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Privacy PolicyTable of Contents
Protecting Your Privacy is Important to Us! At TFG, we are dedicated to protecting your privacy and safeguarding your personal, business, and financial information. No matter how you choose to provide information to us, we use sound security safeguards and adhere to Ten Privacy Principles to ensure your personal and financial information is protected. You are invited to use this privacy site to learn more about personal information protection, about the types of information we collect and how it is used, and about the steps we are taking to ensure your personal and financial information is handled appropriately. Our Commitment to You We are committed to meeting or exceeding the privacy standards established by federal and provincial regulators. All of our information handling practices are designed to comply with federal and provincial laws including the federal Personal Information Protection and Electronic Documents Act, and the British Columbia Personal Information Protection Act. This legislation governs and regulates the collection, use and disclosure of personal information by organizations to ensure that it is handled responsibly. The Ten Privacy Principles The TFG Companies have always been and will continue to be, committed to maintaining the accuracy, confidentiality, and security of your personal and financial information. As part of this commitment, they have used the Ten Privacy Principles to govern their actions as they relate to the use of customer information. These principals have been built upon the values (commonly known as “Fair Information Practices”) which are internationally recognized as fundamental to the protection of personal privacy and are found in most privacy legislation around the world including Canadian Standards Association’s Model Code for the Protection of Personal Information, which was incorporated into Canada’s Personal Information Protection and Electronic Documents Act and BC’s Personal Information Protection Act. Principle 1 – Be Accountable Principle 2 – Identify the Purpose Principle 3 – Obtain Consent Principle 4 – Limit Collection Principle 5 – Limit Use, Disclosure and Retention Principle 6 – Be Accurate Principle 7 – Safeguard Customer Information Principle 8 – Be Open Principle 9 – Customer Access Principle 10 – Handling Customer Complaints and Suggestions
Principle 1 – Be Accountable Principle 2 – Identify the Purpose Principle 3 - Obtain Consent Principle 4 – Limit Collection Principle 5 – Limit Use, Disclosure and Retention Principle 6 – Be Accurate Principle 7 – Safeguard Customer Information Principle 8 – Be Open Principle 9 – Customer Access Principle 10 – Handling Customer Complaints and Suggestions Privacy Protection in Canada Personal Information Protection and Electronic Documents Act The Personal Information Protection and Electronic Documents Act, formerly referred to as Bill C-6, has a fundamental message that, subject to certain exceptions, personal information about an individual cannot be collected, used or disclosed by private sector organizations without that individual’s knowledge and consent. This law, as it’s name suggests, encompasses two primary objectives. The first objective is to establish rules that govern the collection, use and disclosure of personal information by private sector organizations. The second objective is to acknowledge the validity and legality of electronic documents. Personal Information Protection Act - BC In order to govern the commercial information-handling practices within provincial jurisdictions, each province has been encouraged to enact legislation that is substantially similar to the federal law. In October 2003, British Columbia enacted the Personal Information Protection Act, formerly referred to as Bill 38, which applies to commercial activity within BC. However, the Personal Information Protection and Electronic Documents Act will continue to regulate cross-border, inter-provincial and international trade and commerce. On January 1, 2004, both of these Acts require that most organizations regardless of their size, which collect, use or disclose personal information in the course of commercial activity, will become subject to the provisions of the Acts as applicable. For more information regarding this legislation, please visit the Privacy Commissioner of Canada website at http://www.privcom.gc.ca or the Corporate Privacy and Information Access Branch of the BC Ministry of Management Services website at http://www.mser.gov.bc.ca/foi_pop/index.htm What Information is Collected? The types of information we may ask for depends on the nature of your request. Information that is essential for fulfilling most financial requests and applications will include your basic contact information (name, mailing address, e-mail address, phone numbers), your Social Insurance Number, your bank information (branch and account) and your employment details. We may also request additional information to help us provide you with the financial service you have requested. When you visit the Travelers website, information is NOT collected that could identify you personally unless you choose to provide it voluntarily. All the information you provide to us is securely maintained and is kept strictly confidential. Types of Information We Collect At TFG, we collect two types of information from our clients. With your consent, we collect personal information. We may also collect anonymous/non-personal information. Personal Information Personal information is information that refers to you specifically. With your consent, we may gather personal information from you through our representatives or partners, in person, over the telephone or by corresponding with you via mail, fax or the Internet. The type of information we usually collect and maintain in your customer file may include:
For business customers, information may include:
The choice to provide us with personal and financial information is always yours. In financial dealings, however, your decision to withhold particular details may limit the services we are able to provide. If we are unable to accommodate your request based on the information that has been provided, we may ask for additional details. Anonymous/Non-Personal Information At TFG, we may collect anonymous/non-personal information. Anonymous/non-personal information is information that cannot be associated with or traced back to a specific individual or business entity. For example, anonymous/non-personal information is automatically collected by web servers when you visit websites, including Travelers website. The anonymous/non-personal information collected may be used for research and analytical purposes. For example, we are able to determine how many times our online privacy policy has been visited but we do not know any specific information about who the visitor is unless they consent to provide us with that information. To help us better understand our markets, we may also gather information for analytical purposes by extracting demographic information from existing files, from Statistics Canada, and from various industry publications. Information Required for Common Activities
Financial Services for Personal Use For personal financial services requests, such as a car lease or a loan for medical procedures, you will be asked to provide information such as your name, address and telephone number. We will also require that you provide us with permission to review your credit history. You will also be asked for specific information about your current financial situation. In order to conduct an accurate review of your financial situation we will ask for your employment status, social insurance number, and birth date and use that information only to assist in rendering our decision to provide you with credit for your financial requirements. Financial Services for a Proprietor For financial services requests from a Proprietor, such as a business car lease or a lease for business equipment, you will be asked to provide information such as your name, address and telephone number and your business name. We will also require that you provide us with permission to review your credit history. You will also be asked for specific information about your current financial situation and/or the financial situation of your business. In order to conduct an accurate review of your financial situation we will ask for your tax returns, social insurance number, and birth date and use that information only to assist in rendering our decision to provide you with credit for your financial requirements. Browsing TFG Web sites You may browse TFG Web sites anonymously and privately, even if you do not wish to interact with these sites or use online services. No personal or financial information will be collected from you without your knowledge and consent. Online transactions Personal clients may wish to logon to our website and complete our online consumer financial services application forms. It is always your choice to complete the personal information requested. Our system will prompt you to consent to our collection, use and disclosure of your personal information before you remit it to the TFG online application system. Travelers partners also have access to our online services, which only allows them to remit information collected to Travelers and also prompts a consent before remitting that information. No party visiting our website or using our online services has any access to your personal information remitted online, nor is there any access to our client information databases. Extended Financial Service Needs As your financial needs grow, you may wish to purchase insurance products for your equipment leased through Travelers. Travelers does have an arrangement with Sawka Insurance Group to provide a life and disability insurance product for your equipment leases. To facilitate your request for this product, we will need to ask for more detailed personal information from the proprietor or key-man, including health information. The choice is always yours whether you wish to provide this information. How Your Information is Used
Personal and Financial Information We use your personal and financial information to communicate with you, process applications and effectively provide the services you have requested. When you become a TFG customer, we make every effort to establish and maintain a positive relationship with you. To help us do this, we use the personal information you have provided to us to communicate with you and to safeguard your interests. We will keep you informed by sending you notices, and respond to any special needs or enquiries you may have. We only use personal information for the purpose that we have disclosed to you. If for any reason your information is required to fulfill a different purpose, we will notify you and ask you for your consent before we proceed. Transactional Information The majority of information we retain about you is in the form of transaction records that reflect your financial dealings with us. Anonymous/Non-Personal Information The anonymous/non-personal information gathered from TFG websites is used primarily for technical, research and analytical purposes like evaluating the various sections of these sites. This information does not include any personal or financial data and it is only retained until its intended purpose is fulfilled. When Information May be Disclosed to Outside Parties
When Authorized by You Credit agencies and other financial institutions routinely contact us for credit and financial information about clients. To comply with these requests, we require our client's consent. We usually obtain this permission in a Client Application Agreement, which a client signs when requesting a specific product or service. Client Application Agreement A Client Application Agreement is how we gather your personal information. It is used to define the product or service that you are requesting, collects personal information from you and assists us in rendering a decision to advance those products or services to you. (This form may have another name depending on which service you are requesting, but the content of the form will generally be as described herein and Client Application Agreement refers to any TFG application form). With respect to the matter of privacy, the Client Application Agreement authorizes us:
In most cases, your consent to use and/or disclose your information will be obtained in writing. In other cases such as when you apply for a product over the Internet, your consent will be obtained electronically. When Required by Law In some instances such as a legal proceeding or court order, we may be required to disclose certain information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so. When Permitted by Law There are some situations where we are legally permitted to disclose personal information such as employing reasonable and legal methods to collect a delinquent account, a medical emergency or suspicion of illegal activities. With Whom We May Share Your Information Travelers businesses, their employees and service suppliers, our Partners and Funding Partners are all governed by strict standards and policies to ensure your information is secure and treated with the utmost care and respect. At TFG, client information is strictly confidential. With your consent we share information with our Partners and Funding Partners, who perform services on our behalf, but only for the original purposes that the information was obtained for. Unless release is authorized by you or is permitted or required by law, we never sell or trade information about you or your accounts to other parties. Our Employees In the course of daily operations, access to private, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it. As a condition of their employment, all employees of TFG are required to abide by the privacy standards we have established. They are also required to work in an ethical manner and must follow all applicable laws and regulations. Employees are well informed about the importance of privacy and they are required to sign either a code of conduct or a confidentiality agreement that prohibits the disclosure of any client information to unauthorized individuals or parties. Unauthorized access to and/or disclosure of client information by an employee of TFG is strictly prohibited. All employees are expected to maintain the confidentiality of customer information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal. Our Partners At TFG, we have an extended network of service Partners. Our Partners offer Travelers financial services to facilitate your acquisition of their services or products. In order to do this, our Partners may be required to gather personal information on our behalf. All of our Partners and their employees are required to abide by our Privacy Policy when obtaining this information. Our Partners must execute a Privacy Protection Schedule as part of their contractual obligations with Travelers. This agreement defines their responsibilities for collecting, using and disclosing personal information in a manner that is consistent with the privacy policies and practices that we have established. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide. Our Funding Partners At Travelers we source funds from various financial institutions in order to get the most affordable financial services product to our customers. In order to facilitate this, we must share account details, including personal information, with our Funding Partners. Every time we obtain a credit application or contract agreement with our customer, this is disclosed to you and we obtain your consent. Travelers insists on protecting your privacy and has entered into privacy protection agreements with all of our Funding Partners to ensure your information is handled in a manner that is consistent with the privacy policies and practices that we have established. As well, our Funding Partners, being financial institutions themselves, are bound by federal and provincial privacy protection legislation and have similar privacy policies and procedures to that of Travelers. Our Service Providers Sometimes Travelers will contract outside organizations to perform specialized services such as market research or data processing. Our trusted service suppliers may at times be responsible for processing and handling some of the information we receive from you. When we contract our suppliers to provide specialized services, they are given only the information necessary to perform those services. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide. In fact, our suppliers are bound by strict contractual obligations that have been designed to protect the privacy and security of your information. Furthermore, as part of our contract agreements, our suppliers and their employees are required to protect your information in a manner that is consistent with the privacy policies and practices that we have established. Our Opt-Out Policy
How We Safeguard Your Information Client Files Electronic client files are kept in a secured environment with restricted access. Confidential Logins and Passwords are required for each user of the system. Paper-based files are stored either in locked filing cabinets or a locked filing room. Access is restricted. Information Security We make every effort to manage our server environment appropriately. Our firewall infrastructure is thorough and strictly adhered to. Our security practices are reviewed on a regular basis. We employ current technologies to ensure that the confidentiality and privacy of your information is not compromised. To safeguard against unauthorized access to our database, users are required to “sign-on” using a private login and a protected password to access certain secured areas of our database. Users are only given access to information that would be required to fulfill their employment duties. When you call our customer service representatives, we make every effort to confirm your identity before releasing any personal information, including providing your account number, providing some personally identifying information or last-call information or caller-ID. How You Can Protect Your Information Personal Information You should not share personal or financial information such as your Social Insurance Number or Travelers account number with others unless you clearly understand the purpose of their request and you know with whom you are dealing. Suspicious Solicitation From time to time, TFG will engage in promotional campaigns via telephone, mail and e-mail. If you are unsure of the information you receive from us, please call us at 1-877-293-0202 to verify that the campaign is a legitimate TFG activity. Accessing and Amending Your Information Accessing Your Information You may request access to your regular account or transactional information by sending your request in writing to Travelers. Should you have questions concerning a decision we have made, we will inform you of the reasons for those decisions upon your request and if we are permitted to do so by law. If for some reason, you are refused access to factual information held in your file, you may challenge this refusal by contacting our Privacy Officer. Amending Your Information To help us keep your personal information up-to-date, we encourage you to advise us of any inaccuracies or corrections as often as necessary. Where appropriate, we will make every effort to communicate these changes to other parties who may have unintentionally received incorrect information from us. To Make a Change To make a change to the personal contact information contained in your file, please call us at 1-877-293-0202 or send your request in writing. Questions, Concerns and Complaints If you have a concern or complaint about privacy, confidentiality or the information handling practices of your account with TFG, please write us with your request at: Travelers Financial Group Updating this Policy Any changes to our privacy policy and information handling practices shall be acknowledged in this policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of the privacy website. Companies Governed by this Privacy Policy
Web Sites Governed by this Privacy Policy Other Web sites TFG Web sites may contain links to other third party sites that are not governed by this privacy policy. Although we endeavor to only link to sites with high privacy standards, our privacy policy will no longer apply once you leave TFG websites. Additionally, we are not responsible for the privacy practices employed by other third party websites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed. This Privacy Policy Agreement was last Updated on October 20th, 2007.
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