Privacy Policy

FSUAP is committed to keeping your information and personal information (collectively, the “Information”) accurate, confidential and secure. Your Information is handled in accordance with this policy and all provincial and federal privacy laws and regulations including the Personal Information Protection and Electronic Documents Act (“PIPEDA”), any Acts or Statutes relating to electronic execution of documents or transactions and the Act Respecting the Protection of Personal Information in the Private sector (the “ACT”) or any other similar applicable federal or provincial legislation.

Personal information

FSUAP limits the amount and type of Information it collects for you, and will collect Information only for purposes it has already disclosed to you, or as permitted by law. The Information FSUAP collects is with consent and may include but is not limited to:

Contact information such as your name, postal address, e-mail address and telephone number;
Information FSUAP received from you in connection with your application for credit, including employment information and your income, assets, your source of revenue (list of providers and source of revenue), information regarding your debts and expenses, home rental or ownership information and the amount of your financial obligations, date of birth, financial institution information, and other information to assist in obtaining a credit report;
Your permit or license information;
Banking information, including your account number and other information needed for pre-authorized payments;
Information and documents to help us verify your identity;
Information regarding the equipment that you propose to lease or buy and in connection with your proposed lease or financial transaction, including your payment history;
Information FSUAP obtains about you from credit reporting agencies;
Your IP address; and
Information you supply to FSUAP that FSUAP did not request (such as Information you voluntarily put into an email to FSUAP).

If you are a physical person, you are not required to provide FSUAP with your social insurance number (“SIN”). However, if you do provide your SIN to FSUAP, with your consent, FSUAP may use your SIN as a unique identifier to ensure that the credit information requested is about you, rather than someone else with the same or similar name.

Use of the Information

FSUAP uses Information to provide credit to clients and otherwise administer its business with other stakeholders to approve/administer lending or leasing transactions, verify identity in compliance with requirements under anti-money laundering legislation and verify current and ongoing creditworthiness.

More specifically, FSUAP will therefore only use the Information that it has collected for the purposes for which it was collected. FSUAP collects your Information for the following purposes and in accordance with applicable laws:

To provide its clients with its services;
To evaluate the credit application and ongoing creditworthiness and solvency;
To enter into lease or loan transaction with its clients;
To manage, administer, collect amounts owing under and enforce any such lease or transactions;
To respond to inquiries regarding any credit application and any resulting lease or financial transaction;
To verify and confirm your identity;
To establish a record of the information provided;
To take or verify instructions from its clients;
To establish and maintain commercial relations with its clients, including responding to questions regarding its services;
To respond to questions sent by, mail, email or through its Website;
Subject to applicable law, to notify clients about other services and events provided by FSUAP, which may be of interest to its clients;
To customize the appearance of the Website displayed to its clients;
To obtain your feedback regarding its Website and services, including its surveys;
To track behavioral information on the Website, in order to serve similar content upon future visits;
To support its business functions and operations such as internal business processes, marketing, staff training, maintaining quality service levels and advertising;
To meet any legal or regulatory requirements; or
To verify, confirm and track insurance coverage, as it may be required by contracts entered into with its clients.

When does FSUAP collects and discloses the Information

FSUAP obtains consent when or before it collects, uses or discloses Information. Generally, FSUAP will seek consent to use and disclose Information at the same time it collects the Information from you. FSUAP will use or disclose Information only for the reasons it was collected, unless consent is given to use or disclose it for another reason. FSUAP will keep Information only as long as necessary for the identified purposes.

FSUAP may receive and communicate Information from and to third party sources, such as credit reporting agencies, employers, insurers, financial institutions, service providers and manufacturers. You authorize the collection of Information from these sources and, if applicable, authorize these sources to give FSUAP your Information for the above-mentioned purposes.

By using FSUAP Website, its services and by supplying Information, you acknowledge that you have read and understood this Privacy Policy, and you agree and consent to the collection, use, disclosure and other processing of your Information, as outlined in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use FSUAP Website or services or supply your Information to FSUAP on a credit application, or otherwise.

Under certain exceptional circumstances, FSUAP may have a legal duty or right to disclose Information without your knowledge or consent. FSUAP may disclose Information without consent when required or permitted by law including: in the context of subpoenas, search warrants, other court and government orders, debt collection or demands from other parties who have a legal right to the Information and disclosure of Information to FSUAP legal or financial advisers.

FSUAP may also use and disclose your Information to service providers, data processors and other third parties under the following limited circumstances:

To third parties, that assist with FSUAP operations, its Website and its services including, without limitation, for customer services, business operations, monitoring and analyzing Website activity, and operating and maintaining the Website. Such third parties may only use your Information for the purposes described in this Privacy Policy;
To Third Parties who assist in processing your lease or credit application or administering your lease or financial transaction with FSUAP, including, without limitation, credit reporting bureaus, financial institutions, insurance companies or brokers, equipment manufacturers, equipment dealers, government agencies, and persons to whom you have applied for credit;
- When necessary to protect FSUAP safety, property or other rights, its representatives, customers and users of the Website, including to detect and prevent fraudulent activity;
With your consent; or
As otherwise required or permitted by law.

Your Information may be transferred to a third party or parties to be used for the same purposes described herein if a lease agreement of financial transaction is transferred or assigned to such third party or parties, or to an organization in connection with the due diligence for, and completion of, a business transaction, including, without limitation, a securitization or financing involving FSUAP.

If FSUAP sells or transfers all or a portion of its business or assets to a related company or a third party, your Information will remain subject to FSUAP Privacy Policy

FSUAP may process and transfer Information on its servers or to third party servers located outside of the province it was originally collected and in jurisdictions whose data protection laws may differ from those of Canada, such as the United States of America. As a result, Information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions. For example, Information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions. FSUAP will use reasonable efforts, including conducting Privacy Impact Assessments (“PIA”) where necessary, to ensure that appropriate protections are in place to require third parties to maintain protections measures and practices on Information that are equivalent to those that apply in Canada.

Safeguards

FSUAP will protect Information with safeguards that are appropriate to the sensitivity of the Information and will safeguard Information in its possession or control from loss or theft and from unauthorized access, disclosure, duplication, use or modification.

The safeguards employed by FSUAP to protect Information will vary depending on the sensitivity, amount, distribution, format and storage of the Information.

FSUAP will safeguard personal information in its possession or control through security measures, such as, for example:

Regular staff training regarding privacy and treatment of information that is used in FSUAP normal business practices;
Physical security, such as secure locks on filing cabinets and restricted access to offices;
Organizational security, such as controlled entry in data centers and limited access to relevant information;
Electronic security, such as passwords, multi-factor authentication, personal identification numbers and encryption; and
Conducting PIAs when needed, namely developing or overhauling any information system or electronic service delivery system that involves the collection, use, communication, keeping or destruction of Information.

Should a confidentiality incident occur, despite FSUAP best effort to prevent same, FSUAP will take immediate reasonable steps to reduce the risk of harm and to prevent further incidents of a similar nature, and will notify you of such incident, where required by law

Information retention, destruction and anonymization

FSUAP will use care when disposing of, archiving, destroying or anonymizing personal information in order to prevent unauthorized access to the information.

In addition, FSUAP will only retain your Information as long as it is required to fulfill the purposes for which it was collected and to comply with FSUAP legal obligations. FSUAP has adopted practices to ensure that its employees are able to periodically identify Information that needs to be destroyed, and the procedure for doing so.

In accordance with generally accepted best practices, applicable laws and regulations, FSUAP may anonymize some of the Information that allows to personally identify you. Such anonymized Information may include, without being limited to, information FSUAP collects from your use of its Website, and may by used by FSUAP for any serious and legitimate purpose identified by Sonomo, and, subject to applicable law, discloses to third parties.

Access to personal information

You have the right to inquire as to what Information FSUAP has in its possession and what it is being used for, a right to access that Information and to know to which third parties FSUAP has disclosed that Information. Clients may direct their requests by telephone or email to FSUAP Privacy Officer, whose information appears in the present Privacy Policy. You may request to update and change your Information when it is inaccurate, incomplete or equivocal. Where appropriate, the amended Information will be transmitted to third parties having access to such Information.

Subject to legal and contractual requirements, you may refuse or withdraw a consent to certain of the purposes identified in this Privacy Policy at any time by contacting FSUAP Privacy Officer at the contact information set forth below. If you refuse or withdraw a consent, you acknowledge that FSUAP may not be able to provide or continue to provide you with certain services or information that may be of value. However, you may not be permitted to withdraw your consent to certain necessary collection, uses and disclosures of your Information.

You may request FSUAP to delete, destroy or remove your Information if it is obsolete or no longer necessary for the purposes for which it was collected or for which you have given your consent, subject to retention periods provided by applicable law.

Electronic communication

When entering into a commercial relationship with FSUAP, you may have also have consented to receive electronic communications from FSUAP. If you provided consent to receive such communications, FSUAP may use the Information to communicate with you regarding its products, services and promotions, provide you with other information that you request, and/or improve its product and service offerings. You will always have the opportunity to withdraw your consent for receiving any of FSUAP electronic communications.

How to contact FSUAP

FSUAP has appointed a Privacy Officer who shall be responsible for its compliance with applicable privacy laws and this Privacy Policy. If you have inquiries regarding your Information held by FSUAP or if you wish to address a challenge regarding FSUAP compliance with this Privacy Policy, you may contact FSUAP Privacy Officer in writing at the email address listed below:

PRIVACY OFFICER: Michael Dubowec – President
TELEPHONE: 514.317.2756
EMAIL: conseiller@fsuap.com

All inquiries and concerns will be fully investigated and responded to by FSUAP Privacy Officer.

This Privacy Policy is subject to applicable privacy laws and FSUAP right to change it at any time, at its sole discretion.

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