(a) Information You Provide
You may be asked to voluntarily give your personal information to Spring Financial when you interact, orally, in writing or by electronic transmission, with Spring Financial, including when you apply for an account, subscribe to a newsletter, register to receive information, apply or register for or order a product or service offered by Spring Financial or use a product or service provided by Spring Financial. In those circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with Spring Financial or otherwise receive the full benefit of the desired product or service. Telephone calls between you and Spring Financial will be recorded to ensure accuracy and quality assurance, and may be disclosed to third parties to verify Spring Financial is compliant with its contractual obligations to third parties. You can choose not to have the telephone call recorded, and communicate by writing or electronic transmission.
(b) Automated Collection
Spring Financial may automatically collect certain information regarding your use of Spring Financial’s website or online service, such as the dates and times that you access the website or online service, the browsers, operating systems, software and devices that you use to access the website or online service and details of your use of the website or online service.
Spring Financial’s website, online services, email messages and advertisements may use technologies (e.g. cookies, web beacons, tokens, session recording, pixels or tags) to collect information that assists Spring Financial to improve its products, services, customer communications and advertising and to prevent fraud. Spring Financial may use information that it collects through technological means to recognize you as a user of Spring Financial’s website or online services, to facilitate and improve your use of Spring Financial’s website or online services, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of a website or online service. More information about cookies used for interest-based advertising is set out in section 4(c) below.
(c) Credit Reports
(d) Bank Information
(e) Information Regarding Referred Transactions
(b) Specific Consents
Spring Financial may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with Spring Financial.
(c) Referred Transactions
(d) Suppliers and Service Providers
(e) Law Enforcement/Legal Disclosures
(f) Business Transactions
Spring Financial and Spring Financial Companies, and its and their service providers may process, store and use your personal information at facilities in various countries, including Canada, the United States of America and one or more countries in Europe or Asia. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing your personal information to Spring Financial, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.
Spring Financial will rely on you to ensure that your personal information that you
provide to Spring Financial is as accurate, complete and up to date as necessary for
the purposes for which Spring Financial uses the personal information. You will promptly
notify Spring Financial of any changes to your personal information using the procedures
made available for that purpose by Spring Financial or by contacting Spring Financial’s customer
You may reasonably request access to your personal information collected by Spring Financial and information about Spring Financial’s use, disclosure and retention of that personal information by submitting a written request to Spring Financial’s Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and to have the information revised as appropriate. You may be required to pay a reasonable fee for access to your personal information. Spring Financial may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.
(a) Disclaimers, Liability Exclusions/Limitations and Disputes:
(b) Changes to this Policy:
(c) English Language:
(e) Contacting Spring Financial’s Privacy Officer: