Scope and Definitions
This notice describes the privacy practices of Thinking Capital Financial Corporation and its subsidiaries and affiliates. “We” and “us” means Thinking Capital Financial Corporation, our subsidiaries and affiliates, and any of our respective agents and third party service providers (“service providers”). “You” means a website visitor, applicant, customer, former customer, an owner of, or reference or guarantor for, an applicant.
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. 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.
The personal information that we may collect from you includes:
- Contact and identifying information such as name, email address, mailing address, phone number, social insurance number or other government ID, and date of birth;
- Billing information such as credit card number, bank account number, void cheque, and billing address;
- Information about your business such as company name, entity type (e.g. corporation, partnership, sole proprietorship), and business phone number;
- Information about your relationship, such as whether you are a contact, reference or guarantor for an applicant;
- Credit information about you and your business; and
- Financial information about you and your business, such as sales volume, revenue, seasonal or cyclical income patterns, and online banking credentials where you apply for a service that offers data collection directly from your bank account.
We may collect personal information from multiple sources, including:
- From you, in an application, agreement, form, correspondence or verbal communication;
- From third parties such as credit bureaus, business directories, direct contact with nearby businesses, online searches, financial institutions and other entities that have extended credit to you;
- From other people or entities you have identified, such as references (including landlords, suppliers and franchisors), guarantors, employees or directors of your company.
We may collect personal information at various times, including:
- Before we have a business relationship, such as when you send us correspondence, make an inquiry about our products and services, submit an application, or after an application has been declined by us or withdrawn by you;
- During our business relationship, such as when your application and eligibility is being assessed, and during the term of any products, services or other agreement between us; and
- After our business relationship, including to assess your eligibility for new or additional products or services, maintain internal records and communication with you, and to analyze and improve our processes, products and services.
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;
- develop our relationship with you, and to offer financial products and services, including evaluating the needs, wants, and satisfaction levels of customers, potential customers, former customers and others who engage with us, and analyzing and managing our business;
- 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 both products and services which are directly related to your account (such as balance transfers and alternative payment methods) and those that are separate from your account, 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.
Use of Credit Information
Credit score and related information is central to most of the financing products and services that Thinking Capital provides. As a result, the collection and use of credit information is required in order to apply for or maintain our products. In order to offer competitively priced products, we collect and analyze credit information about applicants and customers before, during and after the term of our business relationship, both to assess your eligibility for products and to improve our overall risk assessment tools.
Thinking Capital may collect and use credit information at multiple points throughout the term of the business relationship, and may continue to collect and use updated information after that relationship has ended, for the purposes described above. If you do not want your credit information to be used by Thinking Capital after the term of our business relationship, please contact us using the information provided below.
Use of Your Email Address
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 call you or send you commercial electronic messages at the e-mail address or telephone number 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 call or message you will have the opportunity to opt out of receiving future commercial electronic messages at that e-mail address. If you are a customer, we reserve the right to use the e-mail address 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.
Sharing Personal Information
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:
- to credit bureaus, references, guarantors and other third parties that require it in order to identify you, to provide Thinking Capital with information about you, to facilitate the credit reporting system, to collect on accounts, to provide products or services to you or to assess your eligibility for those third parties’ products or services, or to meet legal and regulatory obligations;
- to third parties who offer products or services that we think may be of interest to you;
- as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process;
- 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 and uses of 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 create, use and disclose anonymized and/or aggregated information which does not allow you to be personally identified to third parties.
Sharing Personal Information Outside of Canada
Retention of Personal Information
We will retain your information for as long as needed to fulfil the purposes for which it was collected and used. In some cases, this may be as long as your account is active or as needed to provide you services. However, in other cases we will retain personal information after the end of our business relationship including to maintain communications with you, facilitate future applications you may submit, understand customer preferences and behaviours, analyze and improve our processes and develop new products and services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You should not assume that your information will be deleted when you close your account with us or if an application is not approved. If you have any questions about how long your personal information is retained, please contact us.
Information Collected through this Site
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 it 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 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 Site, 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 may 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 writing to us at email@example.com. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Links to Other Websites or Social Media Features
Our Site may also include 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.
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 receive an e-mail purportedly from Thinking Capital containing or asking for sensitive information (for example, full account number, social insurance number, personal identification number (PIN), or security passwords), prior to responding, please 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.
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 for correction of your personal information in our possession, please write to us at email@example.com. We may need to confirm your identity before fulfilling your request, such as by requesting a copy of a valid driver’s license, birth certificate, or passport.
If you are a customer, you can also access and update your personal information anytime by logging into your account.
We will respond to your request within a reasonable timeframe.
Updating your Consent Preferences
You may withdraw your consent to the collection, use and disclosure of your personal information by contacting us in writing at firstname.lastname@example.org. In some cases, Thinking Capital will be permitted to continue to collect, use and disclose personal information after you have withdrawn consent, such as where the information is necessary to administer your account, maintain the integrity of the credit reporting system, or as otherwise permitted by law. In other cases, if you withdraw your consent for any purpose required to provide our product or service to you, we may no longer be able to provide that product or service to you.
In addition, if you withdraw consent to the use of your personal information for marketing purposes, you may continue to receive promotional communications after the date of that request if a marketing campaign is already in process before we receive your request.