Confidentiality Privacy
SUN Commercial Bank, Ltd is committed to protecting the confidentiality of all personal information obtained in the course of its activities, in accordance with PIPEDA and applicable provincial laws.
1 Confidentiality Agreement
SUN Commercial Bank, Ltd (variously referred to as "We", "Our" or the "Bank") is committed to protecting the confidentiality of all personal information obtained in the course of its activities. The principles underlying this commitment are set out in this Confidentiality Agreement (the "Agreement"). "You" and "your" refer to any person who has applied, registered or signed an application for a banking, insurance, brokerage or financial product or service offered by Us (the "Service"), including co-applicants, guarantors or personal representatives.
This Agreement is designed to comply with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy laws. This Agreement explains the types of personal information We collect, how it is used, and the measures We have taken to ensure the security of your information. The term "personal information" means any information that identifies an individual (i.e., personal or financial information). This personal information may be collected from you during your interactions with us, and from other sources outside our organization, including government agencies and registries, law enforcement, public registries, credit reporting agencies, other financial institutions, service providers, agents, and other organizations with which you have agreements, or any other source with your consent or as permitted or required by law.
Protecting your privacy is important to SUN Commercial Bank, Ltd. That is why we provide this agreement to explain our practices regarding the collection, use, and disclosure of information we receive through our banking services. This agreement does not apply to third-party websites, services, or applications, even if they are accessible through our services.
SUN Commercial Bank, Ltd uses third-party service providers to process and store personal information collected from our clients. This personal information may be stored on servers located outside of Canada. Consequently, this information may be accessible to the government or agencies of that country under a lawful order issued in that country. SUN Commercial Bank, Ltd remains responsible for all information it collects. We take the necessary measures to ensure that personal information transferred abroad or disclosed to a foreign jurisdiction for processing or storage is protected, used, disclosed, and disposed of in accordance with Canadian federal and provincial privacy laws, as well as the internal privacy policies of SUN Commercial Bank, Ltd. Personal information will only be used for the purposes for which it was originally collected.
By creating an account with SUN Commercial Bank, Ltd, you agree to the terms of this agreement.
2 Principles
This agreement is intended to comply with the requirements of PIPEDA, which sets out the ten (10) principles of personal information protection described below. All employees of SUN Commercial Bank, Ltd have a responsibility to implement, respect, and maintain these principles at all times.
Accountability
SUN Commercial Bank, Ltd is committed to protecting the confidentiality of the personal, business, and financial information it holds. This fundamental practice is implemented throughout all of its activities. To this end, SUN Commercial Bank, Ltd has designated a Chief Privacy Officer.
Identifying Purposes
The purposes for which personal information is collected will be specified by SUN Commercial Bank, Ltd at or before the time of collection.
Consent
The informed consent of the client is required for the collection, use, or disclosure of their personal information, except where permitted by law. SUN Commercial Bank, Ltd will make every effort to inform you of the use that will be made of your personal information and will obtain your consent at or before the time of its collection or use. Your consent may be express, implied, or given by an authorized representative. Subject to legal, regulatory, and contractual requirements, you may withdraw your consent to the collection, use, or disclosure of your personal information. However, depending on the circumstances, this withdrawal could prevent us from providing you with certain services or information that may be useful to you.
Collection
The collection of personal information will be limited to what is necessary for the purposes identified by SUN Commercial Bank, Ltd. Information will be collected only by fair and lawful means.
Limiting Use, Disclosure, and Retention
SUN Commercial Bank, Ltd is committed to not using or disclosing your personal information for purposes other than those for which it was collected, or for purposes compatible with them, except with your consent or as required by law. In certain exceptional circumstances, SUN Commercial Bank, Ltd may be legally required or authorized to disclose your personal information without your consent in order to protect its interests or the public interest.
Accuracy
Your personal information must be accurate and kept up to date to the extent possible and consistent with the purposes for which SUN Commercial Bank, Ltd collected it. We also rely on you to inform us of any changes regarding your information. You may request, in writing, access to your personal information to verify its accuracy and completeness and request that it be modified as necessary.
Safeguards
SUN Commercial Bank, Ltd is committed to protecting all of your personal information by applying security safeguards appropriate to its level of sensitivity. These measures include: physical and electronic security safeguards, organizational procedures, and contractual obligations to third parties. Furthermore, protecting privacy is an integral part of our mission, and all of our employees are trained on the importance of protecting your personal data.
Openness
SUN Commercial Bank, Ltd will make specific information about its policies and practices relating to the management of personal information readily available to individuals.
Individual Access
Upon written request addressed to SUN Commercial Bank, Ltd, toute personne sera informée de l'existence, de l'utilisation et de la communication de ses renseignements personnels et y aura accès. Elle aura le droit de contester l'exactitude et l'intégralité de ces renseignements et de les faire rectifier au besoin. Toutefois, dans certaines situations, il se peut que nous ne puissions pas vous donner accès à tous vos renseignements personnels. Des frais peuvent s'appliquer pour la récupération de certains renseignements.
Challenging Compliance
Any individual may address a challenge concerning compliance with any of these principles to the person or persons designated as responsible by SUN Commercial Bank, Ltd. Nous répondrons à vos questions, préoccupations et réclamations dans les meilleurs délais, généralement sous trente (30) jours. Si nous devons prolonger ce délai ou si nous refusons votre demande, nous vous en indiquerons les raisons.
You acknowledge that we may modify this agreement and our privacy policies from time to time. In the event of material changes, we will notify you by publishing them on our website or by sending you an email or other notification.
3 Collection of Your Personal Information
When you apply, provide a guarantee, or use a product or service as a current or former client, we may collect and confirm personal information about you, such as:
- information allowing us to establish your identity, such as your name, address, occupation, date of birth, and other forms of identification required by law;
- information about your financial situation, including your annual income, assets, liabilities, and credit history;
- information reflecting your business relationship with us;
- information about your transactions, including payment history and account activity;
- information regarding your browsing activity, your browser, and your device;
- information regarding beneficial owners, intermediaries, and other parties required by law;
- other information we may require to provide you with a specific product or service;
- U.S. person status (to comply with regulatory requirements);
- other information with your consent, or when permitted or required by law.
4 Use of Your Personal Information
We may use this personal information from time to time in order to:
- verify your identity, including checking your name against Canadian and foreign watchlists;
- assess your current and future creditworthiness, including obtaining credit reports;
- evaluate and process your application, account, transactions, and reports;
- provide you with the products and services you have requested;
- communicate with you in general, including responding to your requests;
- understand your needs for products and services;
- market a product or service, either directly or through an affiliate;
- determine your eligibility for certain of our products and services and offer them to you;
- help us manage and assess our risks, operations, and our relationship with you;
- protect against fraud and error;
- collect amounts owed to us;
- maintain the accuracy and integrity of information held by a credit reporting agency;
- comply with legal, regulatory, governmental, and contractual requirements.
We may also use your personal information for other purposes with your consent or when required or permitted by law.
5 Disclosure of Your Personal Information
We may share your personal information with third-party organizations and service providers, as necessary, for the purposes described above or to offer you a product or service. If your personal information is shared with third parties, they will be bound by appropriate agreements with the Bank to protect your personal information.
We may share your personal information:
- with our employees, agents, service providers, and any other entity that performs services for you or for us or on our behalf. You acknowledge that some of our service providers may be located outside of Canada and that, as a result, your personal information may be accessible to government authorities in accordance with the laws of those jurisdictions;
- with other financial institutions to process payments or verify information such as your identity;
- with payment card networks to operate or administer the payment card system;
- in response to a court order, search warrant, or other request we believe to be valid;
- to satisfy legal, audit, insurance, self-regulatory, and regulatory requirements;
- in connection with negotiations relating to the sale or transfer of all or part of our business;
- with any person or organization to prevent, detect, or suppress fraud and criminal activity;
- to help us collect a debt or enforce an obligation;
- with your consent; and as permitted or required by law.
Additional Collection, Use, and Disclosure
Social Insurance Number (SIN)
We may collect, use, and disclose your Social Insurance Number (SIN) for income tax reporting purposes, in accordance with the law. For products that generate interest or dividends, your SIN is required. You may refuse to consent to the collection of your SIN for purposes other than those required by law.
Verification of Information
We may verify the personal information you provide to us with credit reporting agencies, credit insurers, registries, financial services industry databases, investigative bodies, your employer, and personal references you provide to us.
Credit Consent
If you hold a savings account, a GIC, a loan, a mortgage, a guarantee, or any other product with us, we may, from time to time, use, disclose, obtain, verify, share, and exchange information about your credit with third parties, including credit reporting agencies, mortgage insurers, creditor insurers, and registries.
Personal Health Information
From time to time, you may disclose your personal health information to us in connection with your insurance products and services associated with your credit products. We will not share your personal health information within the Bank, and we will not use it for purposes other than those originally disclosed to you. We will not deny you any product or service based on this information.
7 Protection of Your Personal Information
We have implemented organizational, technological, and physical safeguards tailored to the sensitivity of your personal information under our control. These measures aim to protect your personal information, regardless of format, against loss, theft, unauthorized access, disclosure, copying, use, or modification. Only authorized employees, agents, and representatives will have access to your personal information in the course of their duties.
Please note, however, that no method of transmission or storage of information over the Internet is completely secure. Consequently, we cannot guarantee the absolute security of your information.
Communications
We may monitor and/or record all communications between you and our representatives (for example, telephone discussions, email conversations, online chats) for accuracy, training, mutual protection, and to improve our customer service.
Links to Other Sites
Our Services may contain links to websites and services owned by third parties. Any information you provide to a third-party service is subject to its privacy policy. We are not responsible for the content, practices, and privacy policies of third-party services. To protect your information, we recommend that you carefully review the privacy policies of all third-party services.
8 Accessing and Updating Your Personal Information
Your personal information will be accessible to our authorized employees, agents, and representatives. It is your responsibility to notify the Bank of any inaccuracy or change to your personal information, such as a change of address, telephone number, or marital status. If your personal information changes, or becomes inaccurate or outdated, you must notify us so that we can update our records.
Subject to contractual and legal restrictions, as well as reasonable notice, you may request access to or correction of your personal information held by us at any time by submitting a written request to the Chief Privacy Officer. We will respond to your access request within thirty (30) days of receiving all necessary information.
Please note that we may not be able to provide you with access to your personal information in certain situations (e.g., if disclosure would reveal confidential commercial information or information concerning a third party). In such cases, we will inform you of the reasons for this restriction.
9 Retention and Disposal of Personal Information
We will retain your personal information only for the period necessary to fulfill the purposes for which it was collected. This may include customer service, legal, or regulatory obligations that require us to retain your personal information after your relationship with us has ended.
When your personal information is no longer required, we will securely destroy or anonymize it. Following the termination or deactivation of our services, we, our affiliates, or our third-party service providers may retain information for a commercially reasonable period for backup, archival, and/or audit purposes.
If you have any questions regarding the termination or deactivation of your services, please contact us directly at privacy@suncommercialebank.com.
Electronic Communications
In addition to postal mail and fax, we may communicate with you electronically (SMS, email, voice messages, or images) regarding our products and services or to comply with our legal obligations. You may request that we stop sending you such electronic communications.
Regular emails are not secure. If you use this method of communication, we strongly recommend that you do not include personal financial information (such as your account numbers) in your emails. We remind you that SUN Commercial Bank, Ltd will never open attachments or links sent by email.
10 Refusing or Withdrawing Consent
Subject to legal, regulatory, and contractual requirements, you may refuse to consent to the collection, use, or disclosure of your personal information, or withdraw your consent at any time by giving us reasonable notice.
However, depending on the circumstances, withdrawing your consent could prevent us from providing you with certain products, services, or information that may be useful to you.
If you hold a credit product with us, such as a mortgage, or if you have provided us with a guarantee, you cannot, during the term of the credit, withdraw your consent to the collection, use, or disclosure of your personal information in connection with this product. We may continue to disclose your personal information to credit reporting agencies, even after the credit is fully repaid.
You can neither refuse nor withdraw your consent to the collection, use, and disclosure of your personal information required by law or regulatory bodies.
You can ask us at any time to stop using your personal information for the promotion of our products and services.
Your Choices
We offer you the choice of how your personal information is collected, used, and shared, and we will respect your choices. Please note that if you decide not to provide us with the personal information we request, you may not have access to some or all of the features of the Services.
Opting Out
By subscribing to our mailing list, you will receive regular newsletters. You can opt out of these promotional communications either through your services or by following the unsubscribe instructions contained in the email. We will still need to send you certain service-related communications from which you cannot opt out.
Contact us
We are committed to providing you with clear and easily accessible information on how we manage your personal information. To request access to your personal information, its correction, ask questions about our privacy policies, or refuse or withdraw your consent, you may send us a written request or contact us:
Responsable de la protection des renseignements personnels
SUN Commercial Bank, Ltd
98 King St W, Toronto, ON M5H 1H1
Branch: 1 Place Ville-Marie, Montréal, QC H3B 2E7
We will make every effort to address your complaint as quickly as possible.