Our Privacy Policy
Updated on November 01, 2020
Twenty-First Financial Inc., its subsidiaries and affiliates (collectively, “we”, “our”, “us”, and “Company”) is committed to protecting the personal privacy of all its customers, employees, suppliers, contractors, those whom we do business with, or visitors (collectively, “you”, and “your”) to www.twentyfirstfinancial.com (the “Website”). This Privacy Policy describes how we collect, store, handle and protect any recorded information (“Personal Information”) about an identifiable person, including such things as a person’s home address, date of birth, social insurance number and financial information. Such information may be gathered from customers, employees, web site visitors, and those whom we do business with. Most of the Personal Information we handle is collected primarily in connection with products and services provided by or to the Company, and during the establishment of business relations. While conducting our normal course of doing business and depending on various factors such as the nature and purpose of our interaction, the type of products or services may request or use, and any applicable legal and regulatory obligations, we also collect and use Personal Information for a variety of purposes, including:
- Communicating with or to contact you;
- Confirming your identity, and to protect those whom we do business with;
- Establishing, managing and terminating business relations with you, including billing and collecting overdue amounts;
- Determining your creditworthiness or eligibility for our products or services;
- Understanding how you use our different products or services or otherwise do business with us;
- Improving service and understanding more about you (i.e. language and communication preferences and/or what types of products, services, or offers you may like);
- Monitoring or recording communications with our representatives (i.e., telephone calls) in order to assure and enhance customer service quality, to protect you and the Company, to confirm your decisions and our discussions with you, and/or for training purposes.
- Reviewing the products and services that we provide to you;
- Reviewing the products and services that we obtain from third parties;
- Informing you of our other products and services, or those of third parties;
- Protecting us against error, fraud, theft and damage to our goods and property;
- Enabling us to comply with applicable law or regulatory requirements; and
- Any other reasonable purpose to which you consent.
We may also collect Personal Information through our website. Portions of the Website use statistical tools that may be operated by third party providers (collectively, the “Web Tools”). The Web Tools may use “cookies” (text files containing unique identification numbers identifying technical information about the visitor, but not necessarily the identity of the visitor) and/or “web beacons” (also known as a “clear GIF”, an invisible file located on web pages that you visit. Web beacons are used in combination with a cookie to track navigation of a Website, for example if you visit a page on the Website that contains a web beacon, it communicates with your computer to determine, among other things, whether you have been to that page before or have viewed a particular advertisement). This information may be collected by us each time our Website is visited. Cookies allow us to collect and store information such as the type of internet browser and operating system a visitor uses; the date, time and duration of the visit to our Website; the internet address of the Website from which has been linked to our Website; and the pages visited while on our Website. Cookies can also be used to save and remember any preferences that may have been set while the user was browsing the Website, as well as to help to manage online advertising by enabling us to understand which ads bring users to our Website and tailor offers on this and other Websites on which we advertise. Please note that Cookies do not contain information that identifies you personally, and Unless a visitor voluntarily submits Personal Information while on our Website, we will not normally be able to determine the identity of visitors to our Website. The information generated by the cookies and/or web beacons about your use of the Website (including your IP address) will be transmitted to and stored on servers located outside of Canada including, but not limited to, the United States, by the applicable third party provider of a Web Tool.
We may use and may disclose your Personal Information under certain circumstances and in the course of providing products or services to you. The limited circumstances under which we may disclose your Personal Information include:
- During an emergency situation or where necessary to protect the safety of you or others;
- To employees, contractors, agents, consultants and other carefully selected third parties who require the information in order to provide or manage our services to you, including for servicing and installation of products, billing, handling, account administration, collections, marketing initiatives and reporting;
- In response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law;
- At the request of government regulators or law enforcement; and
- Where necessary for the establishment, exercise, or defence of legal claims; or as otherwise required or permitted by law.
We are committed to protecting Personal Information in our possession or control, and in doing so we will implement safeguards to Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The safeguards used will vary depending on the sensitivity, distribution, format and method of storage of the Personal Information; and we employ various physical, electronic and procedural safeguards as appropriate, including limiting access to Personal Information to those employees, agents, contractors, service providers, and others as is applicable, who need to know such information and only in connection with the purposes set forth in this Privacy Policy.
We only retain Personal Information for as long as is necessary to fulfill the purposes for which it was originally obtained, unless we are required or permitted by law to retain the information for a longer period. When Personal Information is no longer needed or permitted to be retained, it is securely destroyed or made anonymous as appropriate.
We disclose Personal Information to unaffiliated third parties only when necessary so that we may provide products or services to our customers or as otherwise identified in this Privacy Policy. When we do disclose such information to other parties, we require them to protect Personal Information to the same standards of the Company and as required by law. If such third parties are located in a foreign jurisdiction, the information becomes subject to the laws of that jurisdiction, including those governing disclosure of Personal Information to government authorities.
The Company may also disclose Personal Information in the event of an actual or in consideration of a possible corporate reorganization, merger or amalgamation with another entity, or an actual or potential sale of all or of a substantial portion of the Company’s assets. In such an event, disclosure would occur on the condition that the information only be used for the purpose of evaluating the transaction, or on completion of the transaction, for the purposes outlined in this Privacy Policy.
You may refuse to provide Personal Information to the Company. Subject to legal or contractual restrictions and reasonable notice, you may withdraw your consent at any time to our collection, use or disclosure of Personal Information. If you withdraw your consent to our collection, use or disclosure of Personal Information we may be unable to provide you with certain products and services. You can withdraw your consent at any time in writing to the Company at the mailing address listed on our Website. In certain circumstances your consent cannot be withdrawn, such as those circumstances where our collection, use or sharing of Personal Information is required by law, or as long as you have a loan or credit product or service with us, you may not withdraw your consent to our ongoing collection, use or disclosure of your Personal Information in connection with such product or service. In addition, to assure integrity of the credit reporting system, we may update your information with credit bureaus from time to time, if you have a loan or credit product or service with us. Your consent to this exchange of information cannot be withdrawn during this time. You may also opt out of continuing to receive communications from the Company in respect of products and services of the Company or third parties other than those which you have inquired about or have consented to receiving. We may, however, collect, use or disclose Personal Information without your knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.
If we use or disclose Personal Information for a purpose other than those identified above, we will, as required, notify you and/or obtain your consent prior to doing so.
You can ask to see the Personal Information that we hold about you at any time. While we take care to ensure that your Personal Information is accurate, correct, and up-to-date necessary for the purposes for which it is to be used, we also rely on you to notify us when your information changes, and we will make all reasonable efforts to ensure that the integrity and accuracy of such information is protected. If you wish to verify the accuracy and completeness of your Personal Information in our records, please contact us at the electronic mailing address listed below. Consistent with applicable law, if an individual requires an alternative method of accessing their Personal Information to accommodate a sensory disability, please contact the customer service phone number listed on this Website, and we will work to provide such alternatives.
When making an access request, we require specific information from you to confirm your identity as well as to search for, and provide you with, the Personal Information that we hold about you. We may charge you a reasonable fee to access your Personal Information; but we will advise you of any fee in advance.
There are only a few circumstances under which we will not comply with your request to provide you with access to your Personal Information. These circumstances include:
- If doing so could reveal Personal Information about a third party (and, in Quebec, if the disclosure could seriously harm that third party);
- If the information is subject to legal privilege or was generated in the context of a formal dispute resolution process;
- If the information relates to the actual or suspected breach of an agreement or of applicable law; or
- Where permitted or required by applicable law.
The Company will inform you of the reasons why, subject to any legal or regulatory restrictions, access has been denied.
From time to time we may update our Privacy Policy. The most current version of this Privacy Policy will be posted on our website.
Should you have any questions or concerns regarding this Privacy Policy or our privacy practices, please contact us at the following electronic mailing address: