Our Privacy Philosophy
This Policy explains how we collect, use, disclose and safeguard the personal information that you or a third party provide to us. Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to Fionic’s collection, use and disclosure of your personal information in accordance with this Policy.
For the purposes of this Policy, “personal information” means information that can identify an individual directly or through other reasonably available means. The meaning of “personal information” shall be interpreted in a manner that conforms with the minimum requirements of applicable privacy legislation.
Our Privacy Principles
Identifying Purposes and Obtaining Your Consent
We identify the purposes for collecting your personal information at or before the time it is collected. We will not collect, use or disclose your personal information without your consent, unless we are required or permitted to do so by law.
We collect, use and disclose personal information about you so we can:
Identify the customer
Understand customers credit needs
Evaluate eligibility for products and services including credit
Deliver products and services
Refine and improve our current products and services
Develop new products and services
Protect our customers and Fionic against error, fraud, theft and damage
Comply with legal and regulatory requirements
We will also use your personal information to communicate with you. If we require your information to fulfill a purpose that is not identified in the Policy then we will first obtain your consent.
Limiting the Collection, Use and Disclosure of Your Personal Information
We collect personal information by fair and lawful means and limit collection of that information to what is necessary for the purposes identified in this Policy. The types of personal information that we collect from time to time include:
contact information that allows us to communicate with or contact you (e.g., address, telephone number, e-mail or other electronic address, social media account name and fax number)
identity information that allows us to identify you or to meet tax, anti-money laundering and other "know your client" legal and regulatory obligations (e.g., name, Social Insurance Number (SIN), date of birth, occupation, and government-issued identification)
financial information that allows us to determine creditworthiness or eligibility for or appropriateness of products or services (e.g., employment and financial history with others, income, net worth, credit reports, and details of security provided for loans)
transactional information about how you use different products or services or otherwise do business with us (e.g., purchase and payment history)
relationship information that helps us to understand more about you including how you like to do business and what types of products, services or offers you may like (e.g. language and communication preferences, location, demographics and interests)
The choice to provide us with your personal information, either directly or through a third party, is always yours. However, your decision to withhold particular information may limit our ability to provide you with some of our products or services.
Personal information may be collected in a number of ways, including: in person, over the phone, by mail, by fax, over the internet, and from third parties who you have authorized to disclose personal information to us.
We make every reasonable effort to ensure that those third parties that disclose your personal information to us have first obtained your consent. If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.
Your personal information will only be used or disclosed in accordance with the purposes for which it was collected, unless you have otherwise consented or where required or permitted by law.
The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose your personal information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the disclosure request have legitimate grounds to do so.
Your personal information may be disclosed in situations where we are legally permitted to do so, such as in the course of employing reasonable and legal methods to enforce your rights, our rights or to investigate suspicion of unlawful activities. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property and safety of ourselves and others.
You also understand and agree that we may use your personal information and disclose your personal information to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing an actual or proposed transaction. These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing personal information as part of concluding a sale or transfer of assets. Our successors and assignors may collect, use and disclose your personal information solely for the purposes set out in this Policy (subject to any rights you may have to withdraw your consent). In the event the transaction does not go through, we will require, by contract, the other party or parties to the transaction not to use or disclose your personal information in any manner whatsoever for any purpose, and to return or permanently destroy such personal information.
Reasonably Foreseeable Consequences
When a lender requests to review your credit report as part of a loan application process, the request can impact your credit score.
Safeguarding Your Personal Information
Access to private, sensitive and confidential information, including your personal information, is restricted to authorized employees with legitimate business reasons.
We require all of our employees to abide by Fionic’s privacy standards. Our employees understand the importance of keeping your information private and secure. For this reason, our employees are required to agree to a code of conduct that prohibits the disclosure of any customer information to unauthorized parties. Employees are strictly prohibited from accessing or disclosing personal information without authorization. All employees are expected to maintain the confidentiality of personal information at all times and failure to do so will result in appropriate disciplinary measures including dismissal. Employees receive regular training regarding data security issues.
Further, we employ security safeguards that are on par with relevant industry standards. Our server environment and firewall infrastructure are well maintained and our security practices are reviewed on a regular basis.
We keep electronic customer files in a secured environment with restricted access. Paper-based files are stored in locked filing cabinets to which access is also restricted.
Identifying Purposes and Obtaining Your Consent
Except as otherwise permitted or required by law, your personal information will be retained for so long as is reasonably necessary to fulfil the purposes for which it was collected.
Access to Records
Upon request, a Fionic customer shall be informed of the existence, use and disclosure of their information and shall be given access to it. Customers may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate. We will amend, as necessary, upon notice from another organization updates to customer personal information. Fionic will correct a customer’s information under our custody and control within a reasonable time frame.
Organizations are authorized under the Privacy Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is protected by legal privilege or contained in mediation records.
If we refuse a request in whole or in part, Fionic will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information by way of redaction or omission and provide the remainder of the record.
We will respond to access requests within 30 calendar days unless meeting this time limit would unreasonably interfere with our operations or if the time required to undertake any consultations necessary to respond to the request would make the time limit impracticable to meet. Please direct all questions or enquiries about this Policy by email to firstname.lastname@example.org or by mail to 100 Lombard Street, Suite 201, Toronto, ON M5C 1M3.
Rights to Withdraw Consent, Be Forgotten, and Challenge Compliance
Please note that you have the right to withdraw consent, to request that your data be removed from our systems, and to challenge Fionic’s compliance in the event that you believe that the organization has impinged on your rights.
To do so, please direct all requests of this nature to email@example.com.
This Policy and all related matters are governed by the laws of the province of Ontario and the applicable federal laws of Canada.