1. Introduction

Welcome to TIB Finance. We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you interact with our services.

This policy complies with Quebec's Act respecting the protection of personal information in the private sector (Law 25) as well as other applicable privacy legislation in Canada.

By using our services, you accept the practices described in this policy. If you do not agree to these terms, please do not use our services.

2. Definitions

• "Personal Information": Any information relating to an identified or identifiable natural person.
• "Processing": Any operation or set of operations performed on personal information.
• "Privacy Officer": The person designated within TIB Finance to ensure compliance with privacy legislation.
• "Processor": Entity that processes personal information on behalf of TIB Finance.
• "Consent": Free, informed, and specific agreement given by the individual for the processing of their personal information.

3. Information We Collect

3.1 Information You Provide to Us

• Identification information: name, date of birth, Social Insurance Number (SIN), email address, phone number.
• Financial information: banking details, income, transaction details, credit history.
• Identity documents: copies of official identification documents (driver's license, passport, health card).
• Employment information: employer name, position held, employment income.
• Communications: emails, calls, contact forms, written correspondence.

3.2 Information Collected Automatically

• Technical information: IP address, browser type, operating system.
• Cookies and similar technologies: to improve your user experience.
• Location data: via GPS or IP addresses.
• Usage information: pages visited, time spent on the site, interactions with features.

3.3 Information from Third Parties

• Financial partners: information relating to transactions and accounts.
• Credit reporting agencies: credit histories, credit scores, and other relevant information (Equifax, TransUnion).
• Authentication services: biometric data or other verification information.
• Public records: information from official public sources.

4. Data Accuracy and Updates

TIB Finance is committed to maintaining the accuracy and integrity of your personal information. We take the following measures to ensure data quality:

4.1 Verification Sources

• Credit reporting agencies: We consult recognized credit bureaus (Equifax, TransUnion) to verify and update financial information.
• Official documents: We use government-issued identity documents to confirm identification information.
• Direct confirmation: We contact you directly to validate important information.

4.2 Update Process

• During new requests: Each new service request triggers a verification and update of your file.
• Periodic reviews: We conduct regular reviews of our databases to identify potentially outdated information.
• Upon client request: You may request an update of your information at any time.

4.3 Controls in Place

• Automated validation of data formats (postal codes, phone numbers).
• Cross-verification of information from multiple sources.
• Automatic alerts when inconsistencies are detected.
• Staff training on data verification procedures.

It is your responsibility to inform us of any changes to your personal information. Please contact us immediately if your contact details or circumstances change.

5. Use of Your Information

• Service provision: processing transactions, managing user accounts, evaluating credit applications.
• Security: fraud detection and prevention, securing operations and data.
• Service improvement: usage analysis, development of new features.
• Communication: sending information, updates, responses to support requests.
• Marketing: proposing relevant products and services, promotional campaigns (with consent).
• Legal compliance: compliance with legal and regulatory obligations (including anti-money laundering and anti-terrorist financing).

6. Sharing Your Information

• Service providers: hosting, analytics, technical support.
• Financial partners: payment processing, credit offers.
• Credit reporting agencies: communication of your payment history in accordance with industry practices.
• Legal authorities: response to judicial requests, investigations, legal obligations.
• International transfers: sharing with entities outside Canada, with appropriate safeguards.
• Other: sharing with your consent or for legitimate purposes provided by law.

7. Legal Bases for Processing

• Contract performance: provision of requested services.
• Consent: when you have given your explicit agreement.
• Legitimate interests: service improvement, security, fraud prevention.
• Legal obligations: compliance with laws and regulations in force, notably Quebec's Act respecting the protection of personal information in the private sector.

8. Your Rights and Access Procedure

In accordance with Quebec's Act respecting the protection of personal information in the private sector, you have the following rights:

• Right of access: obtain a copy of the information we hold about you.
• Right to rectification: correct inaccurate or incomplete information.
• Right to erasure: request the deletion of your information under certain conditions.
• Right to restriction of processing: restrict the use of your information.
• Right to portability: receive your information in a structured and commonly used format.
• Right to object: object to processing for legitimate reasons.
• Right to withdraw consent: at any time if processing is based on consent.

8.1 Procedure to Exercise Your Rights

To exercise your rights of access or rectification, please follow these steps:

1. Submit your request: Send a written request by email to Contact Us or by mail to the address above. Clearly specify the nature of your request (access, rectification, deletion, etc.).
2. Identity verification: To protect your information, we will need to verify your identity. You will need to provide:
   • A copy of a photo ID (driver's license, passport)
   • Recent proof of residence (utility bill, bank statement)
3. Acknowledgment of receipt: We will send you an acknowledgment within 10 business days of receiving your complete request.
4. Request processing: We will process your request and provide you with a response within a maximum of 30 days following receipt of your request.
5. Recourse: If you are not satisfied with our response, you may file a complaint with the Commission d'acces a l'information du Quebec (Quebec Access to Information Commission).

8.2 Request for Rectification

If you find that information about you is inaccurate, incomplete, or ambiguous, you may request rectification. Your request must include:

• Precise identification of the information to be rectified.
• The corrections to be made.
• Supporting documents, where applicable.

Once the rectification is made, we will inform you and, upon request, transmit the rectified information to any person to whom we had communicated the erroneous information.

9. Security of Your Information

TIB Finance implements rigorous security measures to protect your personal information against loss, theft, unauthorized access, disclosure, copying, unauthorized use or modification.

9.1 Access Controls

• Multi-factor authentication: System access protected by multi-factor authentication.
• Role-based permissions: Access to information limited according to each employee's position and responsibilities.
• Principle of least privilege: Employees only have access to information strictly necessary for performing their duties.
• Access logging: All access to sensitive information is recorded and monitored.

9.2 Secure Systems

• Data encryption: Your information is encrypted both at rest (storage) and in transit (transmission) according to AES-256 standards.
• Firewall and network protection: Infrastructure protected by next-generation firewalls and intrusion prevention systems.
• Intrusion detection: Threat detection and response systems operating 24 hours a day, 7 days a week.
• Security updates: Regular application of security patches and system updates.

9.3 Internal Policies

• Staff training: Mandatory annual training on personal information protection and cybersecurity for all employees.
• Security audits: Regular internal and external audits to assess the effectiveness of security measures.
• Confidentiality agreements: All employees and contractors must sign confidentiality agreements.
• Acceptable use policy: Strict rules governing the use of computer systems and information.

9.4 Incident Management

• Incident response plan: Documented procedures for detecting, containing, and remediating security incidents.
• Response team: Dedicated team for managing security incidents.
• Notification: In the event of a privacy incident presenting a risk of serious harm, we will notify you as well as the Commission d'acces a l'information du Quebec, in accordance with the law.

9.5 Physical Security

• Controlled access to premises via access cards and biometrics.
• Video surveillance of sensitive areas.
• Mandatory clean desk policy.
• Secure destruction of physical documents (shredding).

Despite our efforts, no method of transmission or storage is infallible. Please inform us immediately if you suspect a breach of the security of your personal information.

10. Data Retention and Destruction

TIB Finance retains your personal information only for the duration necessary for the purposes for which it was collected, or in accordance with applicable legal requirements.

10.1 Retention Periods

• Maximum duration: Your personal information is retained for a maximum period of seven (7) years after the end of your business relationship with TIB Finance.
• Legal obligations: Certain information may be retained longer if required by law (tax obligations, financial regulations, legal proceedings).
• Marketing information: Retained until withdrawal of your consent or for 3 years after your last interaction.

10.2 Secure Destruction Methods

Upon expiration of the retention period, or when the information is no longer needed, we proceed with secure destruction:

• Electronic data: Certified destruction through multiple data overwriting according to recognized standards (NIST 800-88), with destruction certificate.
• Physical documents: Secure shredding of paper documents (cross-cut level P-4 or higher) by a certified provider.
• Storage media: Physical destruction or degaussing of hard drives and other storage media.
• Destruction log: Maintenance of a log documenting all destructions performed.

10.3 Anonymization

In some cases, rather than destroying information, we may irreversibly anonymize it so that it can no longer be associated with an identifiable individual. This anonymized data may be retained for statistical or research purposes.

11. International Data Transfers

Your information may be transferred and processed outside Quebec or Canada. Privacy laws may be different there.

We use recognized mechanisms (standard contractual clauses, impact assessments) to ensure an adequate level of protection during these transfers.

For any questions regarding international transfers, contact us at Contact Us.

12. Use of Cookies and Similar Technologies

We use cookies and similar technologies to improve your experience, analyze the use of our services, and personalize your navigation.

You can manage cookies in your browser settings. However, disabling certain cookies may affect the user experience.

For more information, see our Cookie Policy.

13. Changes to the Privacy Policy

We may update this Policy to reflect our internal changes or legal requirements. Any significant update will be notified to you by email or via our website.

The most recent version will always be available on our website.

14. No Sale of Information

TIB Finance does not sell your personal information to third parties. The use and sharing of your information is done only according to the terms of this Policy, or in compliance with the law.

15. Contact Us

If you have questions or concerns about this Policy or the processing of your personal information, you can contact us:

We thank you for your trust and remain at your disposal for any additional information.

16. Sample Consent Form

Below is an example of the consent form we use to obtain your authorization regarding the collection, use, and disclosure of your personal information.