, maintain and manage business relations with you so that we may provide you with the information, products or services that you request;
- internal business purposes, such as administering or improving our website or services;
- to perform market research and conduct polls and surveys;
- to provide you with information, solicitations and promotional materials regarding Debt.ca and our affiliates, and products or services offered by Debt.ca
- to sell or otherwise provide your personal information to our affiliates so that subject to your consent they may contact you about products or services directly or indirectly related to the debt industry, including debt relief companies, credit repair products and services, personal loan financing, and car financing;
- to protect us against error, fraud, theft or damage to our goods, our business or our property;
- to comply with any legal, accounting and regulatory requirements, including reporting requirements, applicable laws, and any search warrants, subpoenas or court orders; and
- any other reasonable purpose for which you provide consent.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government request or court order, or based on our good faith belief that it is necessary to do so in order to comply with such law, request or court order, or to protect our assets, the users of our website, or the public.
THIRD PARTY DISCLOSURE
We may disclose your personal information in response to requests from government agencies, law enforcement authorities and regulators, or to satisfy legal or regulatory requirements. We may also disclose your personal information when we buy a business or sell all or part of our business.
Subject to your opting out below, we may sell or otherwise provide your personal information to our affiliates and non-affiliated third parties, including debt companies, other wholesale lead providers and other persons or organizations that offer products or services directly or indirectly related to the debt industry, including debt relief companies, credit repair products and services, personal loan financing, and car financing. You acknowledge and agree that our affiliates and the non-affiliated third parties to whom we sell or provide your personal information may, in connection with the purpose for which the information was disclosed, conduct searches in relation to your personal information, including credit checks, or contact you to request additional information. We will use appropriate contractual or other means to require our affiliates and non-affiliated third parties to whom your personal information is disclosed to provide a comparable level of protection while the information is being used by them and to refrain from further disclosing your personal information without your consent, except as provided in this Policy.
You may opt out of receiving communications from us at any time by following the opt-out instructions in the email communication, by emailing us at email@example.com
You further acknowledge and agree that, in the course of our supply of services to you, we may delegate our authority to collect, access, use, and disseminate your information to third party subcontractors. Third party subcontractors may include web hosts, payment processors, delivery and logistics providers, social network integrators, and membership vendors. If we transfer any personal information to a third party subcontractor, we will provide the subcontractors only with the information needed to perform the subcontracted service, and will use appropriate contractual or other means to provide a comparable level of protection while the information is being used by them. However, you agree not to hold us liable for the actions of any third party subcontractor, even if we would normally be held vicariously liable for their actions, and understand that you must take legal action against them directly should they commit any tort or other actionable wrong against you.
SECURITY AND ACCURACY OF INFORMATION
We have implemented reasonable physical, organizational, contractual and technological security measures to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive personal information. We use user IDs, passwords, and encryption technology, maintain our servers and paper files in locked premises, and restrict the employees and contractors who have access to personal information to those having a “need to know” and who are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner. When destroying personal information, we delete electronically stored personal information and shred any tangible materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.
We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. Therefore, by accessing our website, using our services and/or communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization.
Debt.ca has a responsibility to ensure that all personal information contained in our records or which is disclosed to third parties for the purposes described above is accurate, complete and up-to-date. You may make a request in writing for access to your personal information. We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed. You may have reasonable access to your personal information, and if you demonstrate the inaccuracy or incompleteness of personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data, if your personal information changes, or if you wish to have your information removed from our files. All notices and requests should be in writing and sent to one of the addresses set out above.
INTERNATIONAL TRANSFER AND STORAGE OF INFORMATION
You acknowledge and agree that your personal information may be transmitted, transferred, processed, and/or stored outside of Canada, including in the United States. We will use reasonable means to ensure that your information is protected, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada. By submitting your personal information to us, you consent to the transmission, transfer, processing and/or storage of your personal information outside of Canada.
THIRD PARTY LINKS
Our website may contain optional links to advertiser and other third party Internet sites and services. You acknowledge that these third parties may collect data from users or their computers. The accessing and use of third party websites is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites. This Policy applies only to the Debt.ca website, and we encourage you to review the privacy policies contained on each Internet site that you use.
Minors (persons under the age of 18, although the age of majority may vary in other jurisdictions) are not eligible to use the website or services unsupervised, and we request that minors do not submit any personal information to us. If you are under the age of majority in your jurisdiction, you may only use the website or services in conjunction with and under the supervision of an adult. Debt.ca does not knowingly collect personal information from minors.
You agree that your access to and use of the Debt.ca website, including this Policy, and services is governed exclusively by the laws of the Province of Saskatchewan and the federal laws of Canada applicable therein (excluding conflicts or choice of laws principles).
CREDIT REPORT NOTICE