Privacy Policy | BridgePoint Financial Services Inc.

Privacy Policy (Website)

BridgePoint Financial Services Limited Partnership I and BridgePoint Financial Services Inc. (collectively, "the Company", "we", "us", or "our"), is committed to protecting the personal information of our employees, investors and customers from improper collection, use and disclosure. We are also committed to upholding the privacy commitments of our investors and business partners with regard to the personal information of others that they may make available to us.

This policy ("policy") establishes requirements and responsibilities for the appropriate collection, use and disclosure of personal information. The policy adheres to the privacy principles as set out in the Personal Information Protection and Electronic Documents Act ("PIPEDA") and other applicable legislation.

WHAT IS PERSONAL INFORMATION?

Personal information includes information about an identifiable individual, presented in any form. This may include but is not limited to information such as a person's age, name, address, gender, financial records, opinions, evaluations, and identification numbers including file number(s) and social insurance number.

It does not include the name, job titles, and business address or telephone number of an employee of an organization or personal information that can be found through publicly available information.

Personal information does not include information that has been anonymized so that it does not identify a specific user.

YOUR CONSENT

Your personal information may be collected, used and disclosed by the Company through your filling out of our forms or otherwise providing information in order to obtain products and services from us or our partners and affiliates. By filling out the forms or otherwise providing information, either yourself or on behalf of another individual, or by using our website and our products and services, you consent to the collection, use and disclosure of your personal information and, where applicable, the personal information of another individual in accordance with the terms and conditions of this policy.

Personal information collected by the Company will be used or disclosed for various purposes, including but not limited to:

the purpose for which it was originally collected;
required to be disclosed by law;
to deliver and provide products and services that you obtained from the Company;
to understand your needs and make customized information available regarding other products and services offered by the Company;
to evaluate and/or assist the partners and affiliates of the Company with respect to your eligibility for other products and services offered by the partners and affiliates of the Company;
to perform analytics, administer surveys, or request feedback to improve and manage our relationship with you, and
to confirm or authenticate your identity and ensure that your information is correct and current.

We also collect information from third-party agencies to manage credit and business risks; collect an outstanding debt; detect, prevent, manage, and investigate fraud or other unauthorized or illegal activity.

By providing your personal information to us, you have agreed to its collection, use and disclosure as described here within our privacy policy.

In certain circumstances we may ask for your express consent which may be provided in writing, electronically (by clicking a button or checking a box), email, facsimile, or orally over the telephone when speaking to our employees or agents.

You may withdraw your consent at any time subject to any legal/contractual restrictions and reasonable notice by contacting us at the contact information below. However, by providing limited personal information we may not be able to provide you with certain products and services that are contingent on providing such information.

WHAT PERSONAL INFORMATION DO WE COLLECT?

The personal information we collect is primarily provided by you. We also collect your information from third parties that demonstrate that they have the right to disclose such information to us or where you have provided consent to such disclosure. When you inquire or apply for our products and services, we may collect certain information. The information collected may include (but is not limited to) your name, mailing address, email address, phone number, driver's license number, date of birth, medical records, and other information that is critical in providing our services.

WHAT DO WE DO WITH YOUR PERSONAL INFORMATION?

We only collect the information necessary to provide our products. The more we know about you, the better we are able to serve your needs.

The personal information provided to us (including our affiliates, contractors, agents, investors, and lenders) in connection with providing our products may be collected and/or disclosed by us for the purposes of:

evaluating your application for eligibility of the products and services we offer;
establishing and maintaining communication with employees, investors, business partners, and customers;
complying with legal and where applicable, regulatory requirements;
conducting quality assurance audits and compiling of statistics;
detecting and preventing fraud;
retaining a service provider or other agent, such as a credit reporting agency, for account management, the collection of debt owed by you to the Company;
using a service provider or third party that is performing administrative functions for the Company to manage its products and services; responding a person who, in the Company’s reasonable judgement, is seeking the information as your agent;
any other use and disclosure authorized by you; and
as otherwise set out in this privacy policy.

In the event that your personal information is to be used or disclosed for any new purposes, we will notify you prior (if required by law) to its use or disclosure and obtain your consent if required.

We will not sell or rent any of your personal information to third parties for their marketing purposes and only share your personal information with third parties that are described in this policy.

We may also de-identify, aggregate or anonymize information about our customers to identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products, services or offers. Such information may also be shared with third parties for other analytical purposes, but will not personally identify any individual and therefore is not subject to our privacy policy.

In some cases, laws and regulations outside of Canada may be applicable for instances where we may process, disclose or store your personal information outside of Canada. Under such circumstances, we may be lawfully required to disclose your personal information to government authorities under a lawful order or applicable law within that jurisdiction.

SAFEGUARDING YOUR PERSONAL INFORMATION

Our safeguards are designed and maintained in order to protect your personal information, regardless of the format it is in. We ensure that your personal information is protected against theft or loss, unauthorized access, use, copying, modification, disclosure or disposal. Our current measures of protection include (but are not limited to):

physical measures including restricted access to premises;
organizational measures including training of employees, internal limitations on accessibility of information;
internal password and security policies;
confidentiality agreements with any third parties we engage with;
technological measures including the use of firewalls and encryption of data; and
investigative measures should we determine that a privacy breach has occurred as a result of inappropriate collection, use, or disclosure of personal information.

PRIVACY AND OUR WEBSITE

In general, we do not collect any of your personal information that can identify you when browsing our website. However, certain non-personal information such as an IP address, cookies, Internet tags and navigational data may be collected. The non-personal information collected is used to improve the content of our website and to enhance the user experience.

The only personal information collected from our website would be the personal information you voluntarily provide so that we may contact you regarding our services that you have inquired about.

ACCESSING, VERIFYING AND UPDATING YOUR PERSONAL INFORMATION

Since we use your personal information to provide you with great service, it is important that your information be kept accurate, complete and up-to-date. If any of your personal information changes please be sure to notify us so that we can make the necessary changes. We may also obtain updated personal information from any other third party that has your consent to share such information with us.

You may request to see any personal information we hold about you (please see contact information below). In rare cases you may be denied access to your personal information if;

there is a legal requirement that requires it be held by authorized law;
the access to your information jeopardizes the personal information of others;
it harms the Company's rights and property; or
the request is frivolous or vexatious.

In a situation where you are denied access to your personal information, we will advise of the reason in writing.

CHANGES TO OUR PRIVACY POLICY

We constantly review and update all of our policies and procedures including our privacy policy which may change from time to time to ensure that your personal information is always respected and protected. We will not give any notice as to when these changes occur. Any changes to our policy will be posted to our website.

Please monitor this privacy policy to ensure you are familiar with its most updated version.

COMMUNICATING WITH US

If you have any questions regarding our Privacy Policy or practices, or would like access to the personal information we have about you, please contact our Privacy Officer who can be reached by:

BridgePoint Financial Services Limited Partnership I and BridgePoint Financial Services Inc. – Privacy Officer

133 Richmond Street West, Suite 201

Toronto, ON

M5H 2L3

Phone – 1-888-800-4966

Email – inquiries@bpfin.com

Our Privacy Officer has the decision making authority to resolve most issues. If you are unhappy with how your privacy concerns have been addressed you may contact the Office of the Privacy Commission of Canada at http://www.priv.gc.ca/index_e.asp.

Last updated: January 1, 2018