Overview

This Privacy Policy establishes rules to govern the collection, use and disclosure of personal information collected by Symend Inc. (the “Company”) in the course of business, in compliance applicable federal, state and provincial privacy laws.

This Privacy Policy applies to all individuals whose personal information the Company collects, uses or discloses in the course of doing business. This includes individuals who we are engaged to collect debts from and all individuals who are contract workers, contractors, and consultants to the Company. It is our policy to only disclose your personal information as required or authorized by law or as otherwise set out in this policy.  Where this Privacy Policy states that a list of items is “including”, the lists so described are meant to be examples and not exhaustive or exclusive.

We reserve the right to change this policy from time to time as industry practice, the law, and our procedures in this area may change from time to time. We will post the current version of this policy at: www.symend.com.

The Company has designated a Privacy Officer to be accountable for the operation of this Privacy Policy.  If the policies and procedures outlined in this document do not address a specific situation, individuals are advised to contact the Company’s Privacy Officer for guidance or clarification.

Collection and Use of Personal Information

The Company collects and uses only the personal information that we need for providing services and operating our business. Generally, the Company collects and uses the following personal information from individuals for the various purposes set out below:

  • name, address, email address (home and work), phone number
  • demographic information, such as age and gender
  • payment history but not specific credit card numbers or other bank account numbers

The Company collects, uses and discloses personal information for the following purposes:

  • to process or make payment arrangements;
  • to manage the Company’s business and operations, including customer relationships and matters, including disclosing to another entity within the Company corporate family;
  • to report to third parties with respect to progress of debt collection;
  • to meet legal and regulatory requirements;
  • deliver, develop, enhance or improve products and services;
  • evaluate suitability of employment candidates;
  • when we reasonably believe in good faith that use and disclosure is genuinely necessary to protect our rights, protect your safety, or the safety of others, investigate fraud, or respond to a government request; and
  • conduct market research.

Your data may be disclosed to our third-party partners for data processing. These parties are only given the information necessary to perform the processing activity. Symend requires that any third-party service provider to protect your information in a manner that is consistent with our privacy policies.  In the event our the third-party service provider is located in a foreign jurisdiction, they are bound by the laws of the jurisdiction in which they are located and may be required to disclose information in response to valid demands from regulators, courts, government authorities, or law enforcement authorities.

In addition, we also receive and send data from our servers and from your browser when you visit our website, including your IP address, the time and information about the page you requested and the website through which you were linked to our site, if any. We may use tracking technologies in a variety of ways, including the following: keeping count of return visits to our site; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on website usage; and determining which features users like best.

Links to Other Websites

Our site includes links to other websites whose privacy practices may differ from those of Company. If you submit personal data to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Widgets

Our website may include social media features, such as the Facebook Like button and widgets, the Share this button or interactive mini-programs that run on our site (collectively, “Features”). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Features are either hosted by a third party or hosted directly on our site. Your interactions with these Features, if any, are governed by the Privacy Statement of the company providing it.

Consent

We normally collect information directly from individuals and from third parties that utilize our services. We may collect your information from other persons with your consent or as authorized by law. Before or at the time of collecting personal information, we identify the purposes for which we are collecting the information. We do not provide this notification when personal information is volunteered for an obvious purpose. If we wish to use or disclose your information for a new purpose not included in this policy, we will notify you and seek your consent.  You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.

We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask individuals to provide their consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button). In cases that do not involve sensitive personal information, we may rely on “opt-out” consent. The amount and type of personal information collected by the Company shall be limited to what is necessary to fulfill the identified purpose. Personal information shall only be used or disclosed for the purposes for which it is collected. Exceptions may be made with the consent of the individual or if authorized or required by law.

Obtaining Access to Personal Information

Upon request received by the Company in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information. Requests to access personal information held by the Company should be directed to the Company’s Privacy Officer.

Requests must be made in writing or by e-mail. Individuals may be required to verify their identity in order to access their personal information. Any such documentation provided shall be used for verification purposes only.

The Company responds to requests for access to personal information within thirty (30) days of receipt of the request, or as may be permitted in accordance with applicable privacy legislation.

A fee for reasonable costs incurred may be charged when responding to more complex requests. The individual will be informed of the applicable fee.

Requested information will be provided in a form that is generally understandable.

The Company will be as specific as possible when describing third parties to whom it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information, the Company will provide a list of organizations to which it is likely to have disclosed information.

Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed from the Company, individuals wishing to view an original record will do so at the Company’s head office and under the supervision of designated the Company personnel.

Limitation to Access

The Company will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation.

In the event that the Company refuses to provide access to information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. The Company will respond to your requests for access in accordance with applicable privacy legislation.

Maintenance of Personal Information

Personal information shall be kept as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used.

Individuals have the right to challenge the accuracy and completeness of the personal information that is maintained by the Company and have it amended as appropriate.

Individuals seeking a correction or amendment to their personal information should direct their requests in writing to the Company’s Privacy Officer. All formal requests to amend personal information must be accompanied by appropriate supporting documentation. The Company’s Privacy Officer will manage any exceptions. The amended information will be transmitted to third parties, as appropriate.

If the individual is not satisfied with the results of the request, the Company shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.

Security of Personal Information

Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal information.

Personal information will be retained only as long as necessary and will be disposed of in a manner that is appropriate to the sensitivity of the information. We render individual personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying individual personal information, including shredding paper records and permanently deleting electronic records.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Inquiries

Inquiries concerning compliance with this Privacy Policy should be addressed, in writing, to the Company’s Privacy Officer.

If you are not satisfied with the response from our Privacy Officer after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the Federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.

If you have a question or concern about any collection, use or disclosure of personal information by the Company, or would like to request access to your own personal information, please contact: legal@symend.com.