Smart Everyday People Financial Inc. its parent, subsidiaries, affiliates, or any of their respective employees, agents, officers, directors or third-party service providers (collectively “SEP”, “we”, “us” and “our”) provides services to you though its various websites based on the applicable product or service (collectively, the “Website”), mobile application (“App”) and client portal (“Portal”), which may also be accessed through the App.
SEP is committed to protecting the personal information our customers (“customer”, “you” and “your”) provide, including the collection, use, and disclosure of personal information. SEP recognizes and respects the importance of protecting the security and confidentiality of the personal information we collect and maintain about our customers and takes steps to ensure we meet privacy principles and requirements with respect to personal information under applicable Canadian privacy legislation, which can include the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and any comparable provincial legislation, as well as related regulations.
The purpose of this policy is to inform our customers and other individuals how we deal with your personal information and acts a guideline of how we collect, use, disclose, and protect your personal information.
Types of Personal Information:
Personal information means information about an identifiable individual. This may include identification information (name, date of birth, sin number, drivers license number), contact information (address, telephone number, email address), financial information (bank account numbers, bank statements, credit report, credit card information, monthly income), medical or health information (provincial health care number, prescription information, diagnosis, medical procedures, health services information) and general information relating to your interactions with SEP (transaction information and information about how you use the Website collected through “cookies”). Personal information does not include anonymous information or information that relates to a group of people rather than individuals where the information does not otherwise contain identifying information.
Acknowledgement, Acceptance and Consent
Withdrawal of Consent
You can withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting our Privacy Officer. Upon reasonable, advance notice SEP will ensure that your personal information collected is no longer used or disclosed by SEP (unless otherwise required or permitted by law). Once notified, we will use reasonable efforts to remove your personal information in a timely manner (unless otherwise required or permitted by law). We will advise you of any consequences of the withdrawal of your consent as sometimes, withdrawing consent means you can no longer receive or participate in a product or service.
Consent Not Required or Permitted by Law
SEP may be required or permitted under statute or regulation to collect, use or disclose personal information without the individual’s knowledge and consent in certain circumstances. For example:
- When the collection, use, and disclosure is permitted or required by law or to comply with a court order.
- To comply with local, provincial, or federal laws or regulations or a legally permitted inquiry by a government agency.
- When the collection, use and disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely manner.
- When seeking the consent of the individual may defeat the purpose of collecting the information.
- When needed to collect a debt owed to us, to comply with a subpoena, warrant or other court order or as otherwise required or authorized by law.
- When information is publicly available.
Our Principles of Privacy:
- Establishing Accountability: SEP is responsible for maintaining and protecting the personal information under its control.
- Obtaining Consent: SEP will require the knowledge and consent of the customer for the collection, use or disclosure of customer information (unless required or permitted by law).
- Identifying the Purpose and Limiting the Collection of Information: SEP will identify the purposes for which personal information is collected before or at the time the information is collected, by fair an lawful means. Personal information collected must be limited to those details necessary for the purposes identified by SEP.
- Limiting Use, Disclosure and Retention of Personal Information: SEP may only use or disclose personal information for the purpose for which it was collected unless the customer has otherwise consented, or when it is required or permitted by law. SEP will retain customer information for the duration of our relationship with the customer, plus a reasonable period of time as required or permitted by law.
- Keeping Information Accurate: SEP will maintain customer information in as accurate, complete, and up-to-date form as is necessary to fulfill the purposes for which it is to be used. However, if your personal information has changed, it is your responsibility to provide the updated information to SEP.
- Protecting Customer Information: Personal information will be protected by security safeguards that are appropriate to the sensitivity level of the information.
- Maintaining Openness of Policies and Practices: SEP will make information available to customers concerning the policies and practices that apply to the management of personal information.
- Providing Customer Access to Personal Information: Upon request, a customer shall be informed of the existence, use and disclosure of their personal information, and shall be given access to it, except when legally restricted. Customers may verify the accuracy and completeness of their personal information and may request that it be amended, if appropriate.
- Handling Customer Complaints and Questions: Customers may direct any questions or inquiries with respect to the privacy principles or our privacy practices by contacting our Privacy Officer.
Personal Information We Collect:
Products or Services
We will identify the purposes which personal information will be collected before or at the time of collection (unless new purposes are later identified as set out above). We collect personal information to facilitate the products and services that are offered through the Website, App, Portal and by SEP generally, including information about the products or services, the methods of financing those products and services and the individuals to whom we provide financing.
Product Preferences, Research and Other SEP Offerings
We may also put personal information to other uses, such as communicating information and offers to you, respond to your inquiries and to conduct research to better understand, analyze and respond to your needs and preferences, and to subsequently develop, enhance, and/or provide products and services to meet those needs, such as through promotions or marketing initiatives. Your personal information may be combined with other personal information collected by us to provide aggregate statistical information about your service usage preferences.
Personal Health Information
Personal health information may be collected in relation to certain products and services provided by SEP, including reimbursements and eligibility relating to Health Spending Accounts or as part of an application to financing certain medical procedures or health services.
Some Examples of Collection
SEP might collect personal information for the following purposes (this list includes only some examples and is not exhaustive):
- Your full name, address, telephone number, e-mail address, age, etc. for product or service applications, enrolling in the App or Portal or to adequately respond to your inquiries.
- Your bank account numbers, bank statements, credit report, job title, monthly income, birth date, social insurance number when applying for credit cards, homeownership financing or other credit facilities.
- Your credit card information or bank account numbers for payment processing or bill payments.
- Your purchase history and product or service preferences or instructions as relates to our products or services.
- Your personal health information such as provincial health number, medical procedures or health services, medical equipment information and/or prescription information which may be required for reimbursement under your Health Spending Account or to obtain financing for certain health or medical procedures.
- Your personal identification cards, such as driver’s license, utility bill or any other applicable document for identification and/or signature verification.
- Your IP address and device information, such as identifier, name and type, operating system, location, mobile network information and standard web log information such as your browser type, traffic to and from our Website, the pages you accessed on our Website, and any other available information. This includes, but is not limited to, details of your purchases, content you viewed, event information, click stream information and cookies that may uniquely identify your browser or your SEP account.
- Your information provided during any contact you have with any of our services or employees, such as with our customer support team, surveys or through your interactions with us.
- Your bank account numbers and information for fund withdrawals or at the time of loan repayment in the form of Pre-Authorized Debit/Pre-Authorized Payment.
- Your customer account balance, billing and payment status and history relating to customer transactions and experiences with us and third parties.
- Your customer creditworthiness and credit history we may receive from consumer credit reporting agencies or other outside sources.
Use of Your Personal Information
How we use your personal information may differ depending upon how you interact with us, and what services or products you request and we provide. We will use your information to provide the products and services as requested by you and/or to offer other products or services which we have identified may be of interest.
Some Examples of Uses
SEP uses personal information for the following purposes (this list includes only some examples and is not exhaustive):
- To administer and provide financial or other services.
- To evaluate your application and determine your initial and ongoing eligibility for our financial products and services.
- To confirm or verify your identity or signature.
- To confirm details of your employment and income to assess and administer financial or other products or services.
- To obtain credit information and credit reports from credit reporting agencies to assess credit history and credit worthiness and to confirm accuracy of information provided by individuals.
- To process billing and invoices, and manage, administer, and collect your payments for products or services.
- To confirm or provide pre-approvals, reimbursement or other information under any health spending account or to facilitate financing for medical or health related expenses.
- To maintain business records for and generally manage and administer our business.
- To collect a debt that may become owed by you to SEP.
- To maintain contact with you as permitted by law.
- To report account information, such as credit limit, balances and payment information, to credit bureaus.
- To reporting information, such as balances or expenses for reimbursement, to the relevant merchant or service provider (other than SEP) to allow them to provide or continue to provide products or services to you.
- To extract and generate statistics for our internal purposes.
- To improve our products and services.
- To promote and market our products and services.
- To meet legal, regulatory, security, processing and contractual requirements, or otherwise as permitted or required by law.
Disclosure of Your Personal Information:
SEP discloses personal information as reasonably required to process and provide products or services to you, including suggestions of other promotional or special offers of our products and services available to you. We will make reasonable efforts to ensure personal information is as accurate, complete and up-to-date as is necessary for the purposes for which it is used. Due to the nature of SEP’s business, personal information will be updated on an on-going basis.
We Do Not Sell Personal Information to Third Parties
SEP does not your sell personal information to third parties (except as may apply under the Financing Sources and/or Sale of Business section below). Personal health information will only be disclosed in a manner to facilitate the specific product or service to which it relates.
Financing Sources and/or Sale of Business
Examples of Disclosure
SEP may disclose your personal information to and for the following (this list includes only some examples and is not exhaustive):
- We may disclose personal information we collect to a third party that performs services on our behalf, which may include, but is not limited to, pre-authorized payment processing, contract administration and registration, insurance tracking and processing, third-party facilities that purchase loans in whole or in part (securitization) and credit reporting agencies.
- While completing or partially completing a loan application and/or obtaining financial services, your personal information, such as your contact information and available credit with SEP, will be disclosed to the merchant or service provider from whom you are applying to purchase products or services in connection with your application. Your personal information may be shared even if you do not transact and the merchant or service provider may use this information to contact you.
- We may transfer personal information to outside agents or service providers, such as credit bureaus, billing service providers, insurance companies, collection agents, marketing agencies, or other lenders. If your personal information is transferred to another lender, regardless of whether the lender extends you an offer of financial services or whether you accept such an offer, the lender may use your personal information to conduct its own marketing activities, including by emailing you. You may opt-out of receiving these communications after you receive one by responding directly to the lender.
- We may cooperate with suppliers, merchants, service providers and partners for providing you with additional products or services or for advising us on matters such as market research and data processing. Such parties will only be given the information that may be necessarily required to perform the applicable services and they are required to adhere to comparable privacy standards.
- We may disclose personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, or as permitted or required by law.
Protecting Personal Information
SEP is committed to protecting the security of our users. Please keep in mind, however, that no data transmission over the internet or any wireless network can be guaranteed to be 100% secure and it is not confidential. Such data can be intercepted, lost, misused or altered. As a result, we cannot guarantee the security of any information you transmit using the Website, Portal, App or the internet and you transmit such information at your own risk. Furthermore, SEP does not assume any responsibility for use or disclosure of your information that are the result of unauthorized or illegal access to our systems or the Website, Portal or App or those of our service providers.
We operate secure data networks protected by industry standard firewall and password protected systems, and maintain physical, electronic and procedural safeguards to protect the integrity and privacy of these servers and of your personal information.
Your information may be stored by us on our own protected servers, or by other parties in electronic or physical files. Electronic files are stored on servers which may be located outside of Canada, including in the United States. If such information is located outside of Canada, foreign governments, courts of law enforcement or regulatory agencies may be able to obtain disclosure of this information.
SEP is committed to ensure that your personal information is protected by reasonable security safeguards. In addition to the safeguards set out above for data transmission, SEP follows generally accepted industry standards to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control. Such safeguards may include, but is not limited to, to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. SEP will update and review the reasonableness of the security safeguards as needed on an ongoing basis.
Our Website and the Internet:
Visiting our Website
We operate our Website which provides information about your accounts, and allows you to request further information, customer support or make other inquiries. Like most websites, our Website gathers traffic patterns which may be linked to your Internet Protocol or “IP” addresses (which are unique Internet “addresses” assigned to all Internet users by their internet service providers), Website usage information, type of operating systems, time and duration of visit and pages requested as well as identify categories of visitors by items such as domains and browser types. These statistics are only collected and used on an aggregate basis to evaluate our visitors’ preferences and the effectiveness of our Website. This aggregate usage data does not identify you individually. We may share anonymous, aggregated statistics about visitors to our Website with others outside our company, or we may allow third parties to collect aggregate data through our Website.
Personal information provided by you online is used to respond to your inquiries and fulfill your requests. Personal information that you voluntarily provide in response to our online questionnaires and surveys are used to help us learn more about your interests and preferences and may be used to send you periodic information about our products and services (if you have chosen that option).
Cookies and Other Features
Unless you specifically provide your identity to us, such as by providing information through an online form or sending us correspondence from the Website, cookie information is anonymous, and we will not know the identity of any individual visitor. You can disable cookies using your internet browser’s settings. Please consult your browser’s help function for information on how to disable cookies. If you disable cookies, certain features of our Website may not function properly.
Our Website may also use a technology called “tracer tags” or “web beacons” which are electronic images that allow us to understand which pages you visit on our Website and to help us optimize and tailor our Website. Web beacons may also be used in some of our emails to let us know which emails and links have been opened by recipients which allows us to gauge the effectiveness of our customer communications and marketing campaigns.
Our Website may include links to other websites that are provided as convenience only and whose privacy practices and policies may differ from those of SEP. We are not responsible for such third party websites. If you submit personal information to any of those websites, your information is governed by third party privacy policies. We encourage you to carefully review the privacy policies of any third party websites you may visit.
Text Message or Email Communications:
Access to Personal Information:
You have the right to access the personal information we hold about you. You can access your personal information by making a written request to our Privacy Officer. You may be required to provide satisfactory proof of identification to ensure the safety and security of the personal information before we can process your request. We may charge a reasonable cost (e.g. photocopying, mail charges) to provide such requested information. If we are not able to provide you with access to some of your information, we will advise you of the reasons we are not able to provide access. Where possible we will advise you of the source of the personal information, its use and any parties to whom it may have been disclosed.
We reserve the right to decline to provide access to personal information where the information requested would disclose:
- personal information of another individual or a deceased individual;
- the information is not readily retrievable and the burden or cost of providing the personal information would be disproportionate to the nature or value of the information;
- it does not exist, is not held or cannot be found by us;
- it could reasonably result in serious emotional harm to the individual or another individual, or serious bodily harm to another individual; or
- it may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions.
We will not respond to repetitious or vexatious requests for access.
Contacting Us and Access to Your Personal Information:
Smart Everyday People Inc.
450, 11150 Jasper Avenue
Edmonton, AB T5K 0C7
Your right to access or correct your personal information is subject to applicable legal restrictions.