Last updated: 27 November 2019

Your privacy is important to Capital Approvals. This Privacy Policy explains how Capital Approvals collects, uses, discloses and retains personal information, including information collected by Capital Approvals through websites and telephone calls and when providing products or services.

01. Your Consent

By providing Capital Approvals with your personal information, you consent to the collection, use, disclosure and retention of that information by Capital Approvals in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to Capital Approvals, but then you might not be able to proceed with your intended interactions or transactions with Capital Approvals or otherwise receive the full benefit of Capital Approvals’ products and services.

02. Personal Information

In this Privacy Policy, “personal information” means information about an identifiable individual, such as an individual’s name and email address, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.

03. Information That Capital Approvals Collects

(a) Information You Provide
You may be asked to voluntarily give your personal information to Capital Approvals when you interact, orally, in writing or by electronic transmission, with Capital Approvals, including when you apply for an account or membership, subscribe to a newsletter, register to receive information, apply or register for or order a product or service offered by Capital Approvals or use a product or service provided by Capital Approvals. In those circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with Capital Approvals or otherwise receive the full benefit of the desired product or service. Telephone calls between you and Capital Approvals will be recorded to ensure accuracy and quality assurance, and may be disclosed to third parties to verify Capital Approvals is compliant with its contractual obligations to third parties. You can choose not to have the telephone call recorded, and communicate by writing or electronic transmission.

(b) Automated Collection
Capital Approvals may automatically collect certain information regarding your use of the Capital Approvals’ website or online service, such as the dates and times that you access the website or online service, the browsers, operating systems, software and devices that you use to access the website or online service and details of your use of the website or online service.

Capital Approvals’ websites, online services, email messages and advertisements may use technologies (e.g. cookies, web beacons, tokens, pixels or tags) to collect information that assists Capital Approvals to improve its products, services, customer communications and advertising and to prevent fraud. Capital Approvals may use information that it collects through technological means to recognize you as a user of the Capital Approvals’ websites or online services, to facilitate and improve your use of the Capital Approvals’ websites or online services, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of a website or online service. More information about cookies used for interest-based advertising is set out in section 4(c) below.

Much of the information that is automatically collected by technological means is non-personal information (because the information does not identify you), and Capital Approvals will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

(c) Credit Reports
When you apply or register for, order or use certain products or services from Capital Approvals (e.g. application for credit, finance a car purchase), Capital Approvals may obtain your credit score and related information from a credit reporting agency to process or fulfill the transaction. Capital Approvals may continue to periodically obtain your credit score and related information from a credit reporting agency to update your confidential profile for use by Capital Approvals as set out in this Privacy Policy. Upon your request we will inform you if we have ordered such a report or reports, and will give you the name and address of the credit reporting agency that furnished the report or reports.

You also acknowledge and agree that any dealers or other persons or organizations to which we have disclosed your personal information in accordance with this Privacy Policy, may request a credit report for any legitimate purpose associated with your application [for credit, extending credit, modifying the terms of your credit agreement, or collection on your account.]

(d) Information Regarding Referred Transactions
If Capital Approvals refers you to an independent business (e.g. a car dealer, lender or credit card company) for a proposed transaction (e.g. a car purchase, loan or credit card), then Capital Approvals may collect from that independent business information regarding the transaction to update your confidential profile for use by Capital Approvals as set out in this Privacy Policy.

04. How Capital Approvals Uses Personal Information

(a) General
Capital Approvals uses your personal information collected by Capital Approvals for purposes relating to or arising from your relationship and transactions with Capital Approvals and as otherwise set out in this Privacy Policy or permitted by applicable law, including:

to administer your relationship with Capital Approvals, including to create and manage your account or membership with Capital Approvals and to contact and correspond with you regarding those matters;
to facilitate your interactions and transactions with Capital Approvals, including to process your applications, requests, orders and payments;
to provide products and services to you;
to process and respond to your inquiries, requests and other communications;
to provide you with information (including by email and other electronic messages) regarding Capital Approvals and its products and services and related products and services offered by other businesses, to the extent permitted by applicable law;
to administer and facilitate your participation in contests and promotions related to Capital Approvals;
to maintain, protect and improve Capital Approvals’ products and services and to develop new products and services;
to protect and enforce Capital Approvals’ legal rights, interests and remedies and to protect the business, operations and customers of Capital Approvals or other persons; and
to assist Capital Approvals to collect, use, disclose and retain your personal information in accordance with this Privacy Policy.

(b) Capital Approvals
Capital Approvals may share your personal information with independent dealerships, and Capital Approvals may develop, maintain and share a confidential profile for you for use by Capital Approvals to provide information, products and services to you, to facilitate your dealings with Capital Approvals and as otherwise set out in this Privacy Policy.

(c) Interest-Based Advertising
Capital Approvals may use interest-based advertising services (sometimes called “re-marketing” or “re-targeting”) provided by third party vendors (such as Google and Facebook) to display advertisements on third party websites and social media sites visited by users of Capital Approvals’ website. Advertising vendors (such as Google and Facebook) use cookies, pixels or tokens – unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses Capital Approvals’ websites – to display ads based on the computer’s past access to Capital Approvals’ websites. You can opt-out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt out of a re-marketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page.

05. How Capital Approvals Discloses Personal Information

(a) General
Capital Approvals discloses your personal information for purposes relating to or arising from your relationship and transactions with Capital Approvals and as otherwise set out in this Privacy Policy or permitted by applicable law.

(b) Specific Consents
Capital Approvals may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with Capital Approvals.

(c) Referred Transactions
If Capital Approvals refers you to an independent business (e.g. a car dealer, lender or credit card company) for a proposed transaction (e.g. a car purchase, loan or credit card application), then Capital Approvals may disclose your personal information (including your credit score and related information) to the independent business to facilitate the proposed transaction. Capital Approvals has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the independent business, and the use, disclosure and retention of the disclosed information by the independent business is not subject to this Privacy Policy.

(d) Suppliers and Service Providers
Capital Approvals may disclose your personal information to its suppliers and service providers (including fraud prevention services and payment processors) to assist Capital Approvals in the provision of information, products and services to you, to provide services to Capital Approvals, to assist Capital Approvals to use your personal information as set out in this Privacy Policy and as otherwise permitted by applicable law.

(e) Law Enforcement/Legal Disclosures
Capital Approvals may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. Capital Approvals may disclose your personal information to law enforcement agencies or other independent organizations if Capital Approvals reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if Capital Approvals reasonably believes the disclosure is necessary or appropriate to protect and enforce Capital Approvals’ legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of Capital Approvals or other persons (including to detect and prevent fraud and other illegal activities, enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of the Capital Approvals’ products or services). Capital Approvals has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the agencies, independent organizations or other persons to whom Capital Approvals discloses the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.

(f) Business Transactions
Capital Approvals may disclose your personal information in connection with a proposed or actual business transaction in which Capital Approvals is involved (such as a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of the Capital Approvals’ business or assets), but Capital Approvals will require the information recipient agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

06. Location of Personal Information

Capital Approvals and its service providers may process, store and use your personal information at facilities in various countries, including Canada, the United States of America and one or more countries in Europe or Asia. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing your personal information to Capital Approvals, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.

07. Retention of Personal Information

Capital Approvals retains your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with Capital Approvals’ legal obligations or enforce or protect Capital Approvals’ legal rights, or a longer period required or permitted by applicable law. Capital Approvals will delete or dispose of your personal information when Capital Approvals is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy.

08. Protection of Personal Information

Capital Approvals uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in Capital Approvals’ possession or under Capital Approvals’ control to help protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. Nevertheless, security risks cannot be eliminated and Capital Approvals cannot guarantee that your personal information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy.

09. Accuracy and Access to Personal Information

Capital Approvals will rely on you to ensure that your personal information that you provide to Capital Approvals is as accurate, complete and up to date as necessary for the purposes for which Capital Approvals uses the personal information. You will promptly notify Capital Approvals of any changes to your personal information using the procedures made available for that purpose by Capital Approvals or by contacting Capital Approvals’ customer service.

You may reasonably request access to your personal information collected by Capital Approvals and information about Capital Approvals’ use, disclosure and retention of that personal information by submitting a written request to Capital Approvals’ Chief Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and to have the information revised as appropriate. You may be required to pay a reasonable fee for access to your personal information. Capital Approvals may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.

10. Non-Personal Information

Capital Approvals creates and collects non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. Capital Approvals may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then Capital Approvals will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined.

11. Other Websites and Businesses

Capital Approvals’ websites and correspondence (including emails and messages) may include advertisements for products and services (e.g. car sales, personal loans and credit cards) offered by independent businesses (that may have a financial relationship with Capital Approvals) or links to websites operated by independent businesses (e.g. car dealers, lenders and credit card providers). Capital Approvals has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure and retention of your personal information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service or business.

12. Other Matters

(a) Disclaimers, Liability Exclusions/Limitations and Disputes: The agreements (including any subscription agreement, membership agreement or terms of service or use) that you accept when you apply, register for, order or use Capital Approvals’ products or services contain important provisions, including provisions disclaiming, limiting or excluding the liability of Capital Approvals and other persons (including service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or Capital Approvals’s collection, use, disclosure and retention of your personal information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

(b) Changes to this Policy: Capital Approvals may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on the Capital Approvals’ website. Capital Approvals’ collection, use, disclosure and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with Capital Approvals after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your personal information as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.

(c) English Language: You and Capital Approvals have each expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language. Les parties conviennent et exigent expressement que cette Politique de Confidentialité et tous les documents qui s’y rapportent soient rédigés en anglais.

(d) Contacting Capital Approvals’ Chief Privacy Officer: If you have any comments or questions about this Privacy Policy or how Capital Approvals deals with your personal information, please contact Capital Approvals’ Chief Privacy Officer by mail or email at: Capital Approvals – Chief Privacy Officer, P.O Box 54, Stittsville, Ontario, K2S 1A2; email: info@capitalapprovals.com.