Debtless Credit is committed to respecting your rights to privacy and protecting your personal information.
What is Personal Information and why do we collect it?
Personal Information is information about an identifiable individual. Examples of personal information we collect include: names, addresses, email addresses, telephone numbers, dates of birth, identification information (such as government issued identification numbers), bank account information and personal credit and financial information.
As part of our legal obligation in assessing whether this program is suitable for you, we need to obtain from you and other parties personal information relating to you.
We may collect, use, hold, and disclose personal and credit related information about you so that we can:
- Accept, assess, and process your application for a credit rebuilding program;
- Undertake risk assessment and management involving credit scoring, identity verification, and fraud prevention. This may include checking your name against watch lists established by regulatory agencies and similar bodies in Canada and foreign countries;
- Provide you with information about other products or services we currently offer or may offer in the future; and
- Comply with any other legislative and regulatory requirements
We may collect and hold identification and transaction information about you for the purpose of our compliance with the Proceeds of Crime (Money Laundering) and Anti-Terrorism Act and related regulations, including government-issued identification documents, information prepared and maintained by a government agency, general business and credit and payment information about you.
We generally collect personal information with consent except where collection of personal information without consent is permitted or required by law. If you do not consent to our collection, use or disclosure of some or all of the information that we seek to collect from you, we may not be able to provide our services to you.
Disclosure of personal information
Your personal information may be disclosed in certain circumstances including, but not limited to the following:
- Third parties where you consent to the use or disclosure;
- To our partners in financial transactions, including financial institutions, merchants and payment organizations for the purposes of paying out loans, setting up pre-authorized debts
- To credit reporting agencies for the purposes of maintaining your credit history, fraud reporting agencies as necessary to report actual or suspected fraud and debt collection agencies to the extent necessary to collect owed to us;
- To your guarantor, or your prospective guarantor, of any credit provided by us to you (if applicable) to the extent necessary to enter into a guarantee agreement;
- To your co-borrower, or your prospective co-borrower, of any credit provided by us to you (if applicable) to the extent necessary to enter into a co-borrower agreement;
- As required or authorized by law, for example, to government or regulatory bodies who have made a lawful request for the information; and
We may collect your personal information from credit reporting agencies, including obtaining your credit report. We may disclose to credit reporting agencies personal information about you for the purposes of maintaining your credit history, including:
- If you have failed to meet your payment obligations; and
- Our belief, on reasonable grounds that you have committed a serious credit infringement.
We may transfer personal information to service providers (including affiliates acting in this capacity) that perform services on our behalf, such as communications, billing, marketing, information technology and/or data hosting or processing. Some of these service providers may be located outside of Canada, including in the United States, and the United Kingdom. While outside of Canada, personal information will be subject to applicable local laws, which may permit personal information to be accessed by government or national security authorities in certain circumstances.
We may disclose your name, residential address and date of birth to a credit reporting agency and request it to provide an assessment of whether it matches (in whole or part) personal information held by it for the purposes of verifying your identity pursuant to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and related regulations. The credit reporting agency may prepare and provide that assessment to us and may use that disclosed information and the information on its files to do so.
Access to your Personal Information
You may request access to the personal information we hold about you and to update and/or correct it, subject to certain exceptions permitted by law. If you wish to access your personal information, please contact us in writing.
We will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your personal information. In order to protect your personal information we may require identification from you before releasing the requested information.
We will conduct our business with you electronically unless we are prohibited by law from doing so or if you request otherwise.
We will send you electronic documents and information by either:
- Sending them to your nominated electronic address; or
- Sending notification to your nominated electronic address, that a notice or document is available for your retrieval at our members’ log-in area on our website;
You may not receive paper documents so it is important to regularly check your nominated electronic address for notices and documents and notify us of any changes to your nominated electronic address.
Maintaining the Quality of your Personal Information
It is important to us that your personal information is up to date. We will take reasonable steps to make sure that your personal information is accurate, complete and up-to- date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Security of information
The file containing your personal information will be maintained on our servers or those of our affiliates or service providers, and will be accessible by authorized employees and representatives. We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorized access, modification or disclosure. Unfortunately, no data transmission over the internet can be guaranteed as totally secure.
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party. We will obtain your consent to collect your personal information from a third party, except where collection of the information without your consent is permitted or required by law (for example, where the information is collected for the purposes of collecting a debt).
This Policy may change from time to time and is available on our website.