Crelogix

Protecting Your Privacy is Important to Us!

The Internet has revolutionized the way everyone conducts business. It allows information and services to be accessed from the convenience of your home or office, it also allows information to be shared and distributed broadly and rapidly. At the same time, it raises concerns about privacy and security. As a result, there has been a worldwide effort to legislate consistent practices in relation to the collection and disbursement of personal information in this new electronic age.

At Crelogix, we are dedicated to protecting your privacy and safeguarding your personal, business, and financial information. No matter how you choose to provide information to us, we use sound security safeguards and adhere to Ten Privacy Principles to ensure your personal and financial information is protected.

You are invited to use this privacy site to learn more about personal information protection, about the types of information we collect and how it is used, and about the steps we are taking to ensure your personal and financial information is handled appropriately.

Our Commitment to You
At Crelogix, safeguarding your confidentiality and protecting your personal and financial information is fundamental to the way we do business.

We are committed to meeting or exceeding the privacy standards established by federal and provincial regulators. All of our information handling practices are designed to comply with federal and provincial laws including the federal Personal Information Protection and Electronic Documents Act, and the British Columbia Personal Information Protection Act. This legislation governs and regulates the collection, use and disclosure of personal information by organizations to ensure that it is handled responsibly.

The Ten Privacy Principles
In relation to the Ten Privacy Principles, Crelogix Companies means: Crelogix Credit Group Inc. Crelogic Acceptance Corporation, Crelogix Portfolio Services Corporation, Crelogic Financial Corporation, Crelogic Capital Corporation.

The Crelogix Companies have always been and will continue to be, committed to maintaining the accuracy, confidentiality, and security of your personal and financial information. As part of this commitment, they have used the Ten Privacy Principles to govern their actions as they relate to the use of customer information. These principals have been built upon the values (commonly known as “Fair Information Practices”) which are internationally recognized as fundamental to the protection of personal privacy and are found in most privacy legislation around the world including Canadian Standards Association’s Model Code for the Protection of Personal Information, which was incorporated into Canada’s Personal Information Protection and Electronic Documents Act and BC’s Personal Information Protection Act.

Principle 1 – Be Accountable

Principle 2 – Identify the Purpose

Principle 3 – Obtain Consent

Principle 4 – Limit Collection

Principle 5 – Limit Use, Disclosure and Retention

Principle 6 – Be Accurate

Principle 7 – Safeguard Customer Information

Principle 8 – Be Open

Principle 9 – Customer Access

Principle 10 – Handling Customer Complaints and Suggestions

Principle 1 – Be Accountable
Each Crelogix Company is responsible for maintaining and protecting the customer information under its control. In fulfilling this mandate, each Crelogix Company is required to designate an individual or individuals who is/are accountable for that Company’s compliance with the Ten Privacy Principles.

Principle 2 – Identify the Purpose
The purposes for which customer information is collected shall be identified before or at the time the information is collected.

Principle 3 - Obtain Consent
The knowledge and consent of the customer are required for the collection, use or disclosure of customer information except where required or permitted by law.

Principle 4 – Limit Collection
The customer information collected must be limited to those details necessary for the purposes identified by the Crelogix Company. Information must be collected by fair and lawful means.

Principle 5 – Limit Use, Disclosure and Retention
Customer information may only be used or disclosed for the purpose for which it was collected unless the customer has otherwise consented, or when it is required or permitted by law. Customer information may only be retained for the period of time required to fulfill the purpose for which it was collected.

Principle 6 – Be Accurate
Customer information must be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

Principle 7 – Safeguard Customer Information
Customer information must be protected by security safeguards that are appropriate to the sensitivity level of the information.

Principle 8 – Be Open
Crelogix Companies are required to make information available to customers concerning the policies and practices that apply to the management of their information.

Principle 9 – Customer Access
Upon request, a customer shall be informed of the existence, use and disclosure of their information, and shall be given access to it. Customers may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.

Principle 10 – Handling Customer Complaints and Suggestions
Customers may direct any questions or enquiries with respect to the privacy principles outlined above or about our practices by contacting the designated person(s) accountable for privacy in each Crelogix Company.

Privacy Protection in Canada
This privacy policy has been developed to meet the compliance standards established by Canada’s Personal Information Protection and Electronic Documents Act, and British Columbia’s Personal Information Protection Act.

Personal Information Protection and Electronic Documents Act

The Personal Information Protection and Electronic Documents Act, formerly referred to as Bill C-6, has a fundamental message that, subject to certain exceptions, personal information about an individual cannot be collected, used or disclosed by private sector organizations without that individual’s knowledge and consent. This law, as its name suggests, encompasses two primary objectives. The first objective is to establish rules that govern the collection, use and disclosure of personal information by private sector organizations. The second objective is to acknowledge the validity and legality of electronic documents.

Personal Information Protection Act - BC

In order to govern the commercial information-handling practices within provincial jurisdictions, each province has been encouraged to enact legislation that is substantially similar to the federal law. In October 2003, British Columbia enacted the Personal Information Protection Act, formerly referred to as Bill 38, which applies to commercial activity within BC.

However, the Personal Information Protection and Electronic Documents Act will continue to regulate cross-border, inter-provincial and international trade and commerce.

On January 1, 2004, both of these Acts require that most organizations regardless of their size, which collect, use or disclose personal information in the course of commercial activity, will become subject to the provisions of the Acts as applicable.

For more information regarding this legislation, please visit the Privacy Commissioner of Canada website at http://www.privcom.gc.ca or the Corporate Privacy and Information Access Branch of the BC Ministry of Management Services website at http://www.mser.gov.bc.ca/foi_pop/index.htm

What Information is Collected?
At Crelogix, we gather and use personal information to provide you with the financial services you have requested. We may also use that information to offer you some of our other products and services, which we believe may be of interest to you. Providing us with your personal information is always your choice. That information enables us to complete your request. Most of the information we collect comes to us directly from you, or through our Partners, who are required to adhere to our Privacy Policy. The information is only obtained with your consent.

The types of information we may ask for depends on the nature of your request. Information that is essential for fulfilling most financial requests and applications will include your basic contact information (name, mailing address, e-mail address, phone numbers), your Social Insurance Number, your bank information (branch and account) and your employment details. We may also request additional information to help us provide you with the financial service you have requested.

When you visit the Crelogix website, information is NOT collected that could identify you personally unless you choose to provide it voluntarily.

All the information you provide to us is securely maintained and is kept strictly confidential.

Types of Information We Collect
Crelogix has grown to be a financial services institution of choice for our many clients, and we value that relationship. That is why it is important to have up-to-date and accurate information which helps us provide you with the best possible service and to offer additional products and services we believe might be of benefit to you.

At Crelogix, we collect two types of information from our clients. With your consent, we collect personal information. We may also collect anonymous/non-personal information.

Personal Information

Personal information is information that refers to you specifically. With your consent, we may gather personal information from you through our representatives or partners, in person, over the telephone or by corresponding with you via mail, fax or the Internet.

The type of information we usually collect and maintain in your customer file may include:

For Personal Customers:

Name
Marital/Family status
Mailing Address
E-mail Address
Telephone/Fax Number
Social Insurance Number
Date of Birth
Place of Employment
Annual Income
Bank information
Credit History

For Business Customers:

Business Name
Business Address
Business Telephone/Fax Numbers
Name(s) of Owner(s), Officer(s) and Director(s)
Industry Type
Financial Status/ Financial Statements

The choice to provide us with personal and financial information is always yours. In financial dealings, however, your decision to withhold particular details may limit the services we are able to provide. If we are unable to accommodate your request based on the information that has been provided, we may ask for additional details.

Anonymous/Non-Personal Information

At Crelogix, we may collect anonymous/non-personal information. Anonymous/non-personal information is information that cannot be associated with or traced back to a specific individual or business entity. For example, anonymous/non-personal information is automatically collected by web servers when you visit websites, including Crelogix website. The anonymous/non-personal information collected may be used for research and analytical purposes. For example, we are able to determine how many times our online privacy policy has been visited but we do not know any specific information about who the visitor is unless they consent to provide us with that information.

To help us better understand our markets, we may also gather information for analytical purposes by extracting demographic information from existing files, from Statistics Canada, and from various industry publications.

Information Required for Common Activities
At Crelogix, the type of information you will be asked to provide will vary according to your activity or request. Information will only be requested by a Crelogix representative or partner, in full accordance with our Privacy Policy guidelines as follows:

Financial services for Personal use
Financial services for a Proprietor
Browsing Crelogix Web sites
Online transactions
Extended Financial Services Needs

Financial Services for Personal Use

For personal financial services requests, such as a car lease or a loan for medical procedures, you will be asked to provide information such as your name, address and telephone number. We will also require that you provide us with permission to review your credit history. You will also be asked for specific information about your current financial situation.

In order to conduct an accurate review of your financial situation we will ask for your employment status, social insurance number, and birth date and use that information only to assist in rendering our decision to provide you with credit for your financial requirements.

Financial Services for a Proprietor

For financial services requests from a Proprietor, such as a business car lease or a lease for business equipment, you will be asked to provide information such as your name, address and telephone number and your business name. We will also require that you provide us with permission to review your credit history. You will also be asked for specific information about your current financial situation and/or the financial situation of your business.

In order to conduct an accurate review of your financial situation we will ask for your tax returns, social insurance number, and birth date and use that information only to assist in rendering our decision to provide you with credit for your financial requirements.

Browsing Crelogix Web sites

You may browse Crelogix Web sites anonymously and privately, even if you do not wish to interact with these sites or use online services. No personal or financial information will be collected from you without your knowledge and consent.

Online transactions

Personal clients may wish to logon to our website and complete our online consumer financial services application forms. It is always your choice to complete the personal information requested. Our system will prompt you to consent to our collection, use and disclosure of your personal information before you remit it to the Crelogix online application system. Crelogix partners also have access to our online services, which only allows them to remit information collected to Crelogix and also prompts a consent before remitting that information. No party visiting our website or using our online services has any access to your personal information remitted online, nor is there any access to our client information databases.

Extended Financial Service Needs

As your financial needs grow, you may wish to purchase insurance products for your equipment leased through Crelogix such as life and disability insurance products for your equipment leases. To facilitate your request for this product, we will need to ask for more detailed personal information from the proprietor or key-man, including health information. The choice is always yours whether you wish to provide this information.

How Your Information is Used
At Crelogix, we use three primary types of information:

We use personal and financial information to process applications and to provide you with the services you have requested.
We use transactional information to keep track of your dealings with us.
We use anonymous/non-personal information to improve our products and services to you.

Personal and Financial Information

We use your personal and financial information to communicate with you, process applications and effectively provide the services you have requested. When you become a Crelogix customer, we make every effort to establish and maintain a positive relationship with you. To help us do this, we use the personal information you have provided to us to communicate with you and to safeguard your interests. We will keep you informed by sending you notices, and respond to any special needs or enquiries you may have.

We only use personal information for the purpose that we have disclosed to you. If for any reason your information is required to fulfill a different purpose, we will notify you and ask you for your consent before we proceed.

Transactional Information

The majority of information we retain about you is in the form of transaction records that reflect your financial dealings with us.

Anonymous/Non-Personal Information

The anonymous/non-personal information gathered from Crelogix websites is used primarily for technical, research and analytical purposes like evaluating the various sections of these sites. This information does not include any personal or financial data and it is only retained until its intended purpose is fulfilled.

When Information May be Disclosed to Outside Parties
At TAC, we are obliged to keep your personal and financial information confidential except under the following special circumstances:

When Authorized by You
When Required by Law
When Permitted by Law

When Authorized by You

Credit agencies and other financial institutions routinely contact us for credit and financial information about clients. To comply with these requests, we require our client's consent. We usually obtain this permission in a Client Application Agreement, which a client signs when requesting a specific product or service.

Client Application Agreement

A Client Application Agreement is how we gather your personal information. It is used to define the product or service that you are requesting, collects personal information from you and assists us in rendering a decision to advance those products or services to you. (This form may have another name depending on which service you are requesting, but the content of the form will generally be as described herein and Client Application Agreement refers to any Crelogix application form).

With respect to the matter of privacy, the Client Application Agreement authorizes us:

To collect credit and related financial information from you, from other Crelogix companies, from credit agencies, from other financial institutions, and from references provided by you.
To use personal or business information to determine your financial situation, to provide the services you have requested, and to offer additional products and services that might benefit you.
To share your information with Crelogix Funding Partners.
To share your information with credit agencies and other financial institutions.

In most cases, your consent to use and/or disclose your information will be obtained in writing. In other cases such as when you apply for a product over the Internet, your consent will be obtained electronically.

When Required by Law

In some instances such as a legal proceeding or court order, we may be required to disclose certain information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so.

When Permitted by Law

There are some situations where we are legally permitted to disclose personal information such as employing reasonable and legal methods to collect a delinquent account, a medical emergency or suspicion of illegal activities.

With Whom We May Share Your Information

Crelogix businesses, their employees and service suppliers, our Partners and Funding Partners are all governed by strict standards and policies to ensure your information is secure and treated with the utmost care and respect.

At Crelogix, client information is strictly confidential. With your consent we share information with our Partners and Funding Partners, who perform services on our behalf, but only for the original purposes that the information was obtained for. Unless release is authorized by you or is permitted or required by law, we never sell or trade information about you or your accounts to other parties.

Our Employees

In the course of daily operations, access to private, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it.

As a condition of their employment, all employees of Crelogix are required to abide by the privacy standards we have established. They are also required to work in an ethical manner and must follow all applicable laws and regulations. Employees are well informed about the importance of privacy and they are required to sign either a code of conduct or a confidentiality agreement that prohibits the disclosure of any client information to unauthorized individuals or parties.

Unauthorized access to and/or disclosure of client information by an employee of Crelogix is strictly prohibited. All employees are expected to maintain the confidentiality of customer information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

Our Partners

At Crelogix, we have an extended network of service Partners. Our Partners offer Crelogix financial services to facilitate your acquisition of their services or products. In order to do this, our Partners may be required to gather personal information on our behalf. All of our Partners and their employees are required to abide by our Privacy Policy when obtaining this information. Our Partners must execute a Privacy Protection Schedule as part of their contractual obligations with Crelogix. This agreement defines their responsibilities for collecting, using and disclosing personal information in a manner that is consistent with the privacy policies and practices that we have established. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide.

Our Funding Partners

At Crelogix we source funds from various financial institutions in order to get the most affordable financial services product to our customers. In order to facilitate this, we must share account details, including personal information, with our Funding Partners. Every time we obtain a credit application or contract agreement with our customer, this is disclosed to you and we obtain your consent. Crelogix insists on protecting your privacy and has entered into privacy protection agreements with all of our Funding Partners to ensure your information is handled in a manner that is consistent with the privacy policies and practices that we have established. As well, our Funding Partners, being financial institutions themselves, are bound by federal and provincial privacy protection legislation and have similar privacy policies and procedures to that of Crelogix.

Our Service Providers

Sometimes Crelogix will contract outside organizations to perform specialized services such as market research or data processing. Our trusted service suppliers may at times be responsible for processing and handling some of the information we receive from you.

When we contract our suppliers to provide specialized services, they are given only the information necessary to perform those services. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide. In fact, our suppliers are bound by strict contractual obligations that have been designed to protect the privacy and security of your information. Furthermore, as part of our contract agreements, our suppliers and their employees are required to protect your information in a manner that is consistent with the privacy policies and practices that we have established.

Our Opt-Out Policy
In order to provide you with all of our products and services, Crelogix may with your consent, send you information on our other Crelogix company products. Should you not wish to receive promotional materials simply:

4445 Lougheed Highway, Suite 900
Burnaby, British Columbia V5C 0E4 Canada
Call us at 800 667 6640
Fax us at 800 360 9129

How We Safeguard Your Information
At Crelogix, we use state-of-the-art technologies and maintain current security standards to ensure that your personal and financial information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. All safety and security measures are also appropriate to the sensitivity level of your information.

Client Files

Electronic client files are kept in a secured environment with restricted access. Confidential Logins and Passwords are required for each user of the system.

Paper-based files are stored either in locked filing cabinets or a locked filing room. Access is restricted.

Information Security

We make every effort to manage our server environment appropriately. Our firewall infrastructure is thorough and strictly adhered to. Our security practices are reviewed on a regular basis. We employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.

To safeguard against unauthorized access to our database, users are required to “sign-on” using a private login and a protected password to access certain secured areas of our database. Users are only given access to information that would be required to fulfill their employment duties.

When you call our customer service representatives, we make every effort to confirm your identity before releasing any personal information, including providing your account number, providing some personally identifying information or last-call information or caller-ID.

How You Can Protect Your Information
At Crelogix, we do our utmost to protect and safeguard your personal and financial information. We believe there are measures you should take as well. The following is a list of things you can do to protect yourself against fraud and uninvited intrusion.

Personal Information

You should not share personal or financial information such as your Social Insurance Number or Crelogix account number with others unless you clearly understand the purpose of their request and you know with whom you are dealing.

Suspicious Solicitation

From time to time, Crelogix will engage in promotional campaigns via telephone, mail and e-mail. If you are unsure of the information you receive from us, please call us at 1-877-293-0202 to verify that the campaign is a legitimate Crelogix activity.

Accessing and Amending Your Information
At Crelogix, decisions are often made based on the information we have. Therefore, it is important that your personal and financial information is accurate and complete. As a customer, you have the right to access, verify and amend the information held in your personal and financial files.

Accessing Your Information

You may request access to your regular account or transactional information by sending your request in writing to Crelogix.

Should you have questions concerning a decision we have made, we will inform you of the reasons for those decisions upon your request and if we are permitted to do so by law.

If for some reason, you are refused access to factual information held in your file, you may challenge this refusal by contacting our Privacy Officer.

Amending Your Information

To help us keep your personal information up-to-date, we encourage you to advise us of any inaccuracies or corrections as often as necessary. Where appropriate, we will make every effort to communicate these changes to other parties who may have unintentionally received incorrect information from us.

To Make a Change

To make a change to the personal contact information contained in your file, please call us at 1-877-293-0202 or send your request in writing.

Questions, Concerns and Complaints
If you have a question about the privacy policies stated on this site, please call us at 1-877-293-0202.

If you have a concern or complaint about privacy, confidentiality or the information handling practices of your account with Crelogix, please write us with your request at:

Crelogix
Attention: Privacy Officer
4445 Lougheed Highway, Suite 900
Burnaby, British Columbia V5C 0E4 Canada

Updating this Policy

Any changes to our privacy policy and information handling practices shall be acknowledged in this policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of the privacy website.

Companies Governed by this Privacy Policy
The following Crelogix businesses, affiliates and subsidiaries are governed by the provisions and practices stated in this privacy policy and the use of the term Crelogix herein refers only to these companies.

Crelogix Credit Group Inc
Crelogix Financial Corporation
Crelogix Capital Corporation
Crelogix Leasing Corporation
Crelogix Investment Corporation
Crelogix Acceptance Corporation
Travelers Acceptance Corporation
Crelogix Portfolio Services Corporation
Crelogix Advisior Services Corporation

Web Sites Governed by this Privacy Policy
The Web sites that are governed by the provisions and practices stated in this privacy policy are:
www.crelogix.com

Other Web sites

Crelogix Web sites may contain links to other third party sites that are not governed by this privacy policy. Although we endeavour to only link to sites with high privacy standards, our privacy policy will no longer apply once you leave Crelogix websites. Additionally, we are not responsible for the privacy practices employed by other third party websites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.

This Privacy Policy Agreement was last Updated on October 20th, 2007.