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ROGERS BANK PRIVACY POLICY 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. Introduction What types of personal information does Rogers Bank collect? Why does Rogers Bank collect my personal information? How does Rogers Bank collect my personal information? Does Rogers Bank use cookies, web beacons, or other web technologies to collect information? How does Rogers Bank use my personal information? Will Rogers Bank share my personal information with third parties? How does Rogers Bank protect my personal information? How does Rogers Bank maintain the accuracy of my information? How can I access my personal information that is retained by Rogers Bank? How do updates to this Privacy Policy impact me? What laws or principles govern Rogers Bank’s privacy practices? Who is responsible for Rogers Bank’s privacy practices? How can I contact you? 1. Introduction At Rogers Bank, we are committed to protecting your privacy and ensuring the security and integrity of the personal information you entrust to us. This Privacy Policy explains how we collect, use, share and safeguard your personal information. We encourage you to read this Privacy Policy carefully, since it will govern how your personal information is treated by Rogers Bank. In particular, by providing your personal information to Rogers Bank, you signify your consent to this Privacy Policy. In this Privacy Policy, “we”, “us”, “our”, and similar terms refer to Rogers Bank. The term “personal information” refers to information that can identify an individual directly or through other reasonably available means. “Rogers Group of Companies” refers to Rogers Communications Inc., its subsidiaries, and all of their affiliates and related companies, excluding Rogers Bank. 2. What types of personal information does Rogers Bank collect? Rogers Bank, directly or through its agents, representatives, service providers or other third parties, may collect various types of personal information about you over the course of our relationship with you, such as: Information that establishes your identity, such as your name and birth date; Contact information, such as your email address, mailing address, and phone number; Information relating to the transactions you make through us or others; Information you provide on an application for our products or services, such as your annual income, place of employment, and financial obligations; Information about your financial behaviour, such as information about your payment history and credit worthiness; Information about any of the products or services you receive from members of the Rogers Group of Companies; or Other information obtained with your consent, or collected as permitted or required by law. We limit our collection of personal information to only that information which is reasonably necessary to fulfill an identified purpose. The types of information that we collect in a particular circumstance will depend on the context in which the information is collected. 3. Why does Rogers Bank collect my personal information? We may collect your personal information for a number of reasons, including: To establish, confirm or authenticate your identity, or to ensure we have correct and upto-date information about you; To evaluate an application for any of our products or services; To assess eligibility for any of our products, services, offers or contests; To provide products, services, or offers to you, or process any loyalty credits or rewards; To open, administer or service an account, or to deliver, bill for, and collect payment for any of our products or services; To allow you to participate in our contests and for the administration of those contests; To obtain credit information about you, manage credit risk, undertake debt collection activities, or provide information about your credit behaviour to credit reporting agencies or other parties collecting outstanding debt; To manage business risks; To evaluate an application for employment or other work with Rogers Bank; To market products, services or offers to you, including those offered by our agents or dealers, members of the Rogers Group of Companies, or other companies; To meet legal or regulatory requirements, including “know your customer” and antimoney laundering requirements; -2- To detect, manage, investigate or prevent fraud, money laundering, or other unauthorized or illegal activities; To monitor your compliance with any of your agreements with us; To facilitate our communications with you, including to provide you with newsletters, surveys, electronic messages or information you may request from us; To understand your needs, provide a positive customer experience or manage your overall relationship with us; To perform analytics, administer surveys, or request feedback from you in order to improve or manage our relationship with you; or For other purposes as may be identified from time to time, either prior to or at the time of collecting your information, or as permitted or required by law. We will only collect personal information that is reasonably necessary to fulfill the identified purpose. The choice to provide Rogers Bank with your personal information is always yours; however, your decision to withhold particular information may limit our ability to provide you with our products, services or offers. 4. How does Rogers Bank collect my personal information? We obtain most of your personal information directly from you, whether in person, over the phone, by mail, or over the Internet. On occasion, we may collect personal information about you from third parties, such as from those who are authorized by you to disclose your personal information to us, from credit bureaus, from references you provide, from members of the Rogers Group of Companies, from government or financial institutions, or from public sources or records. Communications between you and our representatives, such as telephone calls with our customer service lines, may be monitored or recorded in order to maintain quality service, to protect you and Rogers Bank, to confirm our discussions with you, or for training purposes. We may also use surveillance, such as videotaping, for in-person interactions with you for the safety of our customers, employees and others, to protect against illegal activity, such as theft, vandalism and fraud, or to ensure we are providing you with quality service. We will only collect your personal information with your consent or as otherwise permitted or required by law. Consent may be either implied or express. If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know as soon as possible (see the “How can I contact you?” section below). 5. Does Rogers Bank use cookies, web beacons, or other web technologies to collect information? Rogers Bank may use certain web technologies, such as web beacons and cookies, to enhance your experience on Rogersbank.com, to assess the value of our communications to you, or to deliver content that is specific to your interests. -3- Web beacons are tiny graphic images that we may embed on website pages or in emails to allow us to measure response rates to our communications and ascertain whether content has been accessed. We use the information discovered by web beacons to improve our web pages and promotions. Cookies are small files created by a web server and stored on a user’s computer to help websites remember certain information about the user. Cookies collect, encrypt and store information so as to record user preferences and enhance the user experience. For example, Rogers Bank uses cookies on RogersBank.com to record language preferences and to let users avoid logging-in repeatedly while they are visiting our webpages. Please consult your browser’s online help function for information on how to tailor your cookie settings to suit your needs. When you submit an application or transaction at RogersBank.com, we may collect, use and disclose your IP address or device attributes for validation purposes, to log requests to the server, or to detect, manage, investigate or prevent fraud, money laundering, or other unauthorized or illegal activities. 6. How does Rogers Bank use my personal information? Rogers Bank uses your personal information to fulfill the purposes identified prior to or at the time of collection, including those purposes identified in this Privacy Policy. Your personal information may also be anonymized or aggregated with that of others, to enable us to manage our business, identify trends, develop statistical information, understand how we are performing, or develop relevant products, services or offers. Any anonymized or aggregated information will not identify you personally, and so will not be subject to this Privacy Policy. 7. Will Rogers Bank share my personal information with third parties? Rogers Bank may share your personal information with third parties, as follows: a) To provide you with products or services In order to evaluate an application for our products, services, or offers, or over the course of our relationship, we may disclose your personal information to credit bureaus, credit reporting agencies, or to your current or future creditors to determine your credit worthiness, to determine or maintain your credit history, or to obtain credit references. From time to time, we may disclose your credit history with us to other lenders or credit reporting agencies in order to support the credit process. We may also disclose your personal information to outside agents, contractors, or services providers performing certain services on our behalf or for our benefit, including website maintenance, marketing, mail distribution, customer service or data processing. We provide these parties only with the limited information that is necessary to perform the services, and we contractually hold them to privacy standards that are consistent with this Privacy Policy and applicable legal requirements. Our service providers or other parties with whom we share information may be located outside of Canada. As a result, your information may be securely used, stored or accessed in foreign jurisdictions and subject to the laws of those jurisdictions. -4- b) To comply with the law Your personal information may be disclosed in situations where we are legally required to disclose it, such as in relation to a criminal investigation or in connection with government reporting requirements. In some instances, we may also be required to disclose your personal information to authorities, such as in response to a search warrant, court order or other demand or inquiry. In those cases, only the information specifically requested is disclosed, and we take precautions to satisfy ourselves that the authorities in question have legitimate grounds to request your information. c) To protect you Where we reasonably believe you might be a victim of fraud, financial abuse, or other illegal activity, we may disclose your personal information to appropriate legal or governmental authorities, to your next of kin, or to any other appropriate person. d) To protect us We may release your personal information to another person or organization, including members of the Rogers Group of Companies or any investigative body, to protect our rights, assets, or interests. For example, we may share your personal information with another person or organization: where we are involved in a judicial, administrative or regulatory proceeding, or similar process involving the enforcement of any of our rights; in order to comply with any legal or regulatory obligations (e.g. subpoena, warrant, or judicial or administrative order or demand); to prevent, detect, investigate or suppress financial abuse, fraud, money laundering, or other criminal or illegal activity; to manage credit risk or other business risks; or to undertake debt collection activities. e) In the context of a business transaction We may share your personal information with third parties in the context of a proposed or actual business transaction, such as a sale or other disposal of all or part of our business or assets, for purposes of evaluating or performing the transaction. These purposes may include, as an example, permitting parties to the transaction to determine whether to proceed or continue with the transaction. We require that the confidentiality of your personal information be preserved, and we limit use of your personal information to the purposes of evaluating or performing the transaction. In the event the transaction does not go through, we will require, by contract, the other parties to the transaction not to use or disclose your personal information in any manner whatsoever, and to return or destroy such personal information. Any of our successors or assigns will be permitted to collect, use and disclose your personal information for substantially the same purposes as those set out in this Privacy Policy. -5- f) To members of the Rogers Group of Companies Unless you opt out by contacting our Chief Privacy Officer (see the “How can I contact you?” section below), Rogers Bank may engage with members of the Rogers Group of Companies to determine whether you are a customer of the Rogers Group of Companies. If we know that we share you as a customer, then Rogers Bank and the Rogers Group of Companies are able to offer you a more seamless and meaningful customer experience. If you are a customer of both Rogers Bank and any member of the Rogers Group of Companies, then, unless you opt out by contacting our Chief Privacy Officer, Rogers Bank may share your personal information with members of the Rogers Group of Companies so that Rogers Bank or any member of the Rogers Group of Companies may: confirm or authenticate your identity; confirm that your information is correct and up-to-date; market or not market, as the case may be, certain products, services or offers to you; provide certain products, services or offers to you; fulfill any special offers; perform analytics or conduct market research; better understand your needs; or process loyalty credits earned through credit card usage as part of a rewards program. Personal information that is shared with Fido Solutions, operated by Rogers Communications Canada Inc., will be subject to the privacy policy, available at www.fido.ca/consumer/terms/privacy-policy. Personal information that is shared with chatr mobile will be subject to the privacy policy, available at www.chatrwireless.com/web/content/support_policy. Personal information that is shared with Cityfone, operated by Rogers Communications Canada Inc. or any of its subsidiaries or affiliates, will be subject to the privacy policy, available at www.cityfone.net/terms/privacy-policy. Personal information that is shared with any other member of the Rogers Group of Companies will be subject to the privacy policy available at www.rogers.com/web/content/Privacy-CRTC. Except with your consent or as otherwise permitted or required by law, Rogers Bank will not disclose the following information to members of the Rogers Group of Companies: your social insurance number; your employment information (e.g. employment status, occupation, employer name); your income particulars; your credit limit particulars; or your transaction level information. g) Other Rogers Bank may also disclose your personal information as follows: to a person who, in our reasonable judgment, is seeking your personal information as your agent; with your consent; or as otherwise required or permitted by law. 8. How does Rogers Bank protect my personal information? Rogers Bank takes the protection of your personal information very seriously. Access to private, sensitive and confidential information, including your personal information, is restricted to authorized employees, service providers, representatives or agents with legitimate business reasons, who have been made aware of the importance of keeping your information confidential. We protect your information with appropriate safeguards and security measures. Your personal information may be stored or processed in or outside Canada. Your personal information will at all times be protected with appropriate safeguards; but, if your personal information is stored outside of Canada, it may be subject to the laws of the jurisdiction where it is held. To ensure that your personal information is protected, we use security safeguards that are consistent with the industry standard. We use modern technologies to ensure that your personal information is not compromised. Paper-based files are stored in locked filing cabinets to which -6- access is also restricted. When you speak with any of our customer service representatives, you will be required to verify your identity. Except as otherwise permitted or required by law, we only retain your personal information for so long as it is reasonably necessary to fulfil the purposes for which it was collected, or for sufficient time to allow you access to the information if it was used to make a decision about you, your account, or your relationship with Rogers Bank. Once we no longer require your personal information, it will be destroyed or de-identified. 9. How does Rogers Bank maintain the accuracy of my information? We make every reasonable effort to keep your personal information as accurate, complete and upto-date as necessary for the purposes for which it is used. However, we also rely on you to proactively inform us when your information changes or if there is an error with the personal information associated with your account. Should you identify any incorrect or out-of-date information, or should you wish to verify the accuracy of the information we have about you, please contact us (see the “How can I contact you?” section below). We will make any necessary updates on a timely basis; and, in the event that inaccurate information is mistakenly disclosed to a third party, we will communicate relevant changes to the third party where appropriate. 10. How can I access my personal information that is retained by Rogers Bank? If you are a Rogers Bank customer, much of your information is available to you through your account statements. If you wish to review the personal information we have on you, please feel free to contact our Chief Privacy Officer (see the “How can I contact you?” section below). To avoid any delays in obtaining your information, please identify yourself in your request and describe, in sufficient detail, the types of information you are requesting. We will get back to you within 30 days and we will advise you in advance of any fees associated with our retrieving or providing you with your information. Please note that access to some information may be restricted as permitted or required by law. For example, information may not be provided if it includes references to other persons, is subject to privilege, is confidential or proprietary to Rogers Bank, or is subject to an investigation. 11. How do updates to this Privacy Policy impact me? Rogers Bank may change, modify, add, or remove portions of this Privacy Policy at any time. We will post any revised Privacy Policy to rogersbank.com/privacy. Your continued interaction with Rogers Bank following any changes to this Privacy Policy will constitute your acceptance of this Privacy Policy as revised. We encourage you to review this Privacy Policy regularly so that you understand our ongoing privacy practices. 12. What laws or principles govern Rogers Bank’s privacy practices? Rogers Bank’s privacy practices are in accordance with all applicable federal and provincial laws and regulations. In particular, we are compliant with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. -7- 13. Who is responsible for Rogers Bank’s privacy practices? Rogers Bank has appointed a Chief Privacy Officer who oversees Rogers Bank’s privacy compliance. Other individuals within Rogers Bank may be delegated to act on behalf of the Chief Privacy Officer and take responsibility for day-to-day compliance with applicable privacy legislation and Rogers Bank’s collection, use, or disclosure of personal information. 14. How can I contact you? If you have any questions or concerns about this Privacy Policy or Rogers Bank’s privacy practices, or if you would like to submit an access request, please contact our Chief Privacy Officer: Email: [email protected] Or write to: Rogers Bank, Attention: Chief Privacy Officer 350 Bloor Street East, Toronto, Ontario M4W 0A1 If any question or concern is not answered to your satisfaction by our Chief Privacy Officer, you may contact the Rogers Bank Ombudsman: Email: [email protected] Fax: 416-935-6304 Or write to: Rogers Bank, Attention: Ombudsman 350 Bloor Street East, Toronto, Ontario M4W 0A1 If your privacy concerns are not addressed to your satisfaction by Rogers Bank, you may contact the Office of the Privacy Commissioner of Canada for further guidance: Phone: 1-800-282-1376 (toll free) or 819-994-5444 Fax: 819-994-5424 TTY: 819-994-6591 Website: www.priv.gc.ca Or write to: Office of the Privacy Commissioner of Canada 30 Victoria Street Gatineau, Quebec K1A 1H3 -8-