Your privacy is important to us

 

Effective Date: July 25, 2016

INTRODUCTION

Bentley Financial Services Canada, Inc. and/or its third party service providers ("BFSC or "we") know that privacy is important to you. It is also vital to our business. The BFSC My Account Privacy Policy ("Privacy Policy") describes the types of information that is identifiable to a particular individual ("Personal Information") that may be collected (directly or through service providers) in connection with the use of the "My Account" System ("System"). This Privacy Policy sets forth the guidelines we use in protecting your privacy. This Privacy Policy is considered part of the System Terms and Conditions (the "Terms"). By using our System, you signify your acceptance of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our System or submit any Personal Information to us.

Our Website is for users located exclusively in Canada. If you are located outside Canada, please do not use our System, as the information practices and the terms of this Privacy Policy may or may not comply with foreign law where you are located. If you continue to use our Website, you consent to the collection, use and disclosure of your information in accordance with this Privacy Policy and subject to the applicable provincial and federal laws of Canada. This Privacy Policy applies to our collection, use, and disclosure of your Personal Information obtained through your use of this Website (also referred to herein as the "Site" or "Services" or "System"). This Privacy Policy does not apply to any of our affiliates, other Bentley companies, or Bentley dealers which are independent third parties.

  1. What Types of Personal Information We Collect and How We Collect It
  2. How We May Use Personal Information About You
  3. How We May Share Personal Information About You
  4. Changes to This Privacy Policy
  5. Links to Other Websites
  6. Security
  7. Data Transfers
  8. Your Right to Access and Correct Your Personal Information
  9. How to Reach Us
  • 1. WHAT TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT.

    We collect certain information about visitors to this Website indirectly through our Internet access logs. When you visit the System to read or download information, we may collect and store: (i) the name of the domain and host from which you access the Internet (such as aol.com); (ii) the Internet protocol address of the host server you are using (such as ww3.aol.com); (iii) the name and version of your Web browser; (iv) the date and time you access our System; (v) if you came to us through a link from some other system, the Internet address of the system from which you linked to our System; and (vi) technical data about the device being used to access the System (such as browser version, operating system version, browser plug-ins installed, and fonts installed). No cookies, apps, or other persistent code will be installed on the device as part of this process.

    For authentication purposes, we may collect responses to security questions, your account number, and other information necessary to establish and use your system log in credentials. We also collect other information (which may be Personal Information) when you directly submit it to us. We may collect Personal Information about you from the following sources: (a) enrollment applications, survey responses, and other electronic or paper forms that you fill out in connection with the Site; (b) your use of the Site, and your interactions with customer service, including information you enter or speak, and information transmitted by your computer, cell phones and other devices you use to connect to the Site or the Service; and (c) from other entities, such as individuals and financial institutions using the Service, credit bureaus, affiliates or other companies (such as identity verification services and credit reporting agencies).

    We do not knowingly collect any Personal Information from or about individuals under 18 years of age. Please do not submit such information to us, and as a parent or legal guardian, please do not allow your children to submit Personal Information without your permission. We do not knowingly collect Personal Information from children under the age of 13 without parental or guardian consent. Please contact us via the Contact Information provided below if you believe we may have collected such information without parental or guardian consent or other than in a manner authorized by law, and we will work to delete it.

    Some parts of the System use cookies, which are small data files placed on your device. The cookies neither capture nor store nor link to any personally identifiable information. Most such cookies are "session" cookies that are only used for a specific period of time during which you are on the System, but some may be "persistent" cookies that stay on your device and are read by the web server when you return to the System (unless you erase them). Cookies will not be used to deliver or run programs on your computer. Cookies may be used to store your preferences in order to save time by eliminating the need to enter the same information on later visits, to log which pages you visit on the System, or to provide certain features during your visit to the System. You can set your browser to refuse to accept cookies; however, if you do this you will not be able to log in as a registered user nor to use certain other interactive features of the System that depend on cookies.

  • 2. HOW WE MAY USE PERSONAL INFORMATION ABOUT YOU.

    We may use Personal Information and the other information described above in order to meet your needs, carry out your transactions, respond to your information requests, comply with laws, regulations, court orders and lawful instructions from a government agency or other competent authority, to protect the personal safety of users of our Services or the public, to defend ourselves from claims, to resolve disputes, to troubleshoot problems, to enforce the Terms, or to protect our rights and property. We may also use this information for general statistical modeling, in order to measure the number of visitors to different pages on our System and to modify the System in order to make the System more helpful. We also use this information to monitor network traffic and identify unauthorized access or unusual activity on the System. We use Personal Information about you only as permitted by law, including but not limited to our everyday business purposes, such as to maintain your ability to access the Site, to authenticate you when you log in, to send you information about the Site, to effect, administer and enforce transactions, to perform fraud screening, to prevent actual or potential fraud and unauthorized transactions, to verify your identity, to determine your transaction limits, to perform collections, and to customize, measure, and improve the Service and the content and layout of the Site including pattern recognition, modeling, enhancement and improvement, system analysis, and Service performance analysis; and for marketing purposes - to offer products and services to you, although you may opt-out of receiving commercial email marketing messages from us by following the opt-out processes described in those messages.

    Device Data may be used as part of our security controls to uniquely identify the device, authenticate the user when accessing the System, and may be compared to and added to a database of similar information operated by a service provider in order to identify and block access to the System by devices previously associated with fraudulent activity.

  • 3. HOW WE MAY SHARE PERSONAL INFORMATION ABOUT YOU.

    BFSC may share your Personal Information to process your transactions, maintain your account, and report to credit bureaus. Your Personal Information is shared only for the purposes communicated to you at the time of collection, and only with your consent.

    We share your Personal Information with parties (including outside service providers) who are contractually obligated to keep it confidential and use it only for the purposes approved by us. In addition, we require them to protect your Personal Information in a manner consistent with this Privacy Policy and our security practices.

    We may also share certain Personal Information about you with our service providers who will compare and add Device Data and fraud data to a database of similar device and fraud information in order to identify and block access to the Site by devices associated with fraudulent or abusive activity. We will not share with service providers any information that personally identifies the user of the device.

    Identity and Location Verification for Mobile Device Users: If you access the System using a mobile device, you authorize us to share your mobile subscriber details, including your name, billing address, email and phone number, with our third party service provider solely for purpose of verifying your identity with your mobile carrier.

  • 4. CHANGES TO THIS PRIVACY POLICY.

    We reserve the right to revise this Privacy Policy at any time in the future at our sole discretion, so you should review it frequently for changes. Any changes to the Privacy Policy will be clearly and conspicuously posted on this section of the Website. The revised version will be effective immediately at the time it is posted, unless a delayed effective date is expressly stated therein. You may (in our discretion) also be provided with an email notification of such amendments. You may (in our discretion) be required to affirmatively acknowledge or accept the revised Privacy Policy in order to continue using the Service. Any use of the Service after a notice of change (whether by Site posting, email, or express acknowledgment or acceptance) will constitute your express agreement to such changes. If we make any change in how we use Personal Information about you we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective.

  • 5. LINKS TO OTHER WEBSITES.

    Our Website includes links to other websites we may not control and whose privacy practices may differ from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies and statements. We encourage you to carefully read the privacy statement of any website you visit.

  • 6. SECURITY.

    To protect Personal Information about you from unauthorized access and use, we maintain physical, electronic, and procedural safeguards, including but not limited to security measures that comply with applicable federal and provincial laws. We also require our service providers to whom we disclose your Personal Information to do the same. For Personal Information pertaining to borrowers and consumers, those safeguards are designed to protect the security and confidentiality of the information, to protect against anticipated threats and hazards to security and integrity of the information, and to protect against unauthorized access to or use of the information that could result in substantial harm or inconvenience. In addition to security measures such as collecting Device Data, System registered users may be required to select and answer multiple security questions and may be required to enter additional information, including Personal Information, when registering for an account or when subsequently logging in to the System. All connections to our web server use SSL (secure socket layer) encryption to protect the transmission of information submitted to us. However, no data transmission is guaranteed as 100% secure.

    We retain Personal Information as long as is required for the purposes identified when you provided the Personal Information, and for any new purposes identified by us and consented to by you, unless a longer retention period is required or permitted by law, including but not limited to risk management, regulatory compliance, and audit purposes.

  • 7. DATA TRANSFERS.

    We may transfer the Personal Information we collect about you to countries outside of Canada. These countries may not have the same data protection laws as Canada and in some countries, your personal information may be accessed by governments, law enforcement authorities or the courts. When we transfer your Personal Information to other countries, we will protect that information as described in this Privacy Policy. If you have any questions regarding our policies and practices relating to transfer of Personal Information, please contact us using the Contact Information provided below.

  • 8. YOUR RIGHT TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION.

    As a registered user, you may change or correct your personal information within the System. To verify the accuracy of Personal Information we hold about you, you may submit a written request to us using the Contact Information provided below. To avoid delays in obtaining your Personal Information, please provide sufficient detail to permit us to identify you and the specific Personal Information that you are requesting.

    There may be instances where access may be restricted as permitted or required by law. Examples may include information that is subject to legal privilege, information containing confidential commercial information and information relating to a third party. If applicable, we will advise you of the reasons for restricting access subject to any legal or regulatory limitations.

  • 9. HOW TO REACH US.

    If you have any questions about this Privacy Policy, you may contact us at the postal address, toll-free number, or email address below:

    Bentley Financial Services Canada
    Attention: General Counsel
    165 Yorkland Blvd, Unit 150
    Toronto, ON M2J 4R2

    Phone: 888-641-6387

    E-mail: customerservicecanada@bentleyfs.com

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