Effective Date: 01/16/2018
Scope and Definitions
This notice describes the privacy practices of Thinking Capital Financial Corporation and its affiliates. “We” and “us” means Thinking Capital Financial Corporation, our affiliates, and any of our respective agents and third party service providers (“service providers”).
Personal information means any factual or subjective information in recorded form, that identifies or could be used to identify an individual.
Collection of Personal Information
The personal information that Thinking Capital collects and uses varies depending on our interactions with you, however, we will take reasonable care to ensure we only collect personal information necessary to appropriately process, record, and manage your interactions with us, or that is required for business record keeping or for internal planning purposes. The personal information that we may collect from you includes:
- Contact and identifying information such as name, email address, mailing address, phone number, government ID, and date of birth;
- Billing information such as credit card number, bank account number, void cheque and billing address; and
- Information about your business such as company name, and business phone number.
We also obtain credit information about you from an outside credit reporting agency to help us with customer authentication and credit-related decisions.
We collect the following personal information from you about your references:
- Phone number
By submitting information about your references, you warrant and represent, that you have obtained the consent of the subject reference to provide their name and phone number to Thinking Capital for the purpose of Thinking Capital contacting such reference regarding your application.
Use of Personal Information
We use personal information about you to:
- evaluate, monitor, maintain, service, and collect any application or account you may have with us, including disclosing or exchanging personal information with credit reporting agencies, to develop our relationship with you, and to offer financial products and services, including evaluating the needs, wants, and satisfaction levels of our customers and analyzing and managing our business;
- administer services, monitor your purchases, transactions, payments, and evaluate your credit eligibility, for the purposes set out in this notice;
- verify your identity (or that of any authorized user or co-applicant) concerning the account and maintain security measures aimed at the detection and prevention of fraudulent activity in relation to your account;
- promote and market products and services offered by Thinking Capital, including products and services which are directly related to your account (such as balance transfers and alternative payment methods), and including by means of direct marketing.
- to establish and maintain communications with you, and respond, report or discuss information in response to product and service inquiries or suggestions for improving our products and services.
- to meet legal and regulatory requirements.
- for everyday business purposes, such as website management, research and product and service development.
We use the personal information about your references only for the purpose of inviting your references to consent to receiving commercial electronic messages from Thinking Capital.
You may withdraw your consent to receive promotional and marketing communications under (d) above, as well as other commercial electronic messages as defined under Canadian anti-spam legislation, at any time after your account has been opened by calling Thinking Capital at 1-866-889-9412 or by writing to us at Thinking Capital, 4200 Boulevard Dorchester, Suite 300, Montreal, Quebec, Canada, H3Z 1V4.
In accordance with your request, and within 5 business days, we will remove your contact information from direct mail marketing, telemarketing, or commercial electronic messages for products and services offered by Thinking Capital.
Please allow 90 days for full effect as marketing campaigns may already be in process. However, if your request is made within the first 30 days of your account’s opening, we will not share your name for use in any secondary marketing campaign. This will not limit information we may provide to you in statements or when you contact us.
Additional Detail: Consent
If you refuse or withdraw your consent for any purpose required to provide our financial product or service to you, we may no longer be able to provide that product or service to you. You understand that if you withdraw your consent at any time to the monitoring of your credit status or your ongoing eligibility for credit, Thinking Capital may no longer be able to maintain your credit account.
By submitting information regarding references, you warrant and represent, that you have obtained the express consent of the subject reference party to provide their name, email address and relationship to you, to Thinking Capital as a referred party. Thinking Capital will use the referred party’s personal information, and will identify you as the referring party, for the purpose of contacting that individual to obtain their further consent to receive to commercial electronic messages from Thinking Capital.
Additional Detail: Personal Information Collection and General Account of Use
We collect personal information about you and use it for the purposes described above. Our objective when collecting and using personal information is to maintain and improve the relationship we have with you; provide you with information about products and services that you will value; reduce the cost associated with maintaining your (and others’) accounts so that we may continue to provide you with a fairly priced product; reduce unwanted or inappropriate marketing; and protect you from unauthorized access to and use of your account or personal information.
Our Security Procedures Protect Your Personal Information
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We work hard to keep personal information secure through physical and electronic information security policies, employee policies and training, and contractual safeguards with all third parties who may have access to personal information. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
However, no transmission of personal information, including transmission over the Internet can be guaranteed to be completely secure. Consequently, Thinking Capital its affiliates, related companies, service providers and their respective officers, directors, employees and agents do not represent, warrant or guarantee that personal information will be protected against misuse, loss or alterations and do not accept any liability for personal information submitted to them nor for your or third parties’ use or misuse of personal information. Moreover, where you use passwords, ID numbers, or other special access features it is your responsibility to safeguard them.
We may provide your personal information to our service providers who may be located outside Canada for purposes related to supporting our business (e.g., sending you emails, fulfillment services, technical support, delivery services), including, without limitation, research and product and service development. These third parties are authorized to use your personal information only as necessary to provide these services to us.
We may also disclose your personal information:
- as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process; and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
- to third parties (who may be located outside of Canada) if Thinking Capital is involved in a merger, acquisition, or sale of all or a portion of its assets, in which case you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information; and
- if the rights or property of Thinking Capital, its affiliates, subsidiaries, or third party service providers are in jeopardy.
In addition, Thinking Capital may disclose anonymized and/or aggregated information which does not allow you to be personally identified to third parties.
Sharing Personal Information Outside of Canada
Collecting Personal Information of Children
Thinking Capital considers the protection of children’s privacy, especially online, to be of the utmost importance. We do not intentionally collect personal information from any person we actually know is under the age of 18, without the consent of a parent or legal guardian. Thinking Capital products and services are not intended for, or designed to attract, individuals under the age of 18.
Access and Correction Requests
Upon request, Thinking Capital will provide you with information about whether we hold any of your personal information. To request access, update and/or correction of your personal information in our possession, submit a personal information request using our “Contact us” form on our website or write to us at: Thinking Capital, 4200 Boulevard Dorchester, Suite 300, Montreal, Quebec, H3Z 1V4. You can also access and update your personal information anytime by logging into your account. Your request must include a copy of a valid driver’s license, birth certificate, or passport.
We will respond to your request to access within a reasonable timeframe.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The Thinking Capital Web servers automatically recognize and record the domain name from which you access the Internet, the corresponding Internet Protocol (“IP”) address, and the names of the pages you visit while at Thinking Capital’s Site, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data and store it in log files. This information is not personally identifiable and is used to improve the content of Thinking Capital Site and make them more useful.
The Thinking Capital web servers do not collect e-mail addresses without your consent.
Personal information of users, including emails, is however, collected when you are responding to specific questions and when you communicate directly with Thinking Capital via e-mail or feedback forms. Thinking Capital may ask you to provide us with your e-mail address at several points, including on applications, in correspondence or communications with you.
Use of Your Email Address
Currently, we do not share any e-mail address you provide to us with our endorsing organizations or other companies to market their products or services. We use both Thinking Capital servers and servers of other service providers to deliver and report on the progress of e-mail programs and to maintain service and fulfill products and services. When Thinking Capital uses a service provider, we prohibit them from using your e-mail address for any other purpose.
With your consent, we may periodically send you commercial electronic messages at the e-mail address(es) you provide, including to solicit your feedback on our products and services, and/or to provide you with marketing offers that may be of interest to you. With each such message you will have the opportunity to opt-out of receiving future commercial electronic messages at that e-mail address. If you are an account holder, we reserve the right to use the e-mail address(es) you provide to present you with information about your account. This may include, but is not limited to, activating your account(s), account past due notices, rates available, and adding an authorized user.
We will track the activity of an e-mail (for example, were graphics viewed, was the e-mail opened, were links in the e-mail clicked), to allow us to measure the effectiveness of the e-mail, to provide future offers, and for fulfillment of products and services. Additionally, for your convenience, we may pre-fill online forms with your e-mail address.
Thinking Capital will not disclose or request sensitive information in an unencrypted e-mail (for example, full account number, social insurance number, personal identification number (PIN), or security passwords).
If you receive an e-mail purportedly from Thinking Capital containing or asking for this type of sensitive information, prior to responding, please contact Thinking Capital Customer Satisfaction at 1-866-889-9412 x0549.
Use of Tracking Technologies
Technologies such as cookies, beacons, scripts and tags are used by Thinking Capital and our marketing partners, affiliates or analytics or service providers. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.
We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
To Further Protect Your Privacy
Our Site also includes Social Media Features, such as the Facebook button, and Widgets, such as the Share this button or interactive mini-programs that run on our website. These features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
Updates and Additional Information
4200 Boulevard Dorchester
Suite 300, Montreal, Quebec