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Changes to this Privacy Policy
This Privacy Policy may be amended from time to time to take into consideration changes in legislation or other issues that may arise. We will provide notice to you of any amendments by posting the revised policy on our websites and/or sending it to you by mail. We may also notify you of any changes to this policy through a notice on your account statement. Your continued use of the account or Service (as defined below) following notice of such change means that you agree to and accept the new terms and conditions of the Privacy Policy as amended.
Definitions
In this Privacy Policy, the words “you” and “your” mean a person who browses one of our websites as a visitor or who has requested from us, enrolled in or signed an application in respect of any financial product or service offered by us (“Service”), including any co-applicants, guarantors or personal representatives. The words “we”, “our” and “us” mean Ally Credit Canada Limited (“ACCL”), ResMor Trust Company (“ResMor”) and ResMor’s product line “Ally”, and include any program or joint venture that we may participate in.
Collecting your information
At the time you begin a relationship with us and during the course of our relationship, we may collect personal information from you and about you such as:
- Your name, address, date of birth, occupation and identification, such as a valid driver’s license or passport, all of which are required by law;
- Information about your transactions, including account activity and how you intend to use the Service, and the source of any incoming funds or assets;
- Information you provide on an application in respect of any Service offered by us, such as your annual income, assets and liabilities and place of employment;
- Financial information such as your payment and credit history, and insurance information;
- Information we may need in order to provide you with a Service; and
- Information about beneficial owners, which is required under money laundering legislation.
We may collect this information directly from you and from sources outside our organization such as:
- Credit reporting agencies;
- Other financial institutions;
- References you have provided;
- Other service providers, agents, and other individuals or organizations such as independent deposit brokers with whom you make arrangements;
- Individuals authorized to act on your behalf under a power of attorney or other legal authority; and
- Government agencies and registries, law enforcement authorities and public records.
Using your information
We may use your personal information for the following purposes:
- To confirm your identity;
- To determine the suitability of our Services for you;
- To determine your eligibility for our Services;
- To set up, manage and offer Services that meet your needs;
- To provide you with ongoing Service;
- To contact you by various channels including mail, or electronically through an electronic mail, instant messaging or similar account or by telephone using the contact information you have provided;
- To help us collect a debt or enforce an obligation owed to us by you;
- To manage our risks and operations; and
- To prevent or detect fraud or criminal activity.
Marketing purposes
We may use your personal information for the following marketing purposes:
- To understand your financial needs and activities to help us serve you better;
- To tell you about other Services that may be of interest to you, including those offered by us, by our affiliate companies (i.e., companies in the Ally Financial Inc. group), and by third parties we select;
- To determine your eligibility to participate in, and to conduct and administer contests, surveys and promotions
Your consent to the use of your personal information for marketing purposes is not a condition of doing business with us and you may withdraw it at any time (see Refusing or withdrawing consent).
Disclosing your information
We may disclose your personal information to any person or organization for the following purposes:
- To help us manage our relationship with you;
- To satisfy legal and regulatory requirements that we believe are applicable to us, including the requirements of any self-regulatory organizations to which we belong;
- To respond to a court order, search warrant or other demand or request that we believe to be valid, or to comply with the rules of production of a court;
- To assist us when we sell all or part of our businesses or when considering such a transaction;
- To help us collect a debt or enforce an obligation owed to us by you;
- To manage our risks and operations; and
- To prevent or detect fraud or criminal activity.
We do not provide directly all the Services related to your relationship with us. We may use outside service providers to perform Services on our behalf such as printing, mail distribution, contact centre management and marketing. We may also share information about you with our affiliate companies (i.e., companies in the Ally Financial Inc. group) that provide data processing, storage and other specialized services, including Ally Financial Inc.
Some of our service providers are located outside of Canada. As a result, your personal information may be accessible to regulatory authorities in accordance with the law of these jurisdictions. When personal information is provided to our service providers, we will require them to protect the information in a manner that is consistent with our privacy policies and practices.
Additional information on collections, uses, and disclosures
Business transactions – We may release information we hold about you to the parties of a prospective business transaction, such as the sale or other disposition of any of our assets. We will require any prospective purchaser to protect the information provided, and to use it in a manner that is consistent with information practices set out in this Privacy Policy.
Contact information for marketing purposes – We may ask you for contact information such as your telephone, mobile or fax number, or e-mail address, and keep and use this information so that we may contact you directly through these channels for the purpose of marketing, including telemarketing. Your consent to this is not a condition of doing business with us and you may withdraw it at any time (see Refusing or withdrawing consent).
Credit information – We may obtain credit and other information about you from credit reporting agencies, creditor insurers, reinsurers, registries, and other persons with whom you may have financial dealings when you apply for or guarantee a loan. We may continue to do this throughout the relationship we have with you.
Social Insurance Number – We may collect, use and disclose your Social Insurance Number (SIN) for income tax reporting purposes, as required by law. In addition, we may ask you for your SIN to confirm your identity, as well as to verify and report credit information to credit bureaus and credit reporting agencies. This allows us to keep your personal information separate from that of other customers, particularly those with similar names, and helps maintain the integrity and accuracy of your personal information. You may refuse to consent to the collection, use, or disclosure of your SIN for purposes other than as required by law.
Telephone discussions / Live-chats – We may monitor or record any telephone call and Live-chat session we have with you, and the content of the call or the Live-chat session may also be retained. This is to establish a record of the information you provide, to ensure that your instructions are followed properly, and to ensure customer service levels are maintained.
Video surveillance – We may use video surveillance in and around our offices for the purpose of safeguarding our clients and employees, and protecting against theft, fraud, and vandalism.
Refusing or withdrawing consent
Subject to certain legal, regulatory, and contractual requirements and reasonable notice, you can refuse or withdraw your consent to our collection, use, or disclosure of your information at any time. However, depending on the circumstances, withdrawal of your consent may prevent us from providing you, or continuing to provide you, with some Services or information that may be of value to you.
We will act on your instructions as quickly as possible but there may be certain uses of your information that we are not be able to stop immediately.
You may not withdraw your consent to our ongoing collection, use, or disclosure of your personal information in connection to a loan you have with us or have guaranteed. We will continue to disclose your personal information to credit bureaus even after the loan or financing has been retired, and you may not withdraw your consent to our doing so. We do this to help maintain the accuracy, completeness, and integrity of the credit reporting system.
You cannot refuse our collection, use, and disclosure of information required by service providers essential for the provision of the Services or required by our regulators, including self-regulatory organizations. Some of our service providers are located outside of Canada. As a result, your personal information may be accessible to regulatory authorities in accordance with the law of these jurisdictions.
You can tell us at any time to stop using information about you to promote our Services or the products and services of our affiliates or third parties we select. To do so, simply call us toll-free.
Ally Deposits – 1-866-247-ALLY (2559)
If you are an existing customer, you may also withdraw your consent by logging into you account and sending us a message through Ally Secure E-mail.
ACCL and ResMor Auto – 1-877-659-ALLY (2559)
ResMor Broker Deposits – 1-866-513-4846.
You should be aware that if you decide to refuse or withdraw your consent, our ability to communicate with you will be diminished. For example, we will generally not be able to share with you promotions that may be of value to you.
Accessing your information
At your request, we will give you access to the personal information we hold about you. Most of this information is in the form of transaction activity records that are routinely available to you through your account statements, by telephone or Live-chat or by accessing our secure online sites.
If you require other information, simply contact us in writing and include sufficient detail to allow us to identify you and the specific information that you are requesting.
Ally Deposits – Customer Care, Ally, P.O. BOX 350, STN. C, TORONTO, ONTARIO, M6J 3N1 or via Ally Secure E-mail by logging into your account.
ACCL – Customer Service, Ally Auto Finance, P.O. Box 5000, STN. D. ETOBICOKE, Ontario M9A 5E3.
ResMor Auto – Executive Resolution Team, Ally Customer Service for ResMor Trust Company, P.O. Box 6390, STN. D, ETOBICOKE, Ontario, M9A 6C3.
ResMor Broker Deposits – Executive Resolution Team, ResMor Broker Deposit Operations, P.O. Box 350, STN. C, TORONTO, Ontario M6J 3N1.
Please note that there may be instances where access to your personal information may be restricted due to legal restraints, such as where our records contain confidential commercial information or references to other persons, or are subject to legal privilege.
Correcting your information
We are committed to keeping your personal information accurate, complete, and current. However, for most updates, we rely on you for information. You can assist us by keeping us informed of any changes, such as if you move or change your telephone or mobile number, or e-mail address. If you find any errors in our information about you, please let us know so we can update our records.
Questions or concerns
If you have a general question about our privacy policies, or a problem or concern, simply call us toll-free:
Ally Deposits – 1-866-247-ALLY (2559)
ACCL and ResMor Auto – 1-877-659-ALLY (2559)
ResMor Broker Deposits – 1-866-513-4846.
Chief Privacy Officer, Manager of our Privacy Program -1-866-497-6541
The customer care associate will also be able to provide you with additional information on our Customer Complaint Resolution Process if you wish to make a complaint.
In most cases, you can also have your question or concern reviewed by the Office of the Privacy Commissioner of Canada (OPC). The OPC oversees compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s private sector privacy law. You may contact the OPC toll-free at 1-800-282-1376 or by mail to Office of the Privacy Commissioner of Canada, 3rd Floor, Place de Ville, 112 Kent Street, OTTAWA, ONTARIO, K1A 1H3 or through the OPC Website at www.priv.gc.ca. |
