Fidem Privacy Policy

Our commitment to Privacy

Effective Date: October 31, 2024

Fidem Finance Inc. (Fidem Finance) is committed to maintaining the accuracy, confidentiality and security of your personal information. We value the trust you have placed in us and wish to provide assurance that nothing is more important to us than the security and appropriate use of your personal information.

We encourage you to read this Privacy Disclosure so that you can better understand how we collect, use, share and protect your personal information. If you have any questions or concerns about your privacy rights or how we manage your personal information, please contact our Customer Service department by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If our Customer Service department is unable to help you, please contact our Privacy Officer using the contact information below. If you remain dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

The handling and protection of personal information is covered by the Federal Personal Information Protection and Electronics Act (PIPEDA) and the Personal Information Protection Acts (PIPA) in British Columbia and Alberta. Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation'.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Fidem Finance any obligations outside of, or in addition to, any obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Disclosure and Canada's federal and provincial privacy laws, as applicable, this Disclosure shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

This policy applies for as long as we hold your information, including after the end of our business relationship and in accordance law and Fidem’s retention policy. By giving us your information, you consent to the collection, use and sharing of your information as described in this policy.

Revisions

From time to time, Fidem Finance may make changes to our Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. Any changes that affect your rights will be communicated to you via this Disclosure and posted on our website. We encourage you to refer back to it on a regular basis.

Accountability

We are responsible for the information in our custody as well as information transferred to a third party for processing on our behalf. We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Email: privacy@fidemfinance.ca
Ph: 1-855-220-7531
Mailing Address: Station B, P.O. Box 53, London, Ontario, N6A 1V3

What is personal information

Personal information is any factual information about an identifiable individual such as contact information, account numbers, or details including, but not limited to age, marital status, income, date of birth and credit history. Personal information does not include information such as a person's business title or business contact information when used or disclosed for the purpose of business communications.

What we collect and how we collect It

We collect personal information about you in order to:

  • Confirm your identity
  • Determine your eligibility for our products and services
  • Understand and assess your ongoing creditworthiness, financial and other requirements and to determine your eligibility or suitability for products or services offered by us
  • Recommend the best products and services to suit your individual needs
  • Contact you by various methods, including mail, email, SMS message, and telephone
  • Provide updates to changes made or communicate important information about your account
  • Set up your accounts and provide ongoing service
  • To comply with legal, security or regulatory requirements
  • Protect you from error and fraud

This information we collect includes but not limited to:

  • Contact Information such as, name, address, telephone number and email.
  • Identification documents including government issued identification, utility bills, name, date and occupation
  • Credit and financial information such as your employment history, income sources, assets, liabilities, credit history, payment preferences and social insurance number (optional)1
  • Any additional information required in respect of a specific product or service that you have applied for.

We collect this information from a variety of sources, such as:

  • Information you provide to us over the phone and on applications or forms, such as your income and place of employment
  • Information from the original lender or previous collection company regarding your account we have purchased
  • Information about you from third parties that we engage with such as, credit bureau, regarding your credit history or employment status
  • Information about your transactions or experiences with companies associated with Fidem Finance

Consent

Fidem Finance will, in most instances, obtain your consent to collect, use or disclose personal information. The method to which the consent will be obtained will be applicable to the type of personal information being collected, used or disclosed. Fidem Finance will obtain your express consent (verbal, written or electronic) to collect, use or disclose personal information such as personal financial information.

Fidem Finance will rely on implied consent to collect, use or disclose your personal information where one (or more) of the following apply:

  • A customer relationship now exists;
  • Express consent was given previously for the same or similar use of personal information;
  • Where the intended use of the information is reasonably clear from the context in which it is obtained and you voluntarily provide the information.

We endeavour to obtain your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

Where we have obtained your personal information from third parties who have collected it in the course of performing a service for us or otherwise, we will take reasonable steps to ensure that such third parties have represented to us that they have your consent to disclose your personal information to us.

We may collect information about you without your knowledge or consent where permitted or required to by applicable law or regulatory requirements. Example, when government institution lawfully requests information or using technologies that monitor or record product use and interaction with Fidem through telephone or email.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer in writing using the contact information set out above. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.

Use and Disclosure of your Personal Information

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including third parties that assist Fidem Finance in the provision of services to you and third parties whose services we use to conduct our business. As such, we, or our business partners, may send you product information that we believe may be of benefit to you. You may opt out of receiving this information at any time.

We may share your personal financial information with:

  • Credit bureaus, credit reporting agencies and financial institutions to confirm your financial situation and your initial and ongoing eligibility for credit;
  • Persons retained to administer or service your account for the purpose of such administration or servicing;
  • Persons (or their permitted assignees) involved in or facilitating the financing of our business (which may include the administration or servicing of your accounts by them or their agents);
  • Other persons as necessary for the provision of credit services to you and the protection of any security interest in any loans we may have with you;
  • For the purposes described in this Privacy Policy;
  • As permitted or required by applicable law or regulatory requirements;
  • To comply with valid legal processes such as search warrants, subpoenas or court orders;
  • In order to administer or service your account or other credit product;
  • To protect the rights and property of Fidem Finance;
  • Debt collection activities on your account;
  • During emergency situations or where necessary to protect the safety of a person or group;
  • Where the personal information is publicly available; or
  • For any additional purposes for which we have obtained your consent

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

In some instances, Fidem Finance may engage the services of third parties or use resources or system of affiliates in jurisdictions outside of Canada. In the event our service provider or affiliate is located in a foreign jurisdiction they are bound by the laws of the jurisdiction in which they are located and may disclose personal information in accordance with those laws

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Fidem Finance or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Access to your Personal Information

Fidem Finance strives to keep your personal information accurate, up to date, and relevant for its intended use. You can assist us by updating your personal information with us (e.g. change of address) as changes occur.

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Customer Service department, and if our Customer Service department is unable to help you, please contact our Privacy Officer in writing using the contact information above.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Updating your personal information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please inform our Customer Service department of this change toll free at 1-800-259-1167. If our Customer Service department is unable to help you, please contact our Privacy Officer using the contact information above.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Security of your personal information

Fidem Financial endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. Our commitment is reflected in our policies, framework and practices to ensure compliance with applicable privacy and data protection laws and regulations. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Fidem Finance will take every necessary step to ensure the protection of your personal information including:

  • Shredding of documents containing personal information;
  • Physical security measures - restricted access to facilities and locked filing cabinets;
  • Electronic security measures for computerized personal information - password protection, database encryption, personal identification numbers;
  • Organizational processes and procedures including limiting access to your personal information to individuals on a need to know basis;
  • The requirement that third parties who are given access to your personal information protect and secure your personal information in similar manner.
  • Regularly auditing our security safeguards and assessing that they remain effective and appropriate

The Companies that work jointly with Fidem Finance are committed to protecting the security and integrity of customer information through procedures and technology designed for this purpose. For example:

  • Employee access to customer information is limited to those who need to know this information in order to service the customer relationships
  • The Companies that work jointly with Fidem Finance maintain policies and procedures covering the proper physical security of workplaces and records
  • The Companies that work jointly with Fidem Finance have established physical, electronics, and procedural safeguards to comply with federal standards regarding the protection of customer information
  • The Companies that work jointly with Fidem Finance require independent contractors and outside companies who work with us to adhere to our strict privacy standards
  • The Companies that work jointly with Fidem Finance use technological means (such as backup files, virus detection and eradication software, firewalls, and other computer software and hardware) to protect against unauthorized access or alterations to customer data.

Respecting and responding to your privacy concerns/complaints

Your privacy concerns matter to Fidem Finance. Should you have any questions or concerns about our handling of your private information, please contact our Privacy Officer at privacy@fidemfinance.ca or by calling 1-855-220-7531 and asking for the Privacy Officer.

If you are a Fidem Finance Credit Card holder and you have questions, concerns or complaint relate to our handling of your cardholder information, this information will be shared with Peoples Trust’s Privacy Officer. You also have the option to contact Peoples Trust Company directly by phone Monday to Friday from 8am to 4:30pm PT at 1-855-683-2881, or submit your complaint or inquiry through the form found on their website http://www.peoplestrust.com/en/about-us/contact/, or by mail at Peoples Trust Company, 1400 – 888 Dunsmuir Street, Vancouver, BC, V6C 3K4. Peoples Trust Privacy & Security Disclosure, as amended from time to time, is available online at https://www.peoplestrust.com/en/legal/privacy-security/.

If you are unsatisfied with our response you may refer your enquiry to the Privacy Commissioner in your jurisdiction. Please refer to our Complaint Procedures under "Legal" or follow this link https://www.fidemfinance.ca/resolving-your-complaints/.

1 We request your Social Insurance Number to assist us in verifying your credit history. However, you are not required to provide us with it when asked and not doing so does not disqualify you from being approved for any of our products.