The information we collect may include, but is not limited to:
(a) Information You Provide
You may be asked to voluntarily give your Personal Information to us orally, in writing, or by electronic transmission, when you interact with us, including when you apply for an Account, subscribe to a newsletter, register to receive information, and apply, register, order or use the Products or Services we offer. 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 us or otherwise receive the full benefit of the desired product or service.
When you communicate with us, we may monitor and record our telephone and chat conversations (including text/SMS messages) with you for accuracy, quality assurance, and to resolve any concerns. Such records may be disclosed to third parties to verify we are compliant with our contractual obligations with such third parties. You will be provided with a notice at the beginning of our initial call with you that it is being recorded. You can choose not to have the telephone call recorded, and can communicate this to us in writing, by e-mail, or during a call with us.
You also consent to us obtaining additional Personal Information about you from third party vendors, to whom we have provided certain basic Personal Information (eg. Spring Financial sending identification information to a third party to receive additional comments and or Personal Information regarding the same). In the scenario you provide your Personal Information to a third party, who then forwards such Personal Information to us, then we will not be liable to you with respect to any consent you may not have provided to such third party for the forwarding of your Personal Information. You are fully responsible for understanding the terms and conditions of the submission of your Personal Information to such third party. Our relationship with you only starts when you engage with our Products and Services.
(b) Automated Collection
We may automatically collect certain information regarding your use of our Website or online service, such as the dates and times that you access our Website or online service, including the full Uniform Resource Locaters (URL), 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. These details can include products you viewed and searched for, aggregate data about download efficiencies, page interaction information, including scrolling, clicks and other mouse movement data. Further we may collect other technical information such as the Internet protocol (IP) address, operating system and platform, browser type and version, time zone settings, and location information to estimate your general location.
Our Website, online services, email messages and advertisements may use technologies (e.g. cookies, browser web storage, web beacons, tokens, session recording, session replay, pixels or tags) to collect information that assists us in improving our Products and Services, customer communications and advertising, and to prevent fraud. We may use information that we collect through technological means to recognize you as a user of our Website or online services, to facilitate and improve your use of our 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 our Website or online service. More information about cookies used for interest-based advertising is set out in section 4(c) below.
(c) Financial Information
(d) Bank Information
You must carefully review any agreements you have entered into with your financial institution to confirm whether you are permitted to provide us with your Banking Information, and whether your use of the Bank Verification System may result in any negative consequences for you. We are not liable for any breach of contract or any other liabilities that may result from your use of the Bank Verification System and your disclosure of your Banking Information to us.
(e) Information Regarding Referred Transactions
(b) Disclosure by Spring Financial
(c) Interest-Based Advertising
(b) Specific Consents
We may disclose your Personal Information in accordance with express or implied consents that you give during your interactions and transactions with us.
(c) Referred Transactions
(d) Suppliers and Service Providers
(e) Law Enforcement/Legal Disclosures
(f) Business Transactions
We and Spring Financial Companies, and our 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, Asia, or South America. 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 us, you consent to the transfer and access of your Personal Information to facilities located in other countries and the processing and storage of your Personal Information at those facilities.
We rely on you to ensure that the Personal Information you provide to us is as accurate, complete and up to date as necessary for the purposes for which we use the Personal Information. You will promptly notify us of any changes to your Personal Information using the procedures made available for that purpose by us or by contacting our customer service.
You may reasonably request access to your Personal Information collected by us and information about our use, disclosure and retention of that Personal Information by submitting a written request to our 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 in our control and you will be entitled to verify the accuracy and completeness of your Personal Information and to have it revised as appropriate. You may be required to pay a reasonable fee for access to your Personal Information.
You may request we delete your Personal Information in our possession by submitting a written request to our Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, we will delete your Personal Information upon such request.
We will take appropriate steps to verify the identity of anyone requesting changes to, access to or deletion of your Personal Information. We may decline to process a request to change or access Personal Information 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:
(d) Contacting Spring Financial’s Privacy Officer: