Privacy Statement
This Policy was last updated on March 8, 2023.
This is Consolidated Credit Counselling Services of Canada Inc.’s (“Consolidated Credit”) privacy policy (this “Policy”). This Policy explains Consolidated Credit’s policies for the collection, use and disclosure of personal information. Consolidated Credit abides by applicable privacy legislation, including, but not limited to the Personal Information Production and Electronic Documents Act, as amended from time to time.
For purposes herein, “personal information” means information about an identifiable individual.
THE INFORMATION WE COLLECT
Consolidated Credit offers consumer credit counselling services.
The types of personal information we may collect include: name and contact information, date of birth, language preference, credit information, debt information, income and financial information, as well as social media user identification names. In addition, we may collect certain information such as cookies, IP addresses, web beacons, or other information that cannot be used to directly identify an individual but may still be used to identify the individual when combined with other information which may be available in the public records. We may record calls to or from our staff for purposes of accuracy, performance reviews and training.
HOW WE COLLECT INFORMATION
Consolidated Credit collects information by various methods including information actively provided by its clients, and (with consent) credit checks and information arising from our credit counselling services.
HOW WE USE THIS INFORMATION
The personal information we collect is only used to provide our services to our clients. The client’s contact information may also be used for other internal purposes such as sending Consolidated Credit’s newsletters, updates, announcements and other information or to better serve our clients.
Consolidated Credit may use aggregated or anonymous information which will not be linked to identified individuals for various other uses for itself and third parties.
WHO WE SHARE THIS INFORMATION WITH
Consolidated Credit does not share personal information with third parties except as required to provide or improve our services. The nature of our services requires Consolidated Credit to disclose personal information to creditors. Consolidated Credit may provide personal information to its consultants, subcontractors and professional advisers or other third-parties (each of which shall be bound by privacy obligations) to assist Consolidated Credit’s uses disclosed herein. If Consolidated Credit refers a client to a third party for advice or services Consolidated Credit does not provide, it will share that client’s personal information with the third party after the client agrees to use such services.
Consolidated Credit will disclose personal information without an individual’s knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of an individual’s personal information. If we receive a request from a police officer or other law enforcement agency for access to your personal information in the course of an actual or potential investigation, our policy is to require the police officer or law enforcement agency to obtain an order, subpoena or warrant, unless the information is urgently required to prevent serious bodily injury or serious damage to personal property. If we receive a written request from a police officer or other law enforcement agency with authority to request access to your personal information in the course of an actual or potential investigation into a breach of a law, our policy is to provide the requested information.
Consolidated Credit may disclose personal information to another entity purchasing (including for diligence purposes prior to purchase) the assets of Consolidated Credit, provided that entity abides by this Policy or a similar privacy policy.
SECURITY
Personal information is stored in a combination of paper and electronic files. These files are protected by security measures appropriate to the nature of the information. Client data on Consolidated Credit’s network is encrypted in transit and all data is encrypted at rest. Backups are run at least once per day and all backups are encrypted, air gapped and zero trust.
You will be promptly notified in writing in the event of theft, loss, unauthorized use or release of your non-public personal information.
ACCESSING INFORMATION
Individuals may review their personal information contained in Consolidated Credit’s files by contacting the Consolidated Credit privacy officer at the email address provided at the end of this Policy. If an individual believes that any of their personal information is inaccurate, we will make appropriate corrections.
OPT-OUT POLICY, YOUR NEWSLETTER AND EMAIL SUBSCRIPTIONS
You can opt-out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. Client service-related communications are an integral part of the services you receive from us and you may continue to receive such service-related emails unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided. You may also opt-out of receiving our newsletter or marketing emails by contacting us at the unsubscribe email or by replying to an existing email with your request to be removed from the mailing list or click here.
COOKIES AND YOUR AD CHOICES: INTEREST-BASED ADVERTISING
Our website uses small pixel files (small images) and cookies (small text files) to keep track of your browser so that you will be recognized when you visit other websites where our third-party ad management providers may show you advertisements from us based on your visit to our website. Some of these advertisements may be customized to particular products and services that you viewed, or they may be based on inferences about products and services that you might be interested in. This is called "interest-based advertising".
These pixel files and cookies are generally valid for a limited number of days (usually no more than 90 days) and are provided by our ad management providers. We require our ad management providers to participate in the Digital Advertising Alliance of Canada's Ad Choices Program. Visit the Digital Advertising Alliance of Canada: Your AdChoices website (http://www.youradchoices.ca) where you can find out more information about digital advertising and how you can opt-out of interest-based advertising. You can also opt-out of interest-based advertising using the link provided in any of our interest-based advertisements. Look for the Ad Choices icon or other link provided.
Please note that if you opt-out of interest-based advertising you may still see advertisements from us on other websites. However, they will not be customized based on your browsing history on our website. In addition, we will continue to customize our offers of products and services to you when you are on our website unless you block cookies from our website. If you block cookies on our website, certain functions, such as the "shopping cart" will not function properly because our website must recognize you as you move through the checkout process.
THIRD-PARTY WEB BEACONS
Consolidated Credit uses third-party web beacons from Yahoo! to help analyze where visitors go and what they do while visiting our website, kofetime.ca (the “Website”). Yahoo! may also use anonymous information about your visits to this and other websites in order to improve its products and services and provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by Yahoo! visit https://legal.yahoo.com/us/en/yahoo/privacy/dashboard/index.html to learn how to opt out of this service.
Retention of Personal Information
Consolidated Credit will keep your personal information for as long as it remains necessary for the identified purposes, as required by law, or in accordance with our retention schedules, which may extend beyond the termination of our relationship with you. Consolidated Credit reserves the right to maintain personal information records for both active and inactive/unsubscribed clients.
CHILDREN AND MINORS
Our website and the services offered on our website are not directed to children under the age of 13 years. We will not knowingly collect personal information about a child under the age of 13. We do not allow minors (persons who are under the age of majority in their place of residence) to create accounts, make purchases or enter contests or promotions, or otherwise make any use of our website. If you believe your child entered information on our site, please let Consolidated Credit know so we can remove the information from our site database.
STORAGE OUTSIDE OF CANADA
Your personal information may be used or stored by us or our service providers and our corporate affiliates outside of Canada. We require that our service providers and our corporate affiliates safeguard your personal information. However, if your personal information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.
GENERAL
Consolidated Credit reserves the right to amend this Policy from time to time by posting an updated version on the Website. If such amendments affect how Consolidated Credit uses or discloses personal information already held by Consolidated Credit in a material way, Consolidated Credit will obtain consent.
Notwithstanding the general terms of this Policy, the collection, use, and disclosure of personal information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.
CONTACT US
For more information on Consolidated Credit and privacy, please contact our Privacy Officer at: [email protected]. If you are unhappy with the way Consolidated Credit has processed your personal information, you have a right to complain to the Office of the Privacy Commissioner.
