Privacy

This Privacy Policy sets out the personal information practices of President’s Choice Bank, PC Financial Insurance Agency Inc., PC Financial Insurance Broker Inc., President’s Choice Services Inc., and certain other members of the Loblaw Companies Limited group of companies (“Loblaw”) as identified from time to time and who are subject to this Privacy Policy (“us”, “our”, “we”), with respect to the handling of the personal information our customers (“you”, “your”). As part of our ongoing commitment to protecting your personal information, all of us have adopted the Loblaw Privacy Code, which is based on the privacy principles set out in the Personal Information Protection and Electronic Documents Act as well as applicable provincial privacy laws. This Privacy Policy, as may be amended from time to time, is to be read together with the Loblaw Privacy Code, as may be amended from time to time. The full text of the Loblaw Privacy Code can be obtained at www.loblaw.ca. Some providers of our products and services are companies with whom we have co-venture relationships (“co-venturers”). For the purpose of providing you with certain products and services, your personal information may be collected, used and disclosed by our co-venturers, and this collection, use and disclosure is also governed by the privacy policies of our co-venturers. For example, if you apply for a President’s Choice Financial bank account, you are providing your personal information to one of our co-venturers, the Canadian Imperial Bank of Commerce (“CIBC”), and this information and any information about your transactions is subject to the CIBC Privacy Policy. A current list of our co-venturers and the President’s Choice and PC branded products and services that we and our co-venturers offer can be found at www.pcfinancial.ca/privacy.

Our commitment to you
Respecting your privacy and protecting your personal information is an important part of how we do business Regardless of how the range of products and services we offer our customers expands, and the technology we use changes, we will remain committed to protecting the privacy of your personal information. This Privacy Policy is part of our commitment to ensure that all personal information in our possession is protected and used in accordance with the law. This Privacy Policy replaces any President’s Choice Financial Policy or statement about privacy previously provided by us, but does not replace the applicable privacy policies of our co-venturers or the Loblaw Privacy Code. To the extent that a co-venturer’s privacy policy may permit disclosing your personal information to us, and when such disclosure occurs, your personal information will then be collected, used and disclosed by us according to this Privacy Policy. This Privacy Policy is subject to change. The most current version of this Privacy Policy can be accessed through our website, www.pcfinancial.ca. You should review the current Privacy Policy from time to time.

Your personal information
Personal information is any information about an identifiable person, other than certain business contact information or certain publicly-available information such as contact information in a telephone directory. Personal information can include such information as your name, mailing address, date of birth, Social Insurance Number, and financial information, as well as your opinions, preferences, and purchase patterns. We recognize that some personal information is highly sensitive, and we consider the sensitivity of the information in deciding how we will use it, and, if appropriate, disclose it, and in how we will obtain your consent to such use and disclosure.

Collection, use and disclosure of your personal Information
We may, from time to time, collect personal information about you, including transaction information obtained as a result of your relationship with us and others. We may collect, use and disclose your personal information for several purposes, including:

  • to develop and maintain our relationship with you, including inviting you to comment on the products and services we provide to you;

  • to process your application or quote for products or services, and share your information with the providers of those products and services;

  • to provide and administer the products and services you have requested;

  • to approve transactions;

  • to verify your identity and to protect all parties from errors and fraud;

  • to verify your eligibility for certain products and services;

  • to assess and update your credit worthiness on an ongoing basis, including to adjust your credit limits, and, effective as of July 1, 2009, your interest rates or any other features of your accounts;

  • for marketing analysis purposes and to track and analyze your purchases and other transactions (including the number and amount of transactions by type, product code information, brand, etc.), shopping patterns, account balances, account numbers, payment history, account activity, and the channels you use to apply for or to access or use the products or services to which this Privacy Policy applies;

  • for research and statistical analysis purposes (we anonymize information used for such purposes to the extent possible);

  • effective as of July 1, 2009, for testing, such as when updating systems or adding new vendor relationships (we anonymize information used for such purposes to the extent possible);

  • to better understand your needs including your financial needs;

  • to provide you with information about other products and services offered by us, other members of the Loblaw group of companies, our co-venturers and select unaffiliated entities, which we believe may be of interest to you, and avoid sending you information which we believe will not interest you;

  • for promotions, printing and contest administration;

  • for data processing, website administration or information technology support;

  • to respond to inquiries about your application, account, insurance policy or any other business that you have with us;

  • effective as of July 1, 2009, with respect to your President’s Choice Financial MasterCard, to provide any changes to the number of your account or card(s), to the expiry date of your card(s) and to the status of your account to certain merchants with whom you have set up pre-authorized payments from your account, so that these merchants are able to provide continuous service to you when information about your account changes;

  • to comply with legal and regulatory requirements; and

  • for any other purposes set out in this Privacy Policy or in the Loblaw Privacy Code.

Unless you tell us otherwise, we may contact you by any means for which you have provided contact information. For example, if you provide us with your email address, we may contact you via email from time to time, for any purpose described in this Privacy Policy. The following sections outline certain situations in which your consent to our collection, use and disclosure of some personal information is either required or optional.

Credit accounts
In order to provide you with credit accounts, including credit products, you must consent to the provider of the credit collecting, using and in some cases disclosing and confirming the information you provided on your application, obtaining credit reports and/or other credit history information about you from time to time, and to using such information to assess and update your credit worthiness on an ongoing basis including to: (i) authorize or decline the opening of a credit account, (ii) assess and if applicable adjust your credit limit or (iii) add, remove or modify certain features of your credit account. The information you have provided on your application may be used and disclosed for any purpose described in this Privacy Policy, even if your request for a credit account is declined. In addition, in order to maintain the integrity of the credit reporting system, we must be able to update your credit information from time to time with the entities that support that system, such as credit reporting agencies. Your consent for these uses cannot be withdrawn during the time you have credit with us or during any required reporting period. When you open a credit account with us such as a President’s Choice Financial MasterCard account, you may be asked to provide your Social Insurance Number in order to help verify the accuracy of your credit report and to report credit information to credit bureaus and credit reporting agencies. Your consent to this collection and use is optional. If you choose not to provide your Social Insurance Number, this in itself will not prevent you from obtaining credit from us.

Interest-earning accounts
When you open an interest-bearing or investment account, the Income Tax Act requires us or the co-venturer offering the product to obtain your Social Insurance Number. If you do not provide us or the co-venturer offering the account with your Social Insurance Number, we may not be able to open such an account for you.

Insurance
We collect and use personal information about you, as required to process your request for an insurance premium quote. We also collect, use and disclose to the insurer, the personal information required to complete any applications for insurance you make. Where permitted by law, we may use and/or disclose the information we have collected from yourrequest for a quote or on your application, for any purpose described in this Privacy Policy, even if you do not purchase the insurance or your application for insurance is declined. Your health information may be required to establish your eligibility or rate for certain insurance products or to process a claim. However, your health information is not used or disclosed for any other purpose.

Loyalty programs
The PC points loyalty program, which is operated by President’s Choice Services Inc. or any of its affiliated entities, as identified from time to time, is included with many of our products and services. For loyalty programs, including the PC points loyalty program or any other program we may offer in the future, and any of these programs as they may be amended from time to time, you may choose not to receive secondary marketing offers based on information collected through your loyalty program account. However, if you withdraw your consent to the collection, use or disclosure of your personal information for the purposes of operating the loyalty program, including research and analysis, we may be unable to provide you with certain products and services. Information regarding your loyalty program account may be used by and disclosed by us, by our co-venturers and by third party service providers for the purpose of administering the loyalty program, including providing you with details concerning your PC points transactions on your account statements for any accounts that you hold with us or with one of our co-venturers. Information regarding your account may also be used and disclosed by us, by our co-venturers, by third party service providers and by select unaffiliated entities for the purpose of providing you with information from time to time about products and services which may be of interest to you. For more information, please see “To whom we disclose your personal information” below.

To whom we disclose your personal information
We do not sell or rent your personal information to anyone. Your personal information is not disclosed to or shared amongthe providers of President’s Choice Financial products and services when such disclosure or sharing is prohibited by law. Subject to the terms of this Privacy Policy, we may disclose your information within the Loblaw group of companies, to our co-venturers, to third party service providers, and to other select unaffiliated entities. We make reasonable efforts to ensure that all co-venturers, third party service providers and select unaffiliated entities have privacy policies and security measures in place that conform to our high standards. In addition, with respect to your President’s Choice FinancialMasterCard and effective as of July 1, 2009, we may disclose updated information regarding your account to
certain merchants with whom you have set up pre-authorized payments from your account. Please be aware that we do not review the privacy policies or security measures of the merchants with whom you have set up pre-authorized payments from your account.

When we disclose personal information, we only provide as much personal information as is required to fulfill the purposefor which the information is being disclosed. In order to provide you with the products and services you haverequested, your personal information may be processed and stored by us, within the Loblaw group of companies, by co-venturers, by third party service providers or by select unaffiliated entities located outside the province in which the information was collected or outside Canada. However, before your personal information is transferred in this manner, we will take reasonable steps to ensure that your personal information will not be used for purposes other than those set out in this Privacy Policy, or communicated to third persons other than those contemplated in this Privacy Policy without your consent, except as provided by law. When your personal information is transferred to a jurisdiction outside of Canada, it becomes subject to the laws of that jurisdiction, including laws governing disclosure.

Your consent
Your consent is fundamental to protecting the privacy of your personal information. It is important to us to have your informed consent to any collection, use or disclosure of your personal information. By applying (even if your application is declined) or requesting a quote (even if your quote is not fully processed) for any product or service covered under this Privacy Policy, or by accepting, using, or continuing to hold any such product or service, you consent and agree to the collection, use and disclosure of your personal information in accordance with the terms of this Privacy Policy. We will not collect, use or disclose your personal information without your knowledge and consent except in certain limited circumstances as required or permitted by law. For example, when you use your President’s Choice Financial MasterCard to pay for a grocery item in a Loblaw store, your personal information is not shared for purposes other than those set out in this Privacy Policy, unless we obtain your consent to do so or we are required or permitted to do so by law without your consent. We will obtain your consent if we wish to use personal information that we or our co-venturers have already collected in a manner that is not identified in this Privacy Policy, beyond what you would reasonably expect. Consent can be express or implied, depending on the circumstances. Your consent is implied when we provide you with reasonable notice of the purposes for which we intend to collect, use or disclose your personal information, for example by making this Privacy Policy available to you, and provide you with a reasonable opportunity to refuse or withdraw consent to the proposed collection, use or disclosure, and you do not, within a reasonable time, respond to our notice and this opportunity to refuse or withdraw consent. For more information on refusing or withdrawing your consent, please see the section “Our opt-out policy”, below.

Our opt-out policy
You have the option to refuse or withdraw your consent to the collection, use or disclosure of your personal information as follows:

  1. You may choose not to provide certain personal information to us. Please understand that this may limit our ability to serve you, and may prevent us from providing certain products and services to you.

  2. You may, with reasonable written notice, withdraw your consent to the collection, use or disclosure of your personal information, subject to any legal or contractual restrictions.

  3. You may request that you not receive personalized direct marketing communications from us. However, due to printing and distribution schedules, you may continue to receive some communications that were in progress before we were able to process your request.

  4. If you tell us that you do not wish to receive any marketing communications from us, we will do our best to accommodate your request, within current industry standards and our technical capabilities. This will not limit information that we may send to you with your account statement, or discussions with any of our associates.

  5. If you have previously expressed a request not to receive marketing communications from us, we will continue to honour that request.

  6. You may, with reasonable notice, request to opt-out from any disclosure to merchants of any changes to your account,including the account number, any card number or card expiry dates, and the status of your account. If accommodating your request would limit or prevent us from providing you with a product or service you have requested, where possible, we will explain the implications of your request to you in order to help you make an informed decision. You may contact us regarding your consent to the collection, use and disclosure of your personal information at the addresses shown in the “How to contact us” section below or by calling: 1-866-246-PCMC (7262).

Sale or transfer of business
Some of our businesses and services have in past and may in future be transferred within the Loblaw group of companies, or sold to third parties, in whole or part. In addition, the manner in which products and services are provided to you, and the organization providing those products and services, may also change. As a result, your personal information may be disclosed to an acquiring organization, either as part of due diligence and/or on completion of a transaction, and to additional third party service providers. When your personal information is disclosed within the Loblaw group ofcompanies, it will continue to be protected by this Privacy Policy. When your personal information is disclosed to unaffiliated third parties, either acquiring all or part of a business from us or as a result of a change of product or service provider, we will require the third parties to agree to protect your personal information with policies meeting the same high standards as this Privacy Policy.

Accessing your personal information
Upon written request, we will provide you with reasonable access to personal information about you that is in our possession. We will also update and/or correct your personal information as required. If we are unable to provide you with access to your personal information, we will provide reasons for our inability to do so, unless we are prohibited from doing so by law.

Co-venturer privacy policies
Collection, use and disclosure of your personal information by us is governed by this Privacy Policy together with the Loblaw Privacy Code. For products and services covered under this Privacy Policy which are provided by our co-venturers under the President’s Choice or PC brands, collection, use and disclosure of your personal information by our co-venturers is governed by each applicable co-venturer’s Privacy Policy.

For President’s Choice Financial personal banking products and services other than the President’s Choice Financial MasterCard, please refer to the CIBC Privacy Policy which can be obtained by calling 1-888-723-8881, by visiting www.pcfinancial.ca, or by writing to:
President’s Choice Financial Services
P.O. Box 603, Stn. Agincourt
Scarborough, Ontario M1S 5K9

For PC Financial auto or home insurance, in addition to this Privacy Policy and the Loblaw Privacy Code, please refer to the privacy policy of your insurance company, information about which is included with your insurance policy.

For PC Financial travel insurance, in addition to this Privacy Policy and the Loblaw Privacy Code, please refer to Chartis Insurance Company of Canada for their Privacy Guidelines by calling 1-800-387-4481 x 2745, by visiting www.aigcanada.com and selecting the Privacy link, or by writing to:
The Privacy Officer of Canada
145 Wellington Street West
Toronto, Ontario M5J 1H8

For PC Financial pet insurance, in addition to this Privacy Policy and the Loblaw Privacy Code, please refer to the SecuriCan General Insurance Company Privacy Policy which can be obtained by visiting www.securican.com and selecting the Privacy link, by sending an email to privacy@securican.ca, or by writing to:
SecuriCan General Insurance Company
200-1200 Portage Avenue
Winnipeg, Manitoba R3G 0T5
Attention: Privacy Officer

How to contact us regarding privacy:
By telephone: 1-800-525-7868
By mail: Privacy Officer
439 King St. West, 5th floor
Toronto, Ontario M5V 1K4
By email: privacy@pcfinancial.ca

(As of April 30, 2012
Privacy Officer,
25 York Street, P.O. Box 201, 7th floor
Toronto, Ontario M5J 2V5)

If you are not satisfied with our response to a complaint regarding our compliance with this Privacy Policy or regarding any of our policies and practices with respect to the handling of personal information, you may contact the Federal Privacy Commissioner at 112 Kent Street, Ottawa, Ontario, K1A 1H3, 1-800-282-1376 or the provincial privacy commissioner of the province where the personal information was collected or is stored. More information, including contact information for the provincial privacy commissioners, can be obtained at the federal privacy commissioner’s website, www.privcom.gc.ca.

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