Protecting Your Privacy
Threshold Financial Technologies Inc. (“Threshold”,
“we”, “us” or “our”) values
your business and is committed to helping to protect the privacy
of our customers’ personal information. It may be necessary
for customers to share certain personal information with us
to allow our company to operate effectively in delivering
services to them. We respect that trust and as such, have
implemented policies and procedures as part of our compliance
efforts in view of the Personal Information Protection and
Electronic Documents Act (PIPEDA). Personal information is
information about an identifiable individual, as more particularly
defined in PIPEDA and applicable provincial privacy legislation.
This statement applies to a collection, use and disclosure
of personal information in Canada.
How We Collect, Use and Disclose Your Information
Customers may share personal information with Threshold so
that we may provide them with products and services that best
meet their needs.
ABM and POS Services. We may process and have
access to personal information in the course of providing
automated banking machine (ABM) and point-of-sale (POS) transaction
services to our business clients. This information will include
banking and transaction information necessary to process a
cardholder’s financial or retail transactions and facilitate
the communication of this information between the financial
institutions, retailers or other businesses involved in the
transaction. In providing ABM, POS and related network administration,
switching and monitoring services to our business clients,
we process personal information in accordance with our contracts
with those businesses and in accordance with regulatory requirements
applicable to our industry. If you are concerned about how
your personal information is handled by your financial institutions
or retailers that you deal with, we encourage you to contact
those businesses directly.
Cardholder Customer Service. In certain circumstances,
such as when a cardholder contacts us through our customer
service telephone number, cardholders that use our ABM or
POS facilities may share personal information with Threshold
directly so that we may provide them with requested customer
service. Cardholders may be asked to provide name, address,
phone number, email address, banking information, and other
information relevant to their transaction or customer service
inquiry.
We may use this information in order to:
- Communicate with cardholders
- Respond to customer cash dispensing concerns
- Process payments either to or from customers
- Meet regulatory requirements
We may disclose a cardholder’s personal information
to financial institutions or merchants as necessary to fulfil
these purposes.
Merchant Services. We may also collect, use
and disclose personal information about our merchant customers
(such as Laser Cash merchants), for example in the merchant
application process and in the course of managing our business
relationship with our merchant customers. This information
includes the personal information merchants provide on our
applications and contracts, for example home and/or business
contact information and related banking and credit information.
It may also include personal identification and similar information
provided by the merchant, such as Social Insurance Number,
birth date, and copies of a driver’s licence or other
government-issued ID.
We use this information in order to:
- Assess and process applications, including assessing current
and ongoing credit worthiness
- Provide the products and services requested
- Communicate with merchants regarding our business relationship
and respond to their customer service or similar inquiries
- Manage, administer, collect or otherwise enforce accounts
and payment
- Send occasional communications regarding additional products
or services
- Meet regulatory requirements (for instance relating to
financial services or anti-money-laundering and terrorist
financing)
We may disclose personal information about merchants as necessary
for the above purposes, for instance to financial institutions
and businesses with whom merchants have had or may have a
financial relationship, and credit bureaus and reporting agencies.
General Personal Information Practices
In addition to the above, Threshold generally uses personal
information:
- To maintain business records for reasonable periods
- To generally manage and administer our business
- To meet legal, regulatory, insurance, security, audit
and processing requirements
- Otherwise with your consent, or as permitted or required
by law
Personal information may also be transferred to outside third
party agents or service providers, including outside of Canada,
to provide information processing or similar services on our
behalf. Some of our services may be provided by and through
facilities operated by our affiliates. We take reasonable
measures (including contractual means) to ensure that your
personal information that may be collected, used, disclosed
or otherwise processed by these service providers on our behalf
is protected and not used or disclosed for purposes other
than as directed by Threshold, subject to requirements in
foreign jurisdictions applicable to those organizations. Note
that some of these jurisdictions do not have personal information
protection laws equivalent to those in Canada.
Personal information may be used by Threshold and disclosed
to parties connected with the contemplated or actual financing,
insuring, sale, assignment or other disposal of all or part
of Threshold or our business or assets, for instance for the
purposes of: permitting those parties to determine whether
to proceed or continue with the transaction; fulfilling reporting,
inspection or audit requirements or obligations to such parties;
and the use and disclosure of your personal information by
those parties for substantially the same purposes as described
in this statement.
Threshold may otherwise disclose personal information as necessary
to meet legal, regulatory, insurance, audit and security requirements
(including fraud prevention), with your consent, or as permitted
or required by law. For example, personal information may
be provided to government agencies when we are legally obligated
to do so.
We do not sell customer information.
Our Websites
In general, you can visit our websites and view their content
while remaining anonymous by not providing any personal information.
Our websites collect non-identifiable information that becomes
available to us as a result of your visit to our website.
This information includes, for example, your IP address (a
number automatically assigned your computer when you visit
the website, and which is logged by our servers), your Internet
Service Provider (ISP), your Web browser, the type of operating
system, the domain name of the website which linked you to
our site, and the pages you visited while you were using the
website.
Our clients may be provided with usernames and passwords to
enable authorized personnel to access portions of our website
that permit monitoring of our network or transaction services.
These usernames and passwords are used to control access to
these facilities.
Cookies. We may from time to time use cookies
on this website. Cookies are small text files that your web
browser leaves on your hard drive to allow for personalization
of certain aspects of visits to websites or identify a visitor's
browser to a website each time the site is visited. Information
that may be gathered from cookies by us in this way is only
used on an aggregate basis. Unless a visitor specifically
provides their identity to us (e.g. by providing information
through an online form or sending us correspondence from the
website), we will not know who the individual visitors are.
We may use cookies to store preferences; record session information;
develop information about website visitors’ general
preferences and interests; or record past activity at a site
in order to provide better service when you return to our
site.
You can disable cookies using your Internet browser's settings.
Please consult your browser's help function for information
on how to disable cookies. Note that if you disable cookies,
certain features of our website may not function properly.
Contacting Us. If you make inquiries through
the contact methods in the “Contact Us” or similar
sections of our websites, these inquiries are forwarded to
the relevant department, and are used to respond to your inquiry
and maintain a record of correspondence.
Third Party Links. Our websites may
contain links to other websites that are provided as a convenience
only, and which may have different privacy policies and practices
than Threshold’s. We have no responsibility for such
third party websites, and individuals are advised to review
the privacy policies of any third party websites they visit
We Strive to Protect Your Personal Information
All Employees who are granted access to customer records are
instructed as to the need to keep this information protected
and confidential, and that they are to use the information
only for the purposes intended. This expectation is clearly
and formally communicated.
We’ve also established physical and systems safeguards,
along with the proper processes, to protect customer information
from unauthorized access or use.
Your Privacy Choices
Consent to the collection, use and disclosure of personal
information may be given in various ways. Consent can be express
(for example, orally, electronically or on a form you may
sign describing the intended uses and disclosures of personal
information) or implied (for example, when you provide information
necessary for a service you have requested). Consent may be
given by your authorized representative (such as a legal guardian
or a person having a power of attorney). Generally,
by providing us with personal information, we will assume
that you consent to our collection, use and disclosure of
such information for the purposes identified or described
in this privacy statement, if applicable, or otherwise at
the time of collection.
You may withdraw your consent at any time (subject to legal
and contractual obligation and on providing us reasonable
notice) by contacting our Privacy Officer at the address below.
Please be aware that withdrawing your consent may prevent
us from providing you with the requested product or service.
We may be required or permitted under statute or regulation
to collect, use or disclose personal information without your
consent, for example to comply with a court order, to comply
with local, federal or foreign laws or regulations or a legally
permitted inquiry by a government agency, or to collect a
debt owed to us.
Access and Correction
Threshold may establish and maintain a file of your personal
information for the purposes described in this statement,
which will be accessible at the address below. If you wish
to request access or correction of your personal information
in our custody or control, you may write to our Privacy Officer
at the address below. Your right to access or correct your
personal information is subject to applicable legal restrictions.
Contacting Us
For more information about our privacy policies and procedures,
or to withdraw consent or request access or correction, please
contact our Privacy Officer at:
Privacy Officer
Threshold Financial Technologies Inc.
3269 American Drive
Mississauga, ON
L4V 1V4
(905) 678-7272 ext. 4602
Privacy Statement Changes
This privacy statement may be revised from time to time. If
we intend to use or disclose personal information for purposes
not described in this statement, we will make reasonable efforts
to notify affected individuals in advance, if necessary. If
you are concerned about how your personal information is used,
you should contact us as described above or check back at
our website periodically to obtain a current copy of this
statement. This privacy statement is effective as of July
7, 2004. |
