Application of CBDC Privacy Policy
This Privacy Policy describes how we internally use, protect and disclose to third parties during commercial activities any personal information within our possession collected from you through your use and access of CBDC projects & programs.
Accountability for Your Privacy
Our Privacy Information Officer is responsible for ensuring that Staff complies with this Privacy Policy and can be contacted at:
New Brunswick Association of CBDCs
3-219, Main Street
Bathurst, New Brunswick, E2A 1A9
Attn: Privacy Information Officer
Email: [infoNB@cbdc.ca]
Privacy Team
The Privacy Information Officer is always an individual who is an Officer of NBACBDC. The Privacy Information Officer heads our Privacy Team and may delegate some of his/her duties to one or more members on that team from time to time.
What information do we collect?
Personal information means any information that identifies you, or by which your identity could be deduced. The information we collect is to provide access to programs and/or projects delivered by NBACBDC, as more particularly described below. The information (including personal information) we collect may include:
- Individual customer’s name, home address, home telephone number and email;
- Demographic identifiers such as gender, age, language preferences;
- Business name, location, proof of registration, financial planning documents and relevant contracts
- Business address information, business owners’ names, business emails, and business phone numbers for an individual’s employer and;
- Bank account numbers for direct payment/withdrawal
How do we use Personal Information?
Our primary purpose for collecting personal information is in order to assist you, and to provide our services to you. Your personal information is used for purposes including, but not limited to, assistance in the preparation of business plans; business consultations; direct payment/withdrawal; preparation of legal documents; completion of quarterly reports;; determining eligibility for various funding programs and sources; and related services.
We may also use your personal information to distribute materials concerning these services and new developments relevant to your business, to include you in any direct marketing activities, or to send our newsletter to you. If you no longer wish to receive our newsletter or information about our services and related promotions, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each email and on the site where you signed up).
How do we collect your personal information?
Wherever possible we collect your personal information directly from you, beginning with the application for program participation or information requests.
We may also obtain personal information from other sources which may include:
- your bank or credit union;
- your insurance company;
- your real estate agent in a property transaction;
- government agencies or registries;
- your employer;
- your lawyer;
- your accountant;
- credit reporting agencies (trans-Union and Equifax); and
- outside consultants.
To help us determine program eligibility, make credit decisions, prevent fraud, and check the identity of new clients, we may, on occasion, request information about you from the files of consumer reporting agencies/credit bureaus.
Consent
We only collect, use or disclose personal information with your consent, which may be express or implied. At or before the time we collect the information we will identify for you the purposes for which it will be used. If we want to use your personal information for a new, unrelated purpose, we will first seek your consent to do so
Withdrawing Consent
You can withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Information Officer at infoNB@cbdc.ca. ]. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to you. We will inform you of any implications connected to withdrawing your consent.
You can withdraw your consent to receive marketing and promotional emails at any time using the “unsubscribe” button included in our emails.
Children
Our website and our services are not intended for children, and we do not knowingly collect personal information from children. If you believe we might have any information from or about a child, please contact us at the address provided above.
Information collected automatically
When you use our website, certain information is collected automatically. Cookies, files created by a website and stored automatically on your electronic devices for the purpose of collecting information on browsing activities, allow you to connect to our website during subsequent uses and allow us to personalize certain website features for you. The information collected consists mainly of the following: Domain name; IP address; Navigation history; preferred language. Most browsers automatically accept cookies, but it is usually possible to modify this setting. However, if you choose to refuse cookies, you may not be able use certain features of our website.
The use of such information allows us to improve the services we provide to our clients and to personalize your experience.
Use of Google Analytics
Our website uses Google Analytics to provide us with information about our website visitors. If you opt out, Google Analytics will anonymize the information gathered (but will continue to gather it) or will stop gathering information on your visit, depending on the type of opt-out that you choose. To opt out, you have to accept that a cookie be stored on your computer by Google Analytics. You may request to opt out by clicking on the relevant link in the Google Analytics website section that includes the privacy policy (https://tools.google.com/dlpage/gaoptout).
For more information regarding Google Analytics and its privacy policy, please read the privacy policy at http://www.google.com/intl/en/policies/privacy/.
Disclosure of your Personal Information
We do not disclose your personal information to any third party to enable them to market their products and services without your written consent. We are required, however, to disclose information to certain government organizations including Atlantic Canada Opportunities Agency (ACOA), Innovation, Science and Economic Development (ISED), and certain other government organizations dependant on the specific program for which you are participating. . In addition, we will disclose your personal information when:
- required or authorized by law to do so;
- you have consented to the disclosure;
- necessary in order to establish or collect sums owing to us; and
- we engage a third party to provide administrative services to us (such as computer back-up services or archival file storage).
Information may be shared among other CBDCs, and associations of CBDCs in order to better provide services to you (with your consent). For example, the Atlantic Association of CBDCs and New Brunswick Association of CBDCs provide administrative and other services to individual CBDCs. From time to time, we may receive an inquiry for services that may be delivered by another organization. We would make the referral with your knowledge and may transfer information to them to facilitate your inquiry.
For particular projects or programs that we administer, we may disclose information to third parties to facilitate the project or program, with your knowledge and consent based on your application.
Retention of your Personal information
The CBDCs receive funding from the Atlantic Canada Opportunities Agency (ACOA), and certain other government organizations. The terms of our agreements with those organizations require that we maintain the information that we collect, including personal information, for a period of not less than 5 years from the date that an application is rejected or the loan, if granted, is repaid.
Safeguarding personal information
We take all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
- premises security (locked doors and secure file cabinets);
- restricted access to personal information;
- deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
- internal password and security policies.
You should be aware that e-mail is not a 100% secure medium, and you must be aware of this when contacting us to send personal or confidential information.
Data Transfers
We may process, store, and transfer your personal information in and to another country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
Updates to your personal information
Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date. If during the course of our dealings, any of your information changes, please inform us in writing by contacting our Privacy Information Officer at infoNB@cbdc.ca so that we can make any necessary changes.
If we hold personal information about you and you demonstrate that it is not accurate, complete and up-to-date, we will take reasonable steps to correct any errors. Before making any such changes, we may ask you to provide additional information to verify your identity, which will only be used for that purpose.
Access to Your Personal Information
You may request access to the personal information we hold about you. Requests must be in writing and can be sent to our Privacy Information Officer. Summary information about your file is also available on request. We may seek to be reimbursed for copying charges if you require copies of your personal information. More detailed requests requiring archive or other retrieval costs may be subject to minimal fees.
We may be required to deny you access to your personal information when:
- denial of access is required or authorized by law;
- granting access would have an unreasonable impact on other people’s privacy;
- where the information is protected by solicitor-client privilege;
- where your personal information cannot be severed from another’s personal information.
If we deny your request for access to, or refuse a request to correct information, we shall explain why.
Links to other websites
Our website may contain links to other sites. Information exchanged on such sites is not protected by this Policy, but is subject to the policies of the external sites. Please ensure you read the privacy policies of any such external sites.
Changes to this Privacy Policy
We regularly review all of its policies and procedures, we may change our Privacy Policy from time to time. Please check our site periodically to ensure you are aware of any changes to this Policy.
Questions or Concerns
Should you have any questions or concerns about this Privacy Policy or how we handle your information-access request, please direct them to our Privacy Information Officer. He or she will be pleased to respond and if necessary investigate the matter.
We reserve the right to change our Privacy Policy at any time by posting a new version on our web site. In the event of a conflict between this version and another, the version that is later in time prevails.