Privacy policy

V.9/10/17

At Flexiti Financial, we are committed to providing you with exceptional service. Providing this service involves the collection, use, and disclosure of some of your personal information, and protecting this information is one of our highest priorities.

We will inform you of why and how we collect, use, and disclose your personal information and obtain your consent where required.

Flexiti Financial’s privacy policy outlines the principles and practices we will follow in collecting and protecting your personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of your personal information as well as allowing you to request access to, and correction of, your personal information.

Scope of this Policy
This policy applies to all of Flexiti Financial’s business activities and to the following websites (individually referred to as ‘Website’, or collectively as ‘Websites’):

This policy also applies to any third parties, such as merchant partners and service providers, collecting, using, or disclosing personal information on behalf of Flexiti Financial.

This policy applies to information about Flexiti Financial customers. This policy does not apply to information about merchant partners who carry on business as corporations, partnerships, or other forms of association. Flexiti Financial does, however, protect the confidentiality of such information in accordance with the law and Flexiti Financial’s own policies. This policy does apply to personal information of individual owners of sole proprietorships, and the personal information of merchant partner guarantors, principals, owners, directors, and officers (collectively, ‘merchant partners’).

Amendments to this Policy
Flexiti Financial may amend this policy from time to time. If we make any substantial changes to this policy and the way in which we use your personal data, we will post these changes on this page and do our best to notify you of any significant changes. Please review our Privacy Policy on a regular basis. By continuing to maintain your Account with Flexiti Financial, you agree to abide by any changes made to this policy.

Accountability
Flexiti Financial is accountable for all personal information in its possession or control, including any personal information transferred to third parties for processing. Flexiti Financial has established policies and procedures to comply with this Privacy Policy and has designated a privacy officer to be accountable for compliance.

Collecting Personal Information – Collection, Purpose, and Use
In order to provide you with financial products and services, we may collect the following information from you:

  • Name
  • Address
  • Telephone number
  • Email address
  • Date of birth
  • Gender
  • Mother’s maiden name
  • Social Insurance Number (optional)
  • Credit card number (optional)
  • Information from your driver’s licence or other government identification (identification number, issuing locale, and expiry date)
  • Employment and income details
  • Credit information (such as credit history, payment history and Account details pertaining to other credit accounts you have, payment history and details pertaining to your Flexiti credit Account, and all other personal information that affects credit that has been provided to you or that you have applied for)
  • Banking information (merchant partners only)
  • Language preference
  • Interests and hobbies

We collect information about you from:

  • Information you provide us on applications and online forms
  • Information you provide in the course of doing business with us
  • Information from credit reporting agencies and/or credit bureaus
  • Information collected by cookies when you visit our website

Flexiti Financial may use the personal information collected to:

  • Verify identity
  • Verify creditworthiness
  • Understand your financial, insurance, and warranty needs
  • Open and manage the Account
  • Assign or sell your Account, or amounts owing under your Account to a third party, including a third party located outside of Canada
  • Deliver requested products and services
  • Enrol a customer or merchant partner in a program
  • Provide credit reporting agencies and/or credit bureaus with information about you and your Account, which is used by them in determining your credit rating
  • Anticipate and resolve problems with any products or services supplied
  • Better tailor and improve the features of products and services
  • Create products or services that may meet your needs
  • Prevent fraud
  • Promote Flexiti Financial’s products and services, or products and services provided by partners of Flexiti Financial
  • Ensure a high standard of service to our customers or merchant partners
  • Meet regulatory requirements

The following departments may have access to the information that will be collected and used for the aforementioned reasons: Operations, Customer Service, Credit Risk, Analytics, Information Technology, Fraud, and Product.

Purposes of Collecting Personal Information
Flexiti may use the personal information we collect to:

  • Make decisions about applications, including verifying the applicant’s identity
  • In the case of a Social Insurance Number (provision of which is always optional), to match credit bureau files
  • Evaluate creditworthiness and monitor, service, and collect accounts
  • Allow credit reporting agencies and credit bureaus to obtain information about you and your Account
  • Respond to inquiries about applications, accounts or other services
  • Meet legal, security, processing, and regulatory requirements, including Canadian federal and provincial requirements and foreign requirements applicable to us or any of our service providers
  • Prevent or investigate potential or actual fraud
  • Understand customer or merchant partner needs and to offer products and services to meet those needs
  • Allow our partners to promote their products and services to you (We will not assist our partners in promoting products and services to you where we reasonably determine that they are inappropriate for you or do not meet your needs.)
  • Improve and tailor our Website to better meet your needs and coincide with your interests
  • Use for such other purposes as we disclose in this policy or that we identify to you from time to time or as permitted by law

Consent
We will obtain your consent to collect, use, or disclose personal information (except where, as noted below, we are authorized to do so without consent).

Consent can be provided explicitly, through electronic, oral, or written means, or through an authorized representative. Consent can also be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and you voluntarily provide personal information for that purpose, such as by using or maintaining one of our products or services or by not responding to our offer to remove your personal information from our marketing list, in which case we assume that you consent.

Subject to certain exceptions (e.g. the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), you can withhold or withdraw your consent for Flexiti Financial to use your personal information in certain ways, as long as you give reasonable notice of withdrawal. You must contact us to advise us that you wish to withdraw your consent. Flexiti Financial’s contact information can be found on this Website or in your welcome package. Your decision to withhold or withdraw your consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation in order to assist you in making your decision.

We may collect, use, or disclose personal information without your knowledge or consent:

  • When the collection, use, or disclosure of personal information is permitted or required by law
  • In an emergency that threatens an individual’s life, health, or personal security
  • When the personal information is available from a public source (e.g., a telephone directory)
  • When we require legal advice from a lawyer
  • For the purposes of collecting a debt
  • To protect ourselves from fraud
  • To investigate an anticipated breach of an agreement or a contravention of law
  • When it is reasonable to expect that the collection, use, or disclosure of the personal information with the consent of the customer or merchant partner would compromise the availability or the accuracy of the personal information and the collection is reasonable for an investigation or a proceeding.

Your telephone conversations with our representatives will be monitored and/or recorded for quality control, internal training, and record-keeping purposes. As well, please remember that we, and the third parties with whom we share your personal information in accordance with this policy, may contact you by email, telephone, or in writing, using the email address, telephone number, or address information you have provided to us.

Using and Disclosing Personal Information
We will only use or disclose your personal information where necessary to fulfill the purposes identified at the time of collection.

We will not use or disclose your personal information for any additional purpose unless we obtain your consent to do so. We will not sell customer lists or your personal information to other parties unless we have consent to do so.

Retaining Personal Information
We will retain your personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

If personal information has been used to make a decision about an individual, Flexiti Financial will keep the personal information long enough for you to have access to it after the decision has been made.

Flexiti Financial will destroy, erase, or make anonymous any personal information no longer needed for its identified purposes or for legal requirements.

Collection, Disclosure, Use, Transfer, and Retention of Personal Information Outside of Canada
In some cases, personal information that we manage may be transferred, processed, and stored outside Canada, including in the United States of America (“U.S.”), and therefore may be available to government authorities under lawful orders and laws applicable there.

For Flexiti Financial to provide and administer the services we offer to you, the information you provide to us is transferred, used, disclosed, and stored by our service providers in the U.S. for the same purposes as enumerated above. Service providers in the U.S. may also collect your personal information in order to provide you with customer service in connection with your Account. Information collected, transferred, disclosed, used, or stored in the U.S. is subject to the laws of that jurisdiction. The laws of the foreign jurisdiction may be different and less protective than those of Canada.

By way of example, your information will be transferred, stored, or disclosed in the U.S. if any of our servers are from time to time located in the U.S. or one of our service providers is located in the U.S. Your personal information may be used or collected in the U.S. if our call centre is located in the U.S. and you call us regarding your Account.

Flexiti Financial has taken steps to ensure that your personal information in a foreign jurisdiction continues to be protected to the same degree as it is in Canada. Flexiti Financial will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures that are, at a minimum, equivalent to those employed by Flexiti Financial.

To obtain more information about our practices and policies concerning the collection, transfer, or use of your personal information to the U.S. and those of our service providers, please contact Flexiti Financial’s privacy officer at the address below.

Ensuring Accuracy of Personal Information
Flexiti Financial will make reasonable efforts to ensure that your personal information is accurate and complete where it may be used to make a decision about you or disclosed to another organization.

You may request correction to your personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made by telephone or in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be made by contacting Flexiti Financial. Our contact information can be found on our Website or in your welcome package.

If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the file.

Securing Personal Information
We are committed to ensuring the security of your personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks.

Flexiti Financial stores much of your information electronically. Flexiti Financial protects personal information with safeguards appropriate to the sensitivity of the information. In the event that you provide us with your Social Insurance Number or credit card number, those numbers are stored using database encryption. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. Your information may be stored outside of Canada, including in the U.S.

If a password is used to protect your Account and personal information, it is your responsibility to keep your password confidential.

We also have organizational processes in place to limit access to your personal information by Flexiti Financial Personnel, third parties, partners, and service providers collecting, using, or disclosing personal information on behalf of Flexiti Financial. Electronic information will be destroyed using appropriate security measures when no longer required.

Using appropriate security measures, hard copies of personal information will be stored and destroyed when no longer required for the purposes stated herein.

We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Access to Personal Information
You have a right to access your personal information, subject to limited exceptions.

To request access to personal information, do so electronically and provide sufficient detail to identify the personal information being sought. Forward such request to access personal information to the privacy officer.

Upon request, we will tell you how we use your personal information and to whom it has been disclosed, if applicable.

A fee may be charged for providing access to personal information. Where a fee may apply, we will inform you of the cost and request further direction from you on whether or not we should proceed with the request.

If a request is refused in full or in part, we will notify you in writing, providing the reasons for refusal and the recourse available to you.

Questions and Complaints
The privacy officer is responsible for ensuring Flexiti Financial’s compliance with this policy and all applicable federal and provincial privacy legislation.

You may direct any complaints, concerns, or questions regarding Flexiti Financial’s compliance in writing to the privacy officer. If the privacy officer cannot resolve the concern, you may also write to the Privacy Commissioner of Canada, the Commission d’accès à l’information in Québec, or the provincial Privacy Commissioner in British Columbia or Alberta.

Contact information for Flexiti Financial’s privacy officer:

Flexiti Financial
Attention: Privacy Officer
100 University Avenue, Suite 1000
Toronto, ON M5J 1V6
privacy@flexitifinancial.com

Collection of Personal Information Through Our Websites
When visitors visit a Flexiti Financial Website, anonymous, non-personal information about their visit is automatically collected. Such information may include the length and date of the visit, how the visitor navigated the Website, what pages the visitor viewed, the type of browser being used by the visitor, the type of operating system used by the visitor, and the domain name of the visitor’s Internet Service Provider. When visitors visit a Flexiti Financial Website, certain pieces of personal information are also automatically collected. Such information consists of the gender, age, and personal interests of the visitor. Flexiti Financial uses this information to track the success of its Website with its visitors and to better tailor the Website to visitors’ needs and interests.

Cookie-based Information
Flexiti Financial may use cookies on its Websites. “Cookies” are pieces of information that a website transfers to a visitor’s hard drive for record keeping and identification purposes. We use cookies to make the visitor’s use of a website easier by saving visitor preferences and passwords. They are also used to identify which areas of the Website are popular, which areas need improvement and how to target certain advertising to our Website visitors. Cookies contain information, including personal information that can later be read by a web server in the domain that issued the cookie to you. Flexiti Financial does not use cookies to collect personally identifiable information except for your age, gender, and interests, and in connection with password-protected online services. We may combine your visit and navigational information with personal information that you provide. By visiting a Flexiti Financial website, you are consenting to this collection and use of your personal information. Visitors may visit the Website with its cookies turned off to avoid the collection of cookie-based information; however, by turning off cookies, you will be unable to access the password-protected areas of the Website, including the Customer Portal and Merchant Partner Portal.