|Information essential for fulfilling most requests and applications for our products and services includes:
- Information establishing your identity and meet our regulatory obligations for verification of identity, such as your name, address, phone number, date of birth, identity documents (e.g., driver’s license or documents verifying your name and address or your name and date of birth or your name and confirmation of a financial account), principal business or occupation, intended use of the funds of the account.
- Information to authenticate your identity when you contact us, such as knowledge-based information (e.g., date of birth, address, account number, social insurance number);
- Information you provide on an application for the provision of our products and services, such as your annual income, mortgage, account balances, financial liabilities, transaction history;
- Information you provide during communication with us which may include family details, life events, goals, and issues you may have encountered;
- Information related to transactions, arising from your relationship with and through us;
Information about financial behavior such as your payment history and credit worthiness to assess your eligibility for any credit product or loan; and
- Information pertaining to business clients such as your business name, business model (e.g., sole proprietorship, partnership, corporation) business address, business phone number, industry type, financial status, declaration of tax residence and detail(s) on the owner(s), director(s) and signing authority(ies).
Information we collect during our interactions with you
Over the Phone – We may monitor and/or record your telephone discussions with our representatives to enhance customer service and to confirm our discussions with you.
Through the Internet –When communicating with us through our web-site or social media, we may monitor and/or record our interactions and discussions to enhance customer service and to confirm our discussions with you.
Through Email – When you send us an email or when you ask us to respond to you by email, we obtain your email address and any information you have included in the email. We use your email address to acknowledge your comments and/or reply to your questions, and we may store your communication and our reply in case we correspond further.
For your protection, we recommend that you do not send confidential information or personal information via email unless you have encryption technology or are able to password protect your email or attached documents as email is not a secure method of communication.
We may obtain your consent to collect, use, disclose and share your information in different ways, depending on the situation and the sensitivity of the information.
Express consent may be obtained verbally, online or in writing from you (e.g, our application forms and agreements you enter into). Implied consent may be obtained through your use of a product or service, or when you approach us to obtain information, inquire about or apply for products, or services from us.
There are limited situations permitted by privacy legislation or required by law where we may be required to disclose personal information without your knowledge or consent (e.g., disclosure to a government institution that has made a request for the information, identified its lawful authority to obtain the information and indicated that the disclosure is requested for the purpose of enforcing legislation).
Under no circumstances do we ever sell any customer personal information. Also, we do not release information to others, including spouses, relatives or friends, without your written authorization.
Access to your information is restricted to authorized employees who have a legitimate business purpose for using it. For example, when you call us or visit our office, designated employees will access your information to verify that you are the account-holder and to assist you in fulfilling your financial requests.Unauthorized use and/or disclosure of client information by an employee of Polaris is strictly prohibited. All employees are required to maintain the confidentiality of client information at all times.
Polaris’s referral partners, service partners, or agents who act on our behalf
We may be required to provide reports to referral partners or agents who we have engaged to act on our behalf. We only provide the information necessary to fulfil our contractual referral or agency obligations and we require them to protect the information in a manner consistent with our privacy policies and security practices. Referral partners or agents are generally organizations that you have a primary relationship with.
We may engage service partners to conduct administration processes on our behalf. We only provide the information necessary for them to perform the services they have been specifically engaged to undertake for us. We conduct due diligence respecting privacy and security when engaging with a new service partner and we contractually require them to protect the information in a manner consistent with our privacy policies and security practices.
Outside Service Suppliers
We may engage service providers to perform specialized services on our behalf such as software support or data hosting. We only provide the information necessary for them to perform the services they have been specifically engaged to undertake for us. We conduct due diligence respecting privacy and security when engaging with a new service partner and we contractually require them to protect the information in a manner consistent with our privacy policies and security practices.
Other Third Parties
We will only share your information with other third parties with your consent, as indicated under your account agreement and accepted terms and conditions, or under the following special circumstances where we are permitted by privacy legislation or required by law to disclose information without your knowledge or consent:
- To respond to valid and authorized information requests from domestic and international authorities;
- As permitted or required by law, to comply with laws, regulations, subpoena or court order;
- To protect the personal safety of employees, clients or other third parties on Polaris property; or
- To protect our assets and interests, to help us collect a debt owed to us by you, or to manage or settle any actual or potential loss in the case of a breach of agreement or contravention of the law.
Commitment to Security
|You have our commitment that we will treat your personal, business and financial information with the same standard of care as we treat our own confidential information of a similar nature. Polaris employs a diverse range of technologies and security safeguards to ensure the safety, confidentiality and integrity of your information and to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. We protect personal information regardless of the form in which it is held (e.g., hard or electronic copy).
Polaris employees understand the policies and procedures for protection of customer personal information. As a condition of employment, our employees are required to sign an Oath of Office and Confidentiality including a commitment to keep an individual’s personal information in strict confidence.
All third-party service providers that may have access to personal information held by Polaris are required to go through a due diligence process to ensure they can meet the same standards we adhere to when it comes to safeguarding your personal information. We also include obligations for privacy and security in our contracts with our third-party service providers. Our third-party service providers are monitored throughout the duration of the relationship to ensure that standards are being maintained.
Polaris has a Privacy Officer to address client and employee concerns and ensure that Polaris’s policy and procedure align with privacy requirements and our commitment to security.
The security of the confidential information we hold is important to Polaris and there are many controls in place, such as up-to-date information security policies, procedures, information management and technology service delivery, and enterprise architecture.
To further protect sensitive information, a security program is in place that includes physical facility access control, event management and audit, intrusion protection, virus protection, vulnerability scanning, as well as numerous other deterrent and detection methods.
Polaris periodically engages external information technology security-certified consultants to review internal controls and benchmark to industry standards. This process confirms that the security procedures and practices used by Polaris protect systems from potentially malicious activities. Additionally, this effort identifies opportunities to reinforce Polaris’ intrusion detection processes.
Polaris retains personal information only as long as necessary to provide the products and services you have engaged us for or for other legitimate purposes such as complying with our legal obligations, resolving disputes or enforcing our agreements.
|If you want to be informed of what personal information we hold about you, how we use it and who we may have disclosed it to, you may submit a written request for access to our Privacy Officer at:
Polaris Leasing Ltd.
Attention: Privacy Officer
Address: 2-396 Assiniboine Avenue, Winnipeg, Manitoba R3C 0Y1
Email address: email@example.com
To avoid delays in obtaining your information, please provide sufficient detail to permit us to identify you and the specific information you are requesting. Do not provide personal information in an email unless you are able to send it securely
In certain situations, we may not be able to provide access to all the personal information we hold about you or disclosures that were made (e.g., if we are restricted by law or the request falls within an exception in our governing privacy legislation). If this occurs, we will advise you of the reasons for the restriction subject to any legal or regulatory limitations.
If you think information, we have about you is incorrect or incomplete, you can ask for amendments or additions to your personal information. As we make decisions based on the information we have, we encourage you to help us keep your information current.