CANADIAN TIRE FINANCIAL SERVICES PRIVACY COMMUNICATION

RESPECTING YOUR PRIVACY RIGHTS

Canadian Tire Financial Services Limited and its wholly-owned subsidiary, Canadian Tire Bank, recognize the importance of your privacy rights. You trust us with your personal information, and we intend to earn that trust by treating your personal information with care. This Privacy Communication sets out the principles governing how we (Canadian Tire Financial Services Limited and Canadian Tire Bank) collect, use, disclose and safeguard personal information of our customers. These principles have been designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation and are consistent with the Canadian Tire Corporation, Limited Policy on Privacy of Customer Personal Information which governs the Canadian Tire family of companies¹.

In this Privacy Communication, we outline the reasons why we collect, use and share your personal information. We explain why, in some cases, our need to collect, use and share your personal information is essential to maintaining a business relationship with you and, in other cases, while it is not mandatory, it may be beneficial to you and is useful to us to be able to collect, use and share certain personal information. We list the types of organizations with which we share your personal information. And we provide our phone/fax numbers and mailing address should you wish to communicate with us in any way.

In several places, we provide practical and illustrative examples of the ways we collect, use and share personal information. While the examples are not exhaustive, we hope that they provide you with some insight into the way privacy protection is integrated into our business and operations.

What is Personal Information?

Personal information is defined in PIPEDA and corresponding provincial privacy legislation. Generally speaking personal information is information that refers to an individual specifically and includes such things as your name, address, age, income, date of birth, financial information and credit records but not information that typically appears on a business card or in public records.

OUR COMMITMENT TO YOUR PRIVACY IS GOVERNED BY THE FOLLOWING PRIVACY PRINCIPLES:

1. We are accountable to you

We are responsible for all personal information under our control, including any personal information that is transferred to third parties for processing, storage or other purposes.We have employees in each of our business units who are accountable for compliance with these privacy and security principles. We have appointed a Privacy Advisor who oversees implementation of privacy policies and programs within Canadian Tire Financial Services Limited and Canadian Tire Bank and reports to the Chief Privacy Officer of Canadian Tire Corporation, Limited. To contact our Privacy Advisor or the Chief Privacy Officer please see Contact Information section.

2. We let you know why we collect your personal information

We identify the purposes for which your personal information is collected. We do this before or at the time the personal information is actually being collected.

We collect, use and share your personal information in order to:
 
• identify you and process your application for a product or service;
• where applicable, assess and update your credit-worthiness on an ongoing basis;
• establish, maintain, service, process, analyze, and audit your relationship with us including collecting any money you owe us;
• protect all parties from error and fraud;
• administer the delivery of products and services to you;
• determine your eligibility for products and services;
• comply with legal and regulatory requirements; and
• with your consent, market and sell products and services that may be of interest to you.

Here are some examples of the types of personal information we require and how they relate to certain purposes. They may vary by products and services. They may also change over time. Information such as name, address, and date of birth, to identify you and process your application; information about your background (for example, occupation) and financial circumstances like assets, income, other financial commitments, to determine your eligibility for products and services; credit reports and other information to assess and update your credit worthiness; information about your transactions which may include details about how you use our products or services, and payment pattern for identifying credit risk, fraud risk, and suspicious activities and to fulfill regulatory obligations such as anti-money laundering and anti-terrorist financing regulations; your language preference and contact information including email address (if provided) to communicate with you; information on the reward program associated with your product to maintain, service, process, analyze and audit your account. Depending on the product, certain information is required by law. For example, your name, address, date of birth,employment information and details of government issued documents like a passport are required under anti-money laundering and anti-terrorist financing regulations and social insurance number (SIN) is required for reporting purposes under the Income Tax Act.

We collect personal information from various sources including: from you directly when you complete an application or other forms, respond to our customer surveys, or call us; from others with your consent (if required) such as your employer and other references you provided, credit bureaus/consumer reporting agencies and other financial institutions; from your transactions and your use of our products and services; and other sources permitted by law such as public records.

A Note on Social Insurance Number

Your SIN is required for reporting purposes under the Income Tax Act and is mandatory when you apply for products such as a deposit account or GIC.

We may also ask for your SIN for other purposes. However, providing SIN for these other purposes is optional. Credit bureaus/consumer reporting agencies use SIN to distinguish you from others with a similar name and your SIN provides us with more accurate credit bureau/consumer reporting agency information. As such, if you prefer not to provide your SIN, the approval of your application and/or your credit limit may be affected. We do not penalize you just because you choose not to disclose SIN for these other purposes. If provided it is used to ensure the accurate and timely exchange of information with credit bureaus/consumer reporting agencies.

A Note on Call Monitoring

In order to provide exceptional customer service, we coach our customer service representatives on an ongoing basis. It is important for us to understand how our representatives are handling calls and the questions they may encounter. As such, if you have a telephone conversation with our representatives, we may monitor the call for coaching and quality control purposes. However, certain calls will be recorded for record keeping purposes. For example, your call will be recorded and retained when you apply for a product or service, or consent or authorize us to activate or enroll you in a product or service by phone.

3. We obtain your consent to collect, use or disclose your personal information

We obtain your consent to collect, use or share personal information.

Consent may be given by your authorized representative. If you are a primary cardholder and have requested supplementary card(s) you represent that you have all necessary authority and/or have obtained all necessary consent from the individual(s) for the additional card(s) to provide us with the information for this purpose.

There are certain circumstances where the law permits or requires that we collect, use or share your personal information without your consent. For example, we may collect, use or share your personal information to investigate a breach of an agreement or a law, or in response to a valid demand, search warrant or other legal enquiries; to realize on security pledged for a loan, or to investigate or deter fraud. We may also collect, use and share information in public telephone directories where the subscriber can refuse to be listed for marketing, customer service or collection purposes.

The way in which we seek consent may vary, depending on the type of personal information and the purpose. For example, we will obtain your consent for credit reports verbally when you apply for a credit product or service by phone, in writing when you sign an application or electronically when you apply online. We may also rely on your actions or your choice not to act for consent. For example, we will assume you want to hear about new products and services and other offers such as contests, customized balance transfer or convenience cheque offers for cardmembers, if you have not asked to be removed from our marketing lists.

Subject to legal and contractual requirements, you may withdraw or change your consent at any time with reasonable notice. For example, you may refuse or withdraw your consent for marketing as described in the Marketing section.

There is certain personal information that we require in order to provide and subsequently service the products or services you have requested.

We require your personal information in order to properly service your account, to provide the products or services that you have requested, or to establish and/or maintain an ongoing business relationship including matters that are essential to the management of our businesses. For instance:
 
• In order to prepare and send you a monthly statement for your card account, we need to match your name and address to your monthly transactions.
• We will be unable to administer the delivery of your products or services if you do not allow us to share your personal information with our processing and data storage partners. It is also worth noting that there is a close relationship between Canadian Tire Financial Services Limited and Canadian Tire Bank. The following are just two illustrations of this relationship: (i) Canadian Tire Financial Services Limited operates a customer call centre that provides call centre services to Canadian Tire Bank. As such, if you do not allow Canadian Tire Bank to share your personal information with Canadian Tire Financial Services Limited, we cannot maintain our business relationship with you. (ii) The monthly charges for certain insurance products sponsored by Canadian Tire Financial Services Limited are directly related to the balance on a customer’s account. In order to calculate the appropriate monthly charges for these products, Canadian Tire Bank must provide to Canadian Tire Financial Services Limited the monthly balance on your accounts. If you do not permit this sharing of personal information between these two businesses, we will be unable to offer these products to you.
• From time to time, your personal information may be used by us and/or shared with parties connected with certain business transactions, including the proposed or actual financing, securitization, guarantee, insuring, sale, assignment or other disposal of all or part of our business or assets, for the purposes of evaluating and/or completing the business transactions.
• If you are requesting a credit-related product or service, we will require a credit bureau report on you to determine your credit-worthiness and the appropriateness of granting you credit and we may continue to do so, from time to time, to update your credit-worthiness in order to administer the credit facility or loan. The credit/consumer reporting system relies on the accuracy and completeness of the information provided to credit bureaus/consumer reporting agencies. As such, during the term of a credit facility or loan, we must continue to collect, use, or share your personal information with the credit bureaus/consumer reporting agencies to support and maintain the integrity of the credit/consumer reporting system. However, if an account is closed voluntarily with no balance remaining on the account, we will stop providing the account information to the credit bureaus.
• Canadian Tire Bank is required by law to know its customers and to verify the identity of its customers before entering into a business relationship or opening an account. Canadian Tire Bank uses third parties including credit bureaus/consumer reporting agencies for these purposes. If you refuse to provide consent, it cannot enter into a business relationship with you or open an account.

Marketing

It is our common practice to notify applicants and customers of discounts and new products they might enjoy. These offers may include products and services from the Canadian Tire family of companies or other selected companies. For example, when you apply for a particular product or service and are not approved, we may offer you another product or service that we feel you might appreciate, and we tell our customers about new ways they can earn Canadian Tire ‘Money’ On The Card awards. The Canadian Tire family of companies is a growing network of interrelated businesses offering a unique mix of products and services. One way to ensure exceptional customer service and provide additional value is to share customer information across the various businesses. For example, where legally permitted, members of the Canadian Tire family of companies may work together to develop joint customer promotions, customer surveys or contests. Moreover, we occasionally use purchase data to develop individual marketing programs. If you do not want us to include you in these marketing programs, please let us know.

• Opt-out of Marketing

You may decide that you do not want your personal information used or shared for marketing purposes. If this is the case, you may always withdraw or refuse your consent at any time by calling us toll-free at 1-866-846-5841. You request will be promptly processed but may not be in time to remove you from promotions already in progress.

• The consequences of withdrawing or refusing consent

You should be aware that if you decide to withdraw or refuse your consent, our ability to communicate with you will be diminished. For example, we will generally not be able to tell you about price discounts, innovative reward programs, customized balance transfer offers, contests, or other products and services that we may introduce in the future.

4. We limit collection of your personal information

We collect only the personal information required to provide products and services to you. If the personal information we require is collected for a reason other than to provide products and services, your consent will be obtained before or at the time the information is collected. We will collect personal information only by clear, fair and lawful means.

5. We limit use, disclosure and retention of your personal information

We use and disclose your personal information only for the purposes it was collected.

We retain your personal information only so long as it is required for the purposes it was collected or as required by law.

Sharing your personal information

We do not sell or rent personal information to any organization or person for any reason.

We only share your personal information with third party organizations for the purposes identified to you and with your consent or as required or permitted by law. If your personal information is shared with third parties, these third parties are bound by appropriate agreements to secure and protect the confidentiality of your personal information.

Here are examples of why we share personal information and the type of organizations we share with:

i. To administer the delivery of products and services to you. In this regard, we may share personal information with the following entities: credit bureaus/consumer reporting agencies, data storage providers, insurers, data and payment processors, credit card printers, cheque printers, claims processors, collection agencies, statement producers, mailing houses (i.e., to mail your statement; to provide any necessary legal communications), third party call centres and account administrators, companies that solicit and collect applications for the financial, insurance and membership services offered or marketed by Canadian Tire Financial Services Limited, other companies that provide and service products and services, software developers specializing in data analysis, fraud detection, and money-laundering and terrorist financing detection; regulatory compliance service providers, insurance and membership service providers that administer those products and services, account adjudicators, and other businesses within the Canadian Tire family of companies that provide administrative services.

We may use service providers located outside Canada, and, if applicable, your personal information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those countries.

ii. To market and sell products and services. In these situations, we may share personal information with the following types of companies for the purposes of promoting and selling products and services that may be of interest to you: mailing houses and letter generators, sales and marketing agencies, organizations that provide and service these offerings, and other businesses within the Canadian Tire family of companies.

We do not necessarily share your personal information with each and every type of company listed above. The personal information we share with other companies will naturally depend on the products and services you are receiving. We would be pleased to tell you which companies have received your personal information from us. Just call us toll-free at 1-866-846-5841 or email us at customerservice@canadiantire.ca and we will make arrangements to provide you with this information.

Retention of your personal information

We retain your personal information only so long as it is necessary for the purposes identified or to comply with legal requirements. For instance, even if you have cancelled your account or your account has otherwise been closed, we are required by law to retain your personal information for a period of time. We may also need to keep your personal information to allow us to answer inquiries and/or deal with disputes. We remove from our systems personal information that we no longer require.

Protection against fraud

In an ongoing effort to protect our customers and ourselves from fraud, we have employees assigned to various teams for fraud protection and strategy. Designated employees may collect, use, and exchange personal information with other financial institutions and other entities permitted by law such as investigative bodies if we have confirmed a case of fraud and/or need to investigate potential cases of fraud. We also share information with the credit bureaus/consumer reporting agencies so that they can update their respective fraud databases. Examples of information shared for these purposes include confirmed fraudulent addresses, phone numbers and social insurance numbers, and other pertinent information.

6. We keep your personal information up to date and accurate

We make every effort to keep your personal information up to date, accurate and relevant for its intended use. You may request access to the personal information we have on record in order to review and amend the information, as appropriate. In circumstances where your personal information has been provided by a third party, we will refer you to that party (e.g. credit bureaus). To access your personal information, refer to the Contact Information section below.

7. The security of your personal information is a priority for us

We take steps to safeguard your personal information, regardless of the format in which it is held, including:
 
• physical security measures such as restricted access facilities and locked filing cabinets,
• electronic security measures for computerized personal information such as password protection, database encryption and personal identification numbers,
• organizational processes such as limiting access to your personal information to a selected group of individuals,
• contractual obligations with third parties who need access to your personal information requiring them to protect and secure your personal information.

8. We are open about our privacy and security policy

We are committed to providing you with understandable and easily available information about our policy and practices related to management of your personal information. This policy and any related information is available on request.

To contact us, refer to the Contact Information section below.

9. We provide access to your personal information stored by us

You can request access to your personal information stored by us. To contact us, refer to the Contact Information section below. Upon receiving a written request, we will:
 
• Inform you about what type of personal information we have on record or in our control, how it is used and to whom it may have been disclosed
• Provide you with access to your personal information so you can review and verify the accuracy and completeness and request changes to the information
• Make any necessary updates to your personal information.

Reviewing your personal information

Our goal is to respond to your request within thirty (30) days of receipt of your written request. If, for some reason, we are unable to respond to your request within this time frame, we will contact you directly and explain the reason for delay.

There may be instances where the law permits us to refuse your request to access your personal information. For example, if providing access to your personal information would reveal confidential commercial or proprietary information or personal information about someone else (and we are unable to separate your data), we may be unable to fulfill your request.

If we refuse access to your personal information, we will contact you directly. If you wish, you may then choose to file a complaint with the Privacy Commissioner of Canada, at the address indicated below.

Alternative format

If you have a sensory disability and require your personal information to be made available in an alternative format to the method we normally use, we will make reasonable efforts to convert your personal information into an alternative format to suit your needs.

10. We respond to your questions, concerns and complaints about the privacy

We will respond to your questions, concerns and complaints about the privacy of your personal information and our privacy policies and procedures in a timely manner, usually within thirty (30) days. If we need to extend the time or if we have to refuse your request we will tell you why and notify you of the new deadline.

CONTACT INFORMATION

If you have any questions or concerns regarding our privacy policies or procedures, or if you would like to review, verify or amend your personal information, please do not hesitate to contact us.
 
• We may be reached toll-free at 1-866-846-5841 or by email at customerservice@canadiantire.ca. Alternatively, you may write to us at:

Privacy Advisor
Canadian Tire Financial Services Limited and Canadian Tire Bank
P.O. Box 2000
Welland, Ontario
L3B 5S3
Fax: 905-714-2783

• If your questions, concerns or complaints have not been resolved to your satisfaction or, if you have further questions, you can contact Canadian Tire’s Chief Privacy Officer by mail at Chief Privacy Officer c/o Canadian Tire Corporation, Limited, 2180 Yonge Street, P.O. Box 770, Station K, Toronto, Ontario, M4P 2V8.
• In the event that we have not satisfied your request for access or responded to your privacy complaint, you may then choose to file a complaint with the Privacy Commissioner of Canada, 112 Kent Street, Ottawa, Ontario, K1A 1H3.

¹The Canadian Tire family of companies means Canadian Tire Corporation, Limited and its affiliates including Canadian Tire Financial Services Limited, Canadian Tire Bank, Canadian Tire Real Estate Limited, Mark’s Work Wearhouse, and its operating divisions including Canadian Tire Retail, Canadian Tire Petroleum and PartSource.