Last revised: October 1, 2023

We value the trust you have placed in Imperial PFS Payments Canada, ULC. This Privacy Policy is our way of making sure you are fully informed and understand what information we collect, and how we use, disclose, transfer and retain (collectively “process”) the information you provide to us when we provide products or services, or communicate with you.

Our Policy – Terms Used

In this Policy “we” or “us” refers to Imperial PFS Payments Canada, ULC and our affiliates.

“You” refers to anyone who visits our website(s), uses our mobile application, our clients, and anyone who engages with our services.

For the purposes of this Policy, “personal information” means information that can identify an individual directly, or indirectly through reasonably available means. However, personal information does not include business contact information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business, or profession.

Information we Collect

We collect information that is reasonably needed to provide you with the financial products and services you’ve requested, fulfill our obligations and terms under agreements with you or to respond to your inquiries or requests. We may also collect information on your use of our website and services in a manner consistent with the terms of this privacy policy. Without limiting the foregoing, the following are examples of the types of information we may collect:

  • Name
  • Address
  • Credit Card Number
  • Bank Information (automatic and one-time payments)
  • Phone Number
  • Email Address
  • Information to authenticate your identity (driver’s license, etc.)
  • Technical information, such as your IP address and geolocation information, web browser type and version, operating system and/or device, cookies and other technology on the devices you use to access our website(s)

We collect information about you from the following sources:

  • Information you give us on applications or other forms
  • Information you provide in the course of discussing your transactions with us
  • Information from public sources such as internet sites, registries or public records
  • Information from credit reporting and financial institutions relating to your credit history and record
  • Automated technologies or interactions by using cookies, pixels, server logs and other similar technologies

How do we Collect your Personal Information?

Personal information may be collected in a number of ways, including from you when you submit an application for a loan, through our website, in person, by mail, by email, via our applications or other software, and from third parties which you have authorized to disclose personal information to us.

If you provide information about a third party or authorize a third party to do so, we will assume you have taken proper measures to obtain informed consent.

(a) Cookies

We may also collect information through “cookies” on our website. Cookies are small text files inside your computer that contain a unique identifier, allowing us to recognize you when you visit our website again. This helps us tailor our content to meet your needs and for advertising purposes. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Please read our cookie policy for more information.

(b) Phone calls

For the purpose of maintaining quality service, telephone calls to our customer service lines may be recorded. If your call is subject to a quality assurance program, you will be advised prior to speaking with a representative.

(c) Social media

If you post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums on our website or other applications, your communications may be viewable by the public.

How we use your Information

We use your information in ways that are reasonably connected to why you have engaged with Imperial PFS Canada. For example, if you are applying for a payment plan, we use your personal information to process payment plans. If you have a payment plan or other agreement with us, we use your personal information for purposes of fulfilling our obligations under the agreement, or to protect our rights or the rights of others arising from the agreement. Without limiting the foregoing examples, we will also use your personal information:

  • to verify your identity
  • to provide the financial service you request
  • to respond to your inquiries or other communications
  • to manage our risk and operations
  • to provide services and product management – maintaining and improving our products and services and otherwise running and managing our business in the ordinary course
  • to communicate with you. We use your data to communicate with you via phone, email and text, including with regard to newsletters or other communications to which you have subscribed or those in which we believe you to be interested
  • for business development and market research purposes. We use data to understand demographics, interests, usage patterns, and other characteristics of customers. We may use your information to create reports or data analyses to aggregate information with other customers
  • to offer tailored content and promotional materials to you and for other marketing and advertising purposes including administering surveys, contests, draws, and raffles, offering tailored content, and promotional materials
  • to provide customer support – assisting you when you contact our customer support services, including to direct your questions to appropriate individuals, investigate and address any of your concerns, and to improve and monitor our customer support responses
  • as required or permitted by applicable regulatory and legal requirements.

Disclosure of Personal Information

Imperial PFS Canada discloses personal information for purposes reasonably connected to the reasons we’ve processed the information. For example, when you apply for a loan or financial assistance, we may disclose personal information to credit reporting and financial institutions for purposes of obtaining credit reports and history on you.

In addition, Imperial PFS Canada shares personal information with:

(a) Service Providers

Third parties who provide services for our benefit and to the extent relating to the services you have requested from us or otherwise reasonably related to our relationship with you (such as third-party technology companies, cloud storage providers, data analytics providers) to ensure we can provide the services you’ve asked for.

(b) Payment Providers

We do not store your payment information (i.e. debit/credit cards), this is shared directly with our third-party payment providers.

(c) When Legally Required or Permitted

We may disclose personal information in situations where we are legally required or permitted to do so. These situations may include to enforce or protect our rights, criminal investigations, government tax reporting requirements, court orders, or instances where we believe the rights and safety of others may be at risk.

If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.

Imperial PFS Canada may also share some or all your personal information to negotiate and complete any merger, financing, acquisition or dissolution, or similar transaction.

If another company acquires Imperial PFS Canada or our business or assets, we may disclose your personal information to that company. We may also retain your personal information and continue using and disclosing it if there is only a partial sale of Imperial PFS Canada or our business or assets.

Your Rights

Subject to certain exemptions, and to the extent permitted by applicable law, you may have the following rights in relation to the personal information we hold about you:

(a) Your Right of Access

At your written request we will inform you whether we hold personal information relating to you and if we do, you have the right to receive a general account of our processing of such personal information. If your request is made in writing, subject to applicable laws and the provisions of this Privacy Policy, we will also provide you with access to your personal information that is in our possession. A reasonable fee may be levied if you request the transcription, reproduction or transmission of such information and you will have to provide information or documentation to verify your identity. We will inform you of the approximate cost before proceeding to respond to your request. Your rights to access your personal information are not absolute. Access can be denied for several different reasons under applicable legislation. If we deny your request for access to your personal information, we shall explain why.

(b) Your Right to Rectification

If we hold personal information about you and you believe that it is not accurate, complete, or up-to-date, you can request to have it rectified (or rectify it yourself via your account information page, if available). If we discover that information is not accurate, complete, or up-to-date, we will take reasonable steps to rectify it. We will also send any information that has been amended, where appropriate, to any third parties that have access to the information.

(c) Your Right to Withdraw Consent

If we rely on your implicit or explicit consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Keeping your Information Safe

The protection of your personal information is of the utmost importance to us. We use many methods to ensure your information is protected, such as passwords to log on to computers, security codes on doors, firewalls and other security software, implementation of a Privacy Policy, and confirming third-party service providers comply with privacy laws. However, all security risks cannot be eliminated, and while Imperial PFS Canada uses numerous methods to try and ensure the security of the information, Imperial PFS Canada cannot guarantee your personal information will not be processed in ways not described in this policy.

Personal Information Outside of Canada

Imperial PFS Canada may use service providers across Canada and in the United States. In such event, personal information will be stored and processed by us and our third parties for purposes set forth herein outside of your jurisdiction of residence. You acknowledge and agree that, as a result, your personal information may be processed or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries. If you have any questions in this regard, please do not hesitate to reach out to us as the contact information below.

Retention of your Personal Information

Imperial PFS Canada retains your personal information for the period necessary in order to provide you with the financial products and services you’ve requested, and to comply with legal obligations, or longer as permitted by applicable law. Imperial PFS Canada will dispose of your personal information when it is no longer permitted to be retained.

Consent

When you provide your personal information to Imperial PFS Canada, you consent to the processing of that information in accordance with this Privacy Policy and as permitted or required by law. You may withdraw your consent, subject to legal and contractual obligations, but you might not be able to proceed with your intended payment plan with Imperial PFS Canada.

If any personal information about another individual is provided to Imperial PFS Canada by you, it is understood that you have obtained all required consents and authorizations to do so.

Our services and websites are not targeted or directed at children under the age of 16. No one under age 16 may use the services or provide any personal information to our websites. We do not knowingly collect personal information from children under the age of 16. If you believe we might have any information from or about a child under 16, please contact us and we will take steps to delete that information as soon as possible.

Inquiries and Request for Access

If you have questions about Imperial PFS Canada’s privacy practices, or wish to exercise your rights in relation to your personal information, please contact Imperial PFS Canada by phone or mail at:

Imperial PFS Canada
Attn: Privacy Officer
1 Toronto Street Suite 1011
Toronto, ON M5C 2V6
1.866.815.9454