Exchange Bank of Canada Privacy Policy
Last Revised: February 2023
Exchange Bank of Canada and its affiliates or subsidiaries (“EBC”, “Bank”, “we”, “us” and “our”) shall collect, use, and disclose Personal Information in accordance with this Privacy Policy (the “Policy”) and with all applicable Canadian laws.
The Policy informs you of the ways we help protect your privacy and the confidentiality of your information. We may amend this Policy from time to time. We will post the revised Policy on our website.
In this Policy:
- “you” and “your” mean any person, or that person’s authorized representative, who has requested from us any product or service (collectively, the “Services”) offered by us in Canada, who visits EBC’s websites (the “Website”), or who otherwise interacts with us
- “Personal Information” means any information about an identifiable natural person
By acknowledging this Policy, using or applying for Services or using the Website, you consent to the handling of your Personal Information for the purposes listed in this Policy.
Most of the information that EBC handles is business information about our corporate and institutional clients, partners, and suppliers. This Policy is about the limited Personal Information that we collect in relation to representatives of these clients or other individuals who interact with us or who interact with our Website.
1. Personal Information We Collect
Information You Provide to Us: If you communicate with us or use the Services, we may collect the following types of Personal Information:
- Individual and business contact information: such as name, title, email address, physical address, shipping address, and telephone number of individuals that communicate with us
Financial information: such as financial or transaction information relevant to officers and directors of clients collected as part of Know Your Client or other due diligence processes - Identity information: such as identification cards, identity verification details, and signature samples for signing authorities on institutional accounts
- Customer service interactions: such as information you provide when you engage with EBC’s customer service, including through recorded calls, surveys, and email correspondence
- Location information: such as your IP address and approximate geolocation obtained from the location of your device when accessing our Website
- Application information: If you apply for employment with EBC, we will collect your job application materials, resume, employment history, education history, and certifications and licenses held
- Communication preferences: such as marketing and cookie preferences
Information We Collect from Third Parties: We may obtain Personal Information about you from third parties, such as credit bureaus, background search services and fraud prevention vendors.
Information We Collect Automatically: When you interact with our Website, certain information about you is automatically collected via cookies and similar technologies (referred to collectively herein as “cookies”). Cookies allow us to see how you browse our Website to improve user experience and facilitate important security features.
The cookies on our Website collect the following Personal Information:
- Usage details about your interactions with our Website, such as which pages you access, frequency of access, what you click on, what search terms you enter, the date and length of your visits to the Website, and which (if any) websites from which you navigated to our Website (i.e. referring websites)
- Device information, including the IP address and other details of a device that you use to connect with our Services, such as device type and unique device identifier, hardware model, operating system, browser, mobile network information, mobile carrier, and the device’s telephone number
- Location information where you choose to provide us with access to information about your device’s location, including information on nearby devices and Wi-Fi access points
Generally, this information cannot directly identify you (for example, it is not associated with your name.) We use the information collected via cookies to understand our user base, monitor the performance of our Services and Website, improve the user experience, and to ensure the security of our Services and Website. You can learn more about how we use cookies and manage your cookie preferences Cookies Settings.
We also use Google Analytics to conduct analytics and to collect information about usage of the Website. You can learn more about privacy and Google Analytics here. In general terms, Google Analytics collects information on how often users visit the Website, what pages or features of the Website they use, and what other websites users visited prior to accessing the Website. You may prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on.
2. How We Use Personal Information:
We may use your Personal Information to:
- Verify the identity of clients and their representatives
- Communicate about the Services, provide the Services, and promote additional Services
- Better understand clients’ needs and to offer relevant information, products, and services to meet those needs, including sending communications by way of postal mail, e-mail, telephone, or other type of electronic message
- Conduct surveys and analysis for research, statistical and product development purposes, (Personal Information will be de-identified where required or appropriate)
- Perform tests to implement or modify systems
- Manage, model and assess risk
- Comply with applicable legal and regulatory requirements
- Achieve other purposes as may, from time to time, be permitted or required by law
If you contact us by phone, the call may be recorded or monitored to:
- Establish a record of the information you provide
- Take or verify instructions from you
- Maintain quality service levels
- Assist in staff training
3. How We Share and Disclose Personal Information
We will only use or disclose Personal Information for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. The Bank does not sell or rent Personal Information.
EBC may transfer, share or disclose Personal Information as follows:
- With our group of companies and corporate affiliates for the purposes outlined above
- With service providers who assist the Bank in its provision of products and services (“Service Provider”). When Personal Information is transferred to a Service Provider, the Bank will require the Service Provider to protect the Personal Information in a manner that is consistent with this Policy
- With advertising partners who assist us in serving advertisements regarding the Services and monitoring those campaigns
- With third party service providers including credit bureaus and background search services in order to accurately identify you if we collect Personal Information from them
- As part of a business transaction with another entity in connection with a contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings)
- To prevent harm or if we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the safety of any person or property
- As required by law or when we are legally permitted to do so, such as in response to or in compliance with court or regulatory agency orders, legal proceedings, or legal process
International Transfers
The Bank’s service providers may be located outside of your province or outside of Canada, and Personal Information they handle may be accessible to government authorities under the laws of that jurisdiction. If your Personal Information is transferred outside of your jurisdiction, we require that it be protected to the same level as in Canada.
4. How Long We Keep Personal Information
We will only retain your Personal Information for as long as is necessary to satisfy the purposes for which it was collected or as may be required or permitted by law. In some cases, Personal Information may be kept after the relationship between you and us ends, where required by law or to achieve the purposes described above. We will destroy, delete or render anonymous Personal Information no longer required for an identified purpose or a legal requirement. The Bank has internal policies, procedures and training programs to govern the retention and secure destruction of Personal Information.
5. How We Secure Information
We take reasonable steps to protect Personal Information through security safeguards that are appropriate to the sensitivity of the Personal Information, in order to protect the Personal Information from loss, theft, unwarranted and/or unauthorized access, intrusion, release or misuse. We have implemented appropriate physical, organizational and technological measures including firewalls, access control policies and restricted access areas.
6. Your Rights With Respect to Your Information
- Withdrawing consent. You may withhold or withdraw your consent for us to collect, use and disclose your Personal Information, as long as there are no legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with Services.
- Updating and accuracy. We make reasonable efforts to keep Personal Information accurate and complete. To do so, we rely to a large extent on you to provide us with accurate information and to inform us of changes. You may also verify the accuracy and completeness of your Personal Information and request that it be amended. To update or verify the accuracy of your Personal Information, you can contact us using the contact information below.
- Access. You can make a written request to the Bank to access your Personal Information. In some cases, there are exceptions to this right of access, but we will explain those to you if we cannot complete your request in full. We may ask you for identification before releasing Personal Information to you.
7. Contact Us
We are accountable for Personal Information under our control. The Bank’s Chief Privacy Officer is responsible for maintaining and updating this Policy, our privacy practices, and employee training about our privacy program.
You may contact us with any inquiries or concerns about the Bank’s privacy practices:
Exchange Bank of Canada
390 Bay Street, Suite 700
Toronto, Ont. M5H 2Y2
Attention: Chief Privacy Officer
[email protected]
If we are unable to resolve any concern you raise, you may be able to complain to the Office of Privacy Commissioner of Canada:
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-Free 1-800-282-1376
Priv.gc.ca