Wealth One Bank of Canada (variously “Wealth One™”, “We”, “Our”, “Us” or the “Bank”) is committed to protecting the privacy of all Personal Information obtained in the course of conducting its business. The principles underlying this commitment are outlined in this Privacy Agreement (this “Agreement”). “You” and “your” mean an individual who has made application to Us for, enrolled in or signed an application in respect of any personal or business banking, insurance, brokerage or financial product or service offered by Us (“Service”), including any co-applicants, guarantors or personal representatives.
This Agreement has been designed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable corresponding provincial privacy legislation. This Agreement explains the types of Personal Information We collect, how it is used, and the steps We have taken to ensure that your Information is handled in a safe and secure manner. The term “Personal Information” means any information that can be used to identify an individual (i.e. personal or financial details). This Personal Information may be collected from You, from your interactions with Us, and from other sources outside Our organization including government agencies and registries, law enforcement authorities, public records, credit reporting agencies, other financial institutions, service providers, agents and other organizations with whom You have arrangements, or any other source with your consent or as permitted or required by law.
Protecting your privacy is important to Wealth One. With this in mind, We are providing this Agreement to explain Our practices regarding the collection, use, and disclosure of information that We receive through Our banking Services. This Agreement does not apply to any third party websites, services, or applications, even if they are accessible through any of Our Services.
Wealth One uses third party Service providers to process and store the Personal Information We collect from Our clients. This Personal Information may be stored on servers located outside of Canada. As such, this information may be available to the government or agencies of that country under a lawful order made in that country. Wealth One remains accountable for all information We collect. We take steps to ensure that Personal Information sent to or shared with any foreign jurisdiction for processing or storage will be safeguarded, used, disclosed, and disposed of in a way that is compliant with Canadian federal and provincial privacy laws as well as with Wealth One internal privacy policies. Personal Information will be used only in keeping with the purpose of its initial collection.
By signing up for a Wealth One account, You agree to the terms of this Agreement.
This Agreement is designed to comply with the requirements of PIPEDA, which sets out the ten (10) privacy principles that are described below. All employees of Wealth One have a responsibility to implement, comply and maintain these principles at all times.
YOU ACKNOWLEDGE THAT WE MAY REVISE THIS AGREEMENT AND ANY OF OUR PRIVACY POLICIES FROM TIME TO TIME. SHOULD ANY MATERIAL CHANGES BE MADE, INCLUDING A CHANGE THAT WILL HAVE RETROACTIVE EFFECT, WE WILL NOTIFY YOU OF SUCH CHANGES BY POSTING THEM ON OUR WEBSITE, OR BY SENDING YOU AN EMAIL OR OTHER NOTIFICATION. ADDITIONALLY THE WEBSITE POSTING WILL REFLECT WHEN THOSE CHANGES WERE MADE.
When You apply for, or provide a guarantee in respect of, or use any product or Service while You are Our current or former client, We may collect and confirm Personal Information about You such as:
We may also use your Personal Information for other purposes with your consent or as required or permitted by law.
We may share your Personal Information with third party organizations and Service providers as necessary for the purposes outlined above and/or to offer You a product or Service. If your Personal Information is shared with third parties, these third parties will be bound by appropriate agreements with the Bank to protect your Personal Information.
We may share your Personal Information:
Like many website operators, We may use automated data collection tools such as Cookies and Web Beacons to collect certain information on Our Site.
“Web Beacons” (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on Our Services for several purposes. For example, We may use Web Beacons to deliver or communicate with Cookies, to track and measure the performance of Our Services, to monitor how many visitors view Our Services, and to monitor the effectiveness of Our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
Our servers automatically record certain information about how a person uses Our Services (We refer to this information as “Log Data”). Log Data may include information such as a User’s Internet Protocol (IP) address, user agent, browser type, operating system, the web page that a User was visiting before accessing Our Services, the pages or features of Our Services to which a User browsed and the time spent on those pages or features, search terms, the links on Our Services that a User clicked on, and other statistics. We use Log Data to administer the Services and We analyze (and may engage third parties to analyze) Log Data to improve, customize, and enhance Our Services by expanding their features and functionality and tailoring them to Our Users’ needs and preferences. We may use a person’s Log Data and other information to generate aggregate, non-identifying information about how Our Services are used and use such aggregated information to understand and improve Our Services and to administer use of the Services. If We engage a third party to analyze the Log Data, We will ensure that such third party is bound by contractual terms requiring it to process such Log Data.
We collect certain information that your mobile device sends when You use Our Services, like a device identifier, user settings, and the operating system of your device, as well as information about your use of Our Services while using the mobile device. We may use this information to provide the Services and to improve and personalize Our Services for You.
We may engage third party service providers to work with Us to administer and provide the Services. These third party service providers have access only for the purpose of performing services on Our behalf and are expressly obligated to secure your Personal Information and not disclose or use your Personal Information for any other purpose.
Social Insurance Number ('SIN'): We may collect, use and disclose your Social Insurance Number (SIN) for income tax reporting purposes, as required by law. For products that earn interest or dividend income, We require your SIN. In addition, We may ask You for your SIN to verify and report credit information to credit bureaus and credit reporting agencies as well as to confirm your identity. This allows Us to keep your Personal Information separate from that of other clients, particularly those with similar names, and helps maintain the integrity and accuracy of your personal information. You may refuse to consent to its collection, use or disclosure for purposes other than as required by law.
Verification of Information: We may verify Personal Information (including employment status) You give Us with credit bureaus, credit insurers, registries, financial Service industry databases, investigative bodies, your employer and the references You provide to Us and You authorize such persons to provide Personal Information to Us for this purpose.
Credit Consent: If You have a savings account, GIC, loan, mortgage, guarantee or any other product with Us, We may, from time to time, use, give to, obtain, verify, share and exchange credit and other information about You with others including credit bureaus, mortgage insurers, creditor insurers, registries and other persons with whom You may have financial dealings, as well as any other person as may be permitted or required by law, at the time of your application and any time during the application process and on an ongoing basis while You are a client, for the purposes of evaluating your current and ongoing creditworthiness and maintaining your credit history.
Insured Credit Product: If You have an insured credit product (i.e. a mortgage) with Us, We may share Personal Information about You, including credit information, to mortgage default insurers for any purpose related to mortgage insurance.
Information retained by Canada Mortgage Housing Corporation will be subject to federal access to information and privacy legislation.
If the credit facility You have with Us or You have guaranteed is in default, We may release your Personal Information to collection agencies, the originating broker or any subsequent mortgagee, or other third parties as necessary for the purposes of assisting in collecting the debt. We will limit the amount and type of Personal Information disclosed to that which is necessary to facilitate the collection of the arrears.
From time to time You may provide Us with your personal health information in connection with insurance products and Services associated with credit products You have with Us. We may collect personal health information from, or share personal health information with any health-care professional, medically-related facility, insurance company, organizations who manage public information data banks or insurance information bureaus. We will not share your personal health information within the Bank or use it in a manner other than the original intent disclosed to You.
Note that We will not refuse You any product or Service on the basis of any personal health information You have provided to Us.
Personal health information includes items such as your age, weight, height, medical history, physical exams, habits, allergies, vital signs, race, laboratory results, drug levels, adverse events/reactions to medication and insurance claim history which includes instances of decline, termination, complaints and/or litigation.
To provide You with a convenient method for applying for savings accounts and GICs and for accessing other Wealth One products and services such as Registered Savings Plans, We may provide secure online application forms. These forms capture personal information that We use to provide You with the products and services You request. This information is processed in a similar way to application forms received through Our other channels.
We may monitor and/or record any communications between You and Our representatives (i.e., telephone discussions, email conversations, online chats) for accuracy, training, Our mutual protection and to enhance Our customer Service.
We have implemented organizational, technological and physical safeguards to protect the security of Personal Information under Our control in a manner that is appropriate to the sensitivity of your Personal Information. These safeguards are intended to protect the security of Personal Information, regardless of the format in which it is held, against loss or theft, and against unauthorized access, disclosure, copying, use or modification. Authorized employees, agents and mandataries will have access to your Personal Information in order to perform their job functions.
If your Personal Information is shared with Service providers, they will be bound by appropriate agreements with the Bank holding them to the same high standards by which We are governed.
Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, We cannot guarantee the absolute security of any information.
Our Services may contain links to websites and services that are owned or operated by third parties. Any information that You provide on or to a third party service or that is collected by a third party service is provided directly to the owner or operator of the third party service and is subject to the owner’s or operator’s privacy agreement. We are not responsible for the content, privacy, or security practices and policies of any third party service. To protect your information We recommend that You carefully review the privacy policies of all third party services that You access via Our Services.
Your Personal Information will be accessible by Our authorized employees, agents and mandataries. You are responsible for advising the Bank of any inaccuracies or changes to your Personal Information, such as changes of address, telephone number, marital status. If any of your Personal Information changes or becomes inaccurate or out of date, You are required to advise Us so We can update Our records. Please be prepared to verify your identity when updating or changing your Personal Information.
Subject to contractual and legal restrictions, as well as reasonable notice, You may request access to or a correction of the Personal Information We hold about You at any time, subject to contractual and legal restrictions and reasonable notice, by submitting a request to the Chief Privacy Officer in writing. Please be prepared to verify your identity upon making such a request. We will respond to your access request within thirty (30) days of receiving all necessary information, or advise You if We require additional time.
Please note that We may not be able to provide You access to your Personal Information in certain situations (i.e., if disclosing the information would reveal confidential commercial information or information about a third party). If this is the case, We will inform You of the reasons that We were unable to provide You access.
We will retain your Personal Information only as long as it is required for the reasons it was collected. This may include customer service, legal or regulatory needs that require Us to keep your Personal Information beyond the end of your relationship with Us.
When your Personal Information is no longer required, We will securely destroy it or convert it to an anonymous form. Following termination or deactivation of Our Services to You, We, Our affiliates, or third party service providers may retain information, including your profile information and user content for a commercially reasonable time period for backup, archival, and/or audit purposes. If You have any questions about termination or deactivation of your Services, please contact Us directly at firstname.lastname@example.org
In addition to mail and fax, We may communicate with You via electronic messages including text, email, sound, voice or image messages to your electronic mail, instant messaging, or to a similar account regarding Our products and Services or to fulfill legal obligations.
You have the right to notify us to stop sending You such electronic communications.
General email is not secure since it passes through many points on its route from You to Us. If You are using general email to communicate with Us, We strongly recommend that You do not include personal financial information (such as account numbers) within the email, as We cannot guarantee its confidentiality on its route to Us. We would like to remind You that Wealth One will never open any attachments or links You may send Us through email or any other electronic forms of communication.
When You email Us your comments, questions or instructions, You provide Us your email address and We will use this address to correspond with You; your email and Our replies will be stored for any future correspondence with You.
Subject to legal, regulatory and contractual requirements, You can refuse to consent to Our collection, use or disclosure of Personal Information about You, or You may withdraw your consent to Our further collection, use or disclosure of Personal Information at any time in the future by giving Us reasonable notice.
Depending on the circumstances, however, withdrawal of your consent may prevent Us from providing You or continuing to provide You with some products and Services or information that may be of value to You.
If You have a credit product, such as a mortgage with Us or have provided a guarantee to Us, You may not, during the term of the facility, withdraw your consent to Our ongoing collection, use or disclosure of your Personal Information in connection with such product. We can continue to disclose your Personal Information to credit bureaus even after the credit facility has matured and been paid out and You may not withdraw your consent to Our doing so. We do this to help maintain the accuracy, completeness and integrity of the credit reporting system.
We will act on your instructions as quickly as is reasonably possible, but there may be certain uses of your Personal Information that We may not be able to stop immediately.
You cannot refuse or withdraw consent to Our collection, use and disclosure of Personal Information required by law or by Our regulators, including self-regulatory organizations.
You can ask Us at any time to stop using Personal Information about You to promote Our products and Services.
We offer You choices regarding the collection, use, and sharing of your Personal Information and We will respect the choices You make. Please note that if You decide not to provide Us with your Personal Information that We request, You may not be able to access some or all of the features of the Services.
You have the right to refuse further collection, use, and/or disclosure of your Personal Information by notifying Us. If You have consented to your access to and use of the Services but wish to rescind such consent, please contact Us in accordance with the “Contacting Us” section below to submit the request. We will promptly discontinue your access to and use of the Services and ensure that your Personal Information is no longer publicly accessible through the Services. Please note, however, that if You refuse further collection, use, and/or disclosure of your Personal Information, You may not be able to access and use all, or a portion of, the Services.
If You subscribe to Our mailing list, We will periodically send You free newsletters and emails that directly promote Our Services. When You receive such promotional communications from Us, You will have the opportunity to opt-out either through your Services or by following the unsubscribe instructions provided in the e-mail You receive. We will need to send You certain communications regarding the Services and You will not be able to opt-out of those communications (i.e., communications regarding updates to this Agreement).
If You want Us to modify or delete your Personal Information, or discontinue the provision of your Personal Information to third parties, please contact Us in accordance with the “Contacting Us” section below with your request. We will take steps to modify or delete your information as soon We can. Please note, however, that some information may remain in archived/backup copies for Our records or as otherwise required or permitted by applicable law.
We are committed to providing You with clear and easily available information about how We manage your Personal Information.
To request access to, or correction of, your Personal Information, to ask questions about Our privacy policies or to refuse or withdraw your consent to Our use of your Personal Information for purposes outlined in this Agreement, You may send a written request or contact Us at:
Chief Privacy Officer
Wealth One Bank of Canada
170 Sheppard Avenue East
Toronto ON M2N 3A4
Toll Free: 1.866.312.1088
We will use Our reasonable endeavors to address any complaint You may have as soon as possible.