Personal Information Protection Policy
At Paragon Financial, we are committed to providing our customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers, protecting their personal information is one of our highest priorities.
While we have always respected our customers privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses may collect, use and disclose personal information.
We will inform our customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ personal information and allowing our customers to request access to, and correction of, their personal information.
Personal Information –means information about an identifiable individual (E.g., name, personal e-mail address, home address and phone number). Personal information does not include publicly available contact information (described below).
Contact information – means publicly available information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Paragon Financial complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect customer information that is necessary to fulfill the following purposes:
- To verify ownership of customer products in our care;
- To identify customer order preferences;
- To communicate in preferred channels with our customers;
- To deliver requested products and services.
1.3 We will make all reasonable attempts to guard any personal information you submit electronically via forms on this website or via email.
1.4 We only collect information from our website that is typed into forms, submitted via email, or broadcast by browsers to identify appropriate software settings and visual preferences. No private information about customers or visitors to our website site is collected in any other manner.
Policy 2 – Consent
2.1 We will obtain customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, in writing, electronically, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the customer does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation) customers can withhold or withdraw their consent for Paragon Financial to use their personal information in certain ways. A customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as to contact our customers directly about products and services that may be of interest.
3.2 We will not use or disclose customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 We will retain customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer personal information is accurate and complete.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.3 We will use appropriate security measures when destroying customer’s personal information such as shredding documents and deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Customers Access to Personal Information
7.1 Customers have a right to access their personal information. Upon request, we will tell customers how we use their personal information.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer
8.1 The Privacy Officer or designated individual is responsible for ensuring Paragon Financial is in compliance with this policy and the Personal Information Protection Act.
8.2 Customers should direct any complaints, concerns or questions regarding Paragon Financial compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Name of organization’s Privacy Officer:
1401-1130 West Pender Street
Vancouver, BC Canada
Telephone: (604) 685-3264