Answers to Common Privacy Questions

What is personal information?

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• Age, name, ID numbers, income, ethnic origin, or blood type;
• Opinions, evaluations, comments, social status, or disciplinary actions; and
• Employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs).

Personal information does not include the name, title or business address or telephone number of an employee of an organization.

Why does HomeEquity Bank collect personal information?

In carrying out our commercial activities we collect personal information for a number of reasons including to:

• Verify the identity of the consumer and investigate the consumer’s background and title interests;
• Provide products to the consumer;
• Help us better understand the current and future needs of the consumer;
• Communicate any benefit, feature and other information about our products.
• The administration and maintenance of any accounts with HomeEquity Bank.

In addition, our websites collect information about consumers in order to:

• Track website statistics and page usage to improve the website experience for consumers;
• Provide and enhance online security on our websites and when transmitting information to and within the Bank;
• Track and monitor the results of online advertising and email campaigns.

Does HomeEquity Bank use its consumer information to create mailing lists?

Yes, we do use our database of consumer information to prepare mailing lists to communicate a variety of things such as new product information and annual statements for our current clients. If you don’t wish to receive certain communications, you can contact us by:

Telephone: (416) 925-4757 or toll-free at 1-888-655-1119
Email: info@chip.ca

Does HomeEquity Bank sell mailing lists of its clients’ information to other businesses?

No, we do not sell mailing lists, or any consumer information we have to any organizations or individuals outside of the Bank.

Does HomeEquity Bank exchange personal information with other businesses?

Yes, in certain instances. For example, if you are applying for a CHIP Home Income Plan, we are required to determine if you qualify. Most of the personal information we need to do this is gathered directly from you. However, we may also need to collect and/or disclose personal information to service providers such as to credit reporting agencies and companies employed by us to conduct title searches.

We may release personal information to marketing and advertising agencies that we have contracted with to conduct marketing on our behalf.

We may transfer your Personal Information to third party service providers who assist us in serving you, such as vendors, suppliers and agents; however, we require them to protect your information in a manner consistent with our privacy standards. Our service providers may be located outside of Canada and may be required to disclose personal information under the laws of their jurisdiction.

We require all of our service providers to abide by privacy law.

Do I always need to provide personal information to find out if I qualify for a CHIP Home Income Plan?

Yes, HomeEquity Bank does need to collect personal information to determine your eligibility and to provide you with an accurate quote.

How does HomeEquity Bank collect personal information?

We collect personal information through several methods including telephone, face-to-face meetings, mail, email and websites. Consent is obtained at the time personal information is gathered and recorded in a client file or on a recorded telephone line. Consent may be explicit, (for example when you fill in an online form in order to get an estimate), or implied, (for example when you continue to use one of our products). The information gathered is collected by fair and lawful means. We don’t collect information in a misleading or indiscriminate way.

How do HomeEquity Bank’s websites collect information?

Like many financial institution websites, our websites routinely collect information automatically when you visitCHIP.ca or our other websites. This information is only accessible by HomeEquity Bank’s IT Department in website usage logs and by marketing and advertising agencies contracted to work on our behalf.

If you choose to fill in an online form then of course we collect your personal information.

If you visit our CHIP.ca and/or CHIPmoney.ca websites and choose to engage in a live chat session, by clicking the chat icon, information is collected about you. HomeEquity Bank’s live chat computer program is operated by one of our Contact Centre representatives who can see if you have visited the site before and will engage you in a live chat session, if you choose to do so. During the course of a live chat session, all typed communication is recorded electronically and the Contact Centre representative may ask you for personal information such as your name and telephone number and may set up a file about you in our database.

HomeEquity Bank’s websites use cookies to help facilitate users’ ongoing access to and use of our websites. We use non-persistent or session cookies to improve operations and functionality and ensure online sessions are secure. These cookies do not contain personal information and are destroyed as soon as the browser is closed and/or the online session has been inactive for twenty minutes. We do not use cookies to follow the surfing behaviour of visitors once they leave our websites. You may browse HomeEquity Bank’s websites without accepting cookies. However, if you choose not to accept cookies, some website functions may not operate properly or optimally.

How is my personal information safeguarded once it’s in HomeEquity Bank’s possession?

We protect your information with safeguards that are appropriate to the sensitivity of the information. This includes physical, organizational and technical security measures that protect personal information against unauthorized disclosure, loss, theft, unauthorized access, copying, use or modification or destruction of the information. The nature of our safeguards varies depending on the type and amount of information, the extent of distribution, the format of the information, and its method of storage.

If you provide us with personal information via our online application form, we strive to provide the most secure transmission environment possible. To secure the transfer of any information to our servers, we have obtained a Secure Socket Layer (SSL) Server Certificate. The certificate is active on every page where you enter information, such that the information is encrypted while being transferred to our secure servers. We also use technologies and processes such as access control procedures, network firewalls, physical security, and other measures to protect your information and we have policies and procedures in place as to how we safeguard information.

Can I see what information HomeEquity Bank has on file for me?

Yes, you have the right to access the information that we have about you by providing an access request in writing and verification of your identity. Once we retrieve your information we will advise you of how the information was used, where it was used, if it was disclosed to any outside service providers, and give you access to the information, unless access is prohibited by law. There may be a fee for doing this. You will be given advance notice of costs if they apply to your access request.

To request access to your personal information held by HomeEquity Bank, you can contact our Chief Privacy Officer by:

Toll-free Telephone: 1-866-313-2447
Email: privacyofficer@heb.ca

Can I have any personal information which HomeEquity Bank has on file for me, changed or deleted?

If you successfully identify information that is incorrect or incomplete, we will make the necessary changes. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question. Any unresolved differences shall be noted in your file.

Do I have any recourse if I’m not satisfied with HomeEquity Bank’s dealing with my personal information?

Yes, you are entitled to challenge our compliance with our privacy policy by using our Complaint Handling Procedure which can be found on any of our websites. HomeEquity Bank reviews and takes appropriate measures to resolve all complaints and the complainant is informed of the outcome of the investigation.

Any inquiry regarding personal information that cannot be dealt with through the normal business process is escalated to our Chief Privacy Officer. HomeEquity Bank’s Chief Privacy Officer can be contacted by:

Toll-free Telephone: 1-866-313-2447
Email: privacyofficer@heb.ca

Failing a satisfactory response from HomeEquity Bank’s Chief Privacy Officer, you may have recourse to additional remedies under Canada’s federal privacy legislation, the Personal Information Protection and Electronic Documents Act (PIPEDA). For further information, contact the Privacy Commissioner at www.priv.gc.ca or call 1-800-282-1376.