FirstReport Terms and Conditions and Privacy Policy

FirstReport Terms and Conditions



FIRSTREPORT USER AGREEMENT

March 8, 2017

This user agreement (this “Agreement”) governs your use of FirstReport services, whether you have purchased or received D+H FirstReport services, over the telephone, on the D+H FirstReport website, from your financial institution or another third party, or by any other means. In this Agreement, “Services” refers to D+H FirstReport services and includes all products, services, reports, alerts, apps and software that are provided with D+H FirstReport services. The Services are provided by D+H Limited Partnership (“D+H”). Please review this Agreement carefully. The current version of this Agreement may be accessed at: firstreport.ca/rbc

Service Description and Fees. The details of the Services, including your membership term and fees, are set out on the Services websites, mobile application and in the additional materials sent to you by D+H (which may include a welcome email or letter, billing confirmations, notices we send you from time to time or other supplementary materials relating to your Services which we send to you). You will be charged on a regular basis according to the billing period for your Services plan (monthly, annual and other periodic renewal). D+H may suspend or terminate your Services for non-payment. Service fees do not include any Internet access or mobile network carrier fees. You are responsible for HST and any other taxes. If you purchased the Services with a 30-day trial, you will not be charged during the first 30 days after your date of purchase. Unless you cancel your Services within that 30-day period, the charges for your Services will begin immediately thereafter.

Changes. D+H may from time to time change all or any part of this Agreement, the fees for the Services or the nature, content or features of the Services. D+H will provide at least 30 days’ advance written notice (by email or other means) of any change before it comes into force, setting out the new terms, the date of the coming into force of the change and your cancellation rights. You may cancel your Services before the effective date of the change (or within such longer period as may be required by law) without cost, penalty or cancellation indemnity. Unless you cancel the Service within that period, you will be deemed to have accepted the new Services and/or fees, whether or not you have accessed or used the Services during the intervening period.

Cancellation. D+H may cancel your Services for any reason. You may cancel your Services by contacting D+H at 1-855-826-5328, during regular business hours. If the billing period for your Services plan was annual or multi-year, you will receive a pro-rated refund as of the end of the Calendar month of your cancellation.

Privacy. In order to receive the Services you may be required to provide certain personal information to D+H. In the course of fulfilling the Services, D+H may access your personal information from one or more credit bureaus. D+H will handle personal information you provide in accordance with its privacy policy, which may be accessed at firstreport.ca/rbc

Technology. Any mobile application, software or other technology that you download or install is licensed, not sold, to you by D+H. You may not use any technology except as described in this Agreement. You may only install and use technology on a compatible device that you own or control. Should you install or use such technology on a device that you do not own or control, you assume all risk and liability that may result from such installation or use and agree to indemnify D+H for any claims or losses associated with such installation or use.

D+H may change any part of the technology or suspend or cancel your access to technology for any reason. D+H is not responsible for any damage or alteration to any device as a result of the installation or use of Services. Upon cancellation of your Services, you must remove all copies of the technology from your devices.

Right to Use. Only Canadian residents may purchase Services. The Services may only be accessed for personal, non-commercial use by you and other Family Plan users, if applicable. You may not copy, modify, translate, reverse engineer or create derivative works of the Services, distribute the Services to any other person or permit any other person to use or access your account, except in accordance with the terms of a Family Plan, if applicable. You may not use the Service to violate the rights of any other person.

Passwords. You must keep any passwords confidential and immediately advise D+H of any unauthorized use of your password. You are responsible for actions taken by any person that accesses or uses your Services, including any Family Plan users, even without your permission or knowledge. You take full responsibility and accept all risk for the use of your Services by any minor, and agree to indemnify D+H for any claims or losses associated with the use by any minor.

Credit Bureau Services. This section applies if your Services include credit bureau services such as credit reports, credit scores and/or credit monitoring and alert services. Credit bureau services are intended to keep you informed of your credit reports and score and to alert you to certain events affecting your credit score, which may help to detect the creation of new accounts through fraudulent use of your identity. No person may receive credit bureau services unless they are at least 18 years of age. Credit bureau services are generated and supplied by one or more of the credit bureaus in Canada and are not generated or supplied by D+H. You authorize and instruct D+H to obtain, monitor, compile and handle your credit information originating from credit bureaus. In order to receive credit bureau services, you must complete identification verification and authentication in accordance with the protocols of the applicable credit bureau(s). You are responsible for contacting D+H to complete this process. D+H may have performed a preliminary authentication at the time of sale. Unless you have completed full identity verification and authentication you will not be able to access credit bureau services and you will be charged even if you have not completed authentication. For details on how to complete this authentication process, consult your welcome package or contact D+H at the number listed below.

Any credit score provided with the Services is based on the associated credit bureau’s proprietary score model; lenders and other creditors or third parties may use a different score to evaluate a person's creditworthiness. The Services are not intended to provide you with any advice or assistance for the purpose of improving your credit report, credit history or credit score. The Services do not include any review of your credit information for accuracy; you are responsible for contacting the credit bureaus directly to correct any inaccuracy. Credit bureaus may impose additional terms and conditions on your access to and use of credit bureau services.

Online Identity Monitoring. This section applies if your Services include online identity monitoring. Online identity monitoring will provide periodic searching of the Internet for your registered information using a third-party Internet search provider. Our service provider will scan selected areas of the Internet where it suspects consumer information is bought and sold, such as unencrypted chat rooms, malicious websites, and black market sites, for detection of any matching information associated with your registered personal information. In the event the Service detects a monitored item, we will notify you via your selected method of notification. However, the Internet addresses of these suspected Internet trading sites are not published and frequently change, so there is no guarantee that the Service will locate and search every possible Internet site where consumers' personal information is at risk of being traded.

In order to use online identity monitoring Services, you must first register your payment and/or personal information and activate online the particular monitoring Services you wish to use. The type of information you may register for monitoring are described on the Services website and in the additional materials.

This Service relies on the information contained in many third party databases to provide you the Services, and does not scan or search the entirety of the Internet. We cannot guarantee the accuracy or completeness of such third party databases. Due to the dynamic nature of public records, and reliance on the accuracy of third party data sources, we do not promise to detect all possible occurrences of identity theft. We are not responsible for and do not represent the accuracy of third party databases.

Lost Wallet Assistance. This section applies if your Services include lost wallet assistance. In order to use lost wallet assistance Services, you must first register your eligible payment cards (including any credit or debit card you purchased the Services with) with us. This Service may be subject to restrictions on the number or types of cards or documents you may register. You are responsible for completing the registration process; for details, consult your welcome kit, the website or contact D+H at the number listed below. You are responsible for contacting D+H to complete this process; for details, consult your welcome package or contact D+H at the number listed below.

D+H will act as your agent for the limited purpose of delivering notifications to and dealing with your registered card issuers if you report any notification event such as card loss or theft, change of address or other status update with respect to your registered cards. D+H’s responsibility is limited to notifying your registered card issuers of the notification event on your behalf. D+H is not responsible for the completion of any action with respect to your card or account, including cancelling, changing the address of or placing a hold on your card or account. D+H does not promise or warrant that any such notification will be implemented by your card issuer or be effective.

Document Registry Services. If your subscription to the Services began prior to May 14, 2017, your Services may include a registry feature. These services are intended to allow you to record certain important information with us for safe keeping. Information you store with us for this service is not monitored and is not eligible for lost wallet assistance. Only certain types of information are eligible for registration. We do not validate the accuracy or completeness of any information provided as part of document registry services. Registry will not be available for any subscriptions purchased after May 14, 2017. For details about this service, including eligible types of information applicable to your subscription, please review our privacy policy and consult the website, or contact D+H at the number listed below.

Identity Theft Assistance. This section applies if your Services include identity theft assistance services, including identity restoration services, limited power of attorney and fraud monitoring. If D+H provides you with any information on preventing identity theft, including any third party materials, this information is provided without warranty of any kind and your reliance on any such information is at your own risk. If you choose to use identity restoration services with limited power of attorney, you will be required to agree to a power of attorney agreement with a lawyer or other expert. You will be responsible for any legal or other fees or expenses required as part of the limited power of attorney option. You will be responsible for any legal or other fees or expenses required as part of the limited power of attorney option. D+H or its service provider will assist you with coordinating access to these experts but does not monitor their actions or performance. This Service is not a form of insurance. These services are intended to help you mitigate the effects of identity theft and there is no guarantee your identity will be restored.

Family Plan Memberships. This section applies if you purchased Services as the primary account holder under a family plan or other multiple user offering (a “Family Plan”). As the primary accountholder you authorize and instruct D+H on behalf of each other person receiving Services under your account, and you represent that you have the authority to do so. You are responsible for ensuring each Family Plan user completes credit bureau identification verification and authentication, if applicable. As the primary accountholder, you will be charged even if a user under your Family Plan has not completed identity verification and authentication. Only the primary account holder may cancel Family Plan Services.

Third Party Materials and Services. You may be directed or provided access to third party services, products, materials or web sites, including promotional or incentive offers (collectively, "Third Party Services"). This Agreement extends to the benefit of the providers of Third Party Services. You may be required to accept additional terms of service before using any Third Party Services. Your use of Third Party Services is at your own risk. D+H takes no responsibility for performance of Third Party Services.

NO WARRANTIES. The Services are provided on an “as is” and “as available” basis without warranty of any kind, and your use is entirely at your own risk. To the maximum extent permitted by law, D+H disclaims all warranties with regard to the Services including any implied warranties of merchantability, satisfactory quality, fitness for a particular use or purpose, accuracy, quiet enjoyment, and non-infringement of third party rights. No oral or written information or advice given by representatives of D+H or any institution with which we have a joint marketing arrangement (including your financial institution or card provider) constitutes a warranty. For product benefits you must consult the Services website and the materials sent to you by D+H. D+H provides the Services over the Internet and mobile networks, or by mail, and as a result the quality and availability of the Services may be affected by factors outside D+H’s control and are not guaranteed.

LIMITATION OF LIABILITY. To the maximum extent permitted by law, in no event will D+H or any of its affiliates, licensors, suppliers, third party providers or agents (or their respective employees, officers, directors or representatives) (each, a “D+H Party”) be liable for any personal injury, damage to property or indirect losses of any kind in connection with the Services, including losses relating to identity theft, unauthorized use of your credit cards, unauthorized use of your personal information by third parties, inability to use your credit cards including while travelling, fraud, damage to your credit rating, or to any errors, omissions, or other inaccuracies in Services or the content, materials or information provided or available through the Services, whether or not any D+H Party is made aware of the possibility such losses and whether the losses are based on breach of contract, tort (including negligence), product liability or otherwise. No D+H Party nor any credit bureau will be liable for any damages caused by delayed or non-delivery of, or inaccurate or incomplete information in any credit bureau services, or your reliance on the results of any credit bureau services. The maximum total aggregate liability of all D+H Parties to you for all damages (other than as may be required by applicable law) relating to your use of Services, is limited to the greater of ten dollars ($10.00) and the amount paid by you for the Services during the six months prior to the date your claim arises. You are personally responsible for any damages, losses or expenses you suffer or incur above those amounts.

Indemnification. You are responsible for any losses incurred by any D+H Party in connection with: (a) your breach of this Agreement or any applicable policy, instruction or guideline issued by D+H; (b) your use of or inability to use the Services; (c) any content generated or provided by you in the course of accessing or using the Services; or (d) your violation or misuse of any intellectual property of a third party. You agree to indemnify D+H Parties against any such losses.

Assignment. Subject to applicable laws, D+H may transfer or assign your Services agreement upon 30 days’ notice. If D+H is the provider of the Services to you through a joint marketing arrangement between D+H and your financial institution or credit card provider, then this Agreement is transferrable at any time to your financial institution or credit card provider, or to a new service provider designated thereby. In the event of a transfer, D+H makes no representations as to the content or quality of any replacement services.

General. This Agreement, together with your agreement to purchase the Services (as applicable), the privacy policy and the terms relating to fees and subscription periods set out in the materials sent to you by D+H, constitute the entire agreement between you and D+H relating to the Services. This Agreement will govern to the extent of any conflict or inconsistency with any Service website or application, any materials provided to you by D+H or with any statements made by representatives of D+H, your financial institution or credit card provider or any institution with which we have a joint marketing arrangement. Any part of this Agreement which may expressly or by implication extend beyond cancellation of your Services will continue indefinitely following cancellation. If any provision of this Agreement other than sections titled “No Warranties” and “Limitation of Liability” is void or declared void, the remaining provisions will remain in full force and effect. If any part of the Sections titled “No Warranties” and “Limitation of Liability” is void or declared void then your Services will immediately and automatically be cancelled without further notice. This Agreement and all related documents and materials are intended to be governed by and interpreted in accordance with the laws of the Province of Ontario. You submit to the exclusive jurisdiction of the courts of the Province of Ontario with respect to any matter arising from the Services or this Agreement. You confirm your express wish that this Agreement and all documents related thereto be drawn up in the English language. Vous confirmez votre souhait expresse de voir la présente convention et tous les documents s’y rattachant être rédigés en anglais.

If you have any questions regarding the Services or this Agreement please contact D+H at 1-855-826-5328.

© 2017 D+H Limited Partnership, all rights reserved. FirstReport, D+H and all associated logos are trademarks of D+H Limited Partnership.

FirstReport Privacy Policy

Last Modified: March 8, 2017

The FirstReport service (“Service”) is a service provided by D+H Limited Partnership (“we”, “us” or the equivalent).

This privacy policy ("Privacy Policy") is designed to help you understand how we collect, use, and manage Personal Information and to whom this information may be disclosed. “Personal Information” means any information about an identifiable individual but does not include the name, title, business address or telephone number of an employee or organization. As used in this Privacy Policy, the term Personal Information includes Personal Information relating to you.

This Privacy Policy applies to the Service but does not extend to the data management practices of third-party sites that may be linked to the Service.

When you become a subscriber to the Service, you agree to the terms of this Privacy Policy as updated from time to time.

Accountability

We are accountable for all information under our custody and control. We have a dedicated Privacy Office, headed by our Chief Privacy Officer who is accountable for guiding our compliance with the principles set out in this Privacy Policy. See below for details on how to contact our Chief Privacy Officer.

Consent

By subscribing to the Service you consent to the collection, use, disclosure and management of your Personal Information as described in this Privacy Policy.

You may withdraw your consent to the use of Personal Information by contacting the Chief Privacy Officer as provided below. However, if you withdraw your consent you will not be able to continue to use the Service.

Collection of Information

We may collect the following Personal Information in connection with your subscription to the Service:

  • First, middle (optional), and last name;
  • street name and number (and/or apartment #);
  • city;
  • province;
  • postal code;
  • language preference
  • date of birth;
  • email address;
  • home phone number;
  • business phone number (optional);
  • cell phone number (optional, unless you would like to receive alerts and notification of changes via text message);
  • credit card type, number, expiry date;
  • a username and a password, to authenticate you on the Service website or mobile app;
  • selection of two security questions, to enable us to authenticate you when you call us for assistance; and
  • an answer to each security question.

In addition, you may also be required to provide or authorize us to collect the following Personal Information in order to use certain Service features. Providing such information is voluntary. The Personal Information which we may collect depends on Service features available as part of your Subscription; consult our website or the materials provided with your subscription for details:

Credit Bureau Services: This section applies if your subscription includes Credit bureau Services such as credit reports, credit scores and/or credit monitoring and alerts. We may collect your personal information from you and provide to credit bureaus in order to fulfill credit monitoring services. In the course of providing these services we may, based on the authorization you have provided, retrieve your credit information from credit bureaus on your behalf and provide that information to you. Credit information is defined by applicable provincial legislation and may include information such as: your name, current/ former address, date of birth, marital status, social insurance number, current/ former employment, credit history, paying habits, outstanding debt obligations, estimated income, cost of living obligations, and other information. You may also be required to provide or confirm other personal information, including certain elements of your credit information, with us or a credit bureau in order to verify your identity and access these services.

Online Identity Monitoring: This section applies if your subscription includes online identity monitoring Services, including online credit card monitoring and/or online personal information monitoring. We collect the following Personal Information when you use this Service:

  • Other Personal Information you register for the purposes of monitoring, which may include:
    • e-mail addresses
    • social insurance number
    • phone numbers
    • payment card numbers
    • bank account information
    • drivers’ license number
    • passport numbers
  • The types of Personal Information available for monitoring may change over time. Please consult your Services subscription materials and the website for details.

Lost Wallet Assistance: This section applies if your subscription includes lost wallet assistance Services. We collect the following Personal Information when you use this Service:

  • Payment card numbers (including credit card and debit card numbers) you register with us so we can report any loss or theft to the card issuer.

Identity Theft Assistance: This section applies if your subscription includes identity theft assistance Services. We collect the following Personal Information when you use this Service:

  • previous mailing address (optional). This information will be required in the event of fraud to initiate credit monitoring and fraud alert services;
  • Personal Information not previously provided to us which may be necessary to report and remediate an identity theft;
  • any Personal Information required by any power of attorney service provider or other third party engaged to provide identity theft assistance services.

Registry: If your subscription to the Services began prior to May 14, 2017, your Services may include a registry feature. If your subscription began prior to May 14, 2017, you may provide some or all of the following types of information to us in connection with this feature:

  • Debit/Credit Card numbers
  • Retail/Loyalty Points Card numbers
  • Financial Account numbers
  • Government Document numbers
  • Asset details
  • Investment details
  • Insurance Policy details
  • Subscription details and numbers
  • Membership details and numbers
  • Contacts
  • Other Important Documents

If your subscription includes the registry feature, and if you registered certain information prior to May 14, 2017, we will continue to store and provide access to that information as part of this feature. We will not accept registry of the following types of information after May 14, 2017.

  • Passwords/PINs
  • Prescription details
  • Mobile Phone numbers

Please note that we do not validate the accuracy or completeness of any information provided as part of document registry services.

Registry will not be available for any subscriptions purchased after May 14, 2017. Details about this service may be obtained by reviewing your subscription materials or by contacting our customer service department at the contact information set out on the website.

Date Reminders: If your subscription to the Services began prior to May 14, 2017, your Services may include a date reminder feature. If you use this feature, for each reminder you may provide us with a reminder date, message title and message for us to send to you. Please note that reminder notices are automated; we do not review or validate the accuracy or completeness of any information provided as part of date reminder services. Date reminders will not be available for any subscriptions purchased after May 14, 2017. Details about this service may be obtained by reviewing your subscription materials or by contacting our customer service department at the contact information set out on the website.

Website Collection of Information

When you visit the Services website or download the Services mobile app, information is collected by us as you interact with the website or mobile app. We collect certain information from your browser using "cookies". Cookies are small files that are stored on your computer that help us to optimize your experience on the Services website or mobile app. We may use cookies to monitor and improve the website or mobile app experience. These cookies do not contain Personal Information. They gather statistical data such as the average time spent on a specific webpage. This kind of information provides us with insight on how to improve the design, content and navigation of the website and mobile app. Your choice not to accept these cookies will not interfere with your use of the Services.

We may also use cookies as part of the functionality and security of the Services. These cookies may include a persistent cookie installed on your computer or device that contains information to help us verify you as the subscriber and to help block unauthorized attempts to access your information through the website or mobile app. Your choice not to accept these cookies may interfere with your ability to personalize and be recognized by the website or mobile app, and/or may prevent the operation of the services or certain features within the services from operating.

Mobile App Collection of Information

We also collect information about your device such as device model, unique device number, browser type, and IP address. Information about your device helps us to improve the functionality of the Services mobile app, meet our clients’ needs, measure the effectiveness of our services, enhance security measures and protect you.

When accessing the services through the Services mobile app, no Personal Information will be stored on your device. If you choose to use the “Remember Me” functionality, the Services mobile app will store your username and password to help us verify you as the subscriber and recognize you in future sessions.

When you use the mobile application, the app will determine your current location and report that information to us. We may collect this information in order to provide or enhance product functionality, optimize user experience, or for statistical analysis and product development. We will not share your current location with other users or partners. If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application.

Use of Your Personal Information

We may use your Personal Information:

  • to verify your identity and provide the Services and customer support you request, including but not limited to the following Services:
    • Credit Bureau Services (including to monitor your credit bureau file and providing you with credit reports, scores and alerts);
    • Online Identity Monitoring;
    • Lost Wallet Assistance;
    • Document Registry; and
    • Identity Theft Assistance.

This may include disclosure of the information we collect, as described above, to non-affiliated third parties that are acting on our behalf or with whom we interact in performing the Services, including:

    • Credit bureaus.
    • Companies that perform data searches and support services for us.
    • Parties with whom there may be possible cases of identity theft or fraud, and then only to detect the actual facts or to resolve the case.
    • Parties which could include governmental units, courts or other entities (in response to subpoenas and other legal processes), and those with whom you have requested us to share information.
    • To obtain information which may help detect fraud or identity theft.
    • To notify appropriate parties of possible identity theft or fraud.
  • for administrative purposes;
  • to understand your needs and preferences so that we may notify you of new service offerings or send you advertisements that respond to your needs or preferences based on your communication preferences
  • to resolve disputes, collect payments, and troubleshoot problems;
  • on an aggregate, non-identified basis for the purposes of planning a service or product and to monitor patterns, gather data and generate reports. This aggregated information may be published or shared with third parties. We or our service providers may perform statistical analyses of user and online behaviour and characteristics to measure interest in and use of the Services so as to improve the Service. We or our service providers may also perform various analyses of de-identified online interactions and activity of the users we monitor to improve the usefulness of our alerts, as well as to provide behavioral and statistical insight and context across the system.
  • to process payment transactions;
  • to send you notices about your transactions; and
  • to provide a record of correspondence with you, whether by telephone, mail, email or text message, to ensure instructions are properly followed and to ensure customer service levels are maintained.

We may also monitor or record any telephone call we have with you. Monitoring and recording of calls is done to establish a record of the information you provide; to ensure that instructions are properly followed; and to ensure customer service levels are maintained. We will inform you of the possibility that your call is being monitored or recorded prior to proceeding with the call. If you prefer not to have your call recorded you can conduct your transaction online or contact our Chief Privacy Officer to arrange an alternate procedure.

Disclosure of Personal Information

We do not sell, rent or trade any Personal Information to any third party for financial gain or marketing purposes. Except as stated in this Privacy Policy, we will not disclose your Personal Information to any persons other than you without your prior consent, unless as permitted or required by law, for example:

  • to a government institution, law enforcement or other authority that has lawful authority to obtain the information;
  • to comply with a subpoena or warrant or an order made by a court, person or entity with jurisdiction to compel the production of information;
  • in urgent circumstances to protect the life, health or security of any person; or
  • to comply with court rules regarding the production of records and information.

We may transfer certain Personal Information to business service providers, but only to provide the Services and fulfill the purposes as described in this Privacy Policy. When we do, we select a company carefully and, by contractual means, ensure that it uses privacy and security standards comparable to ours.

As part of the Services, we may retrieve your credit bureau information from credit reporting agencies on your behalf and provide that information to you. We do not disclose your credit bureau information to anyone but you, except to our service providers who help us provide the Services to you.

We may disclose your Personal Information in connection with a corporate reorganization, merger or amalgamation, provided that the use of such Personal Information so disclosed continues to be the use permitted by this Privacy Policy.

Your Personal Information may be transferred, stored and/or processed by us or by our third party service providers outside of the country where you reside, such as in the United States. In that case, your Personal Information would be subject to the laws of the country in which it is stored or transferred. That country may have laws that require your Personal Information be disclosed to the government under different circumstances that exist in your country of residence.

Safeguards

We have implemented reasonable technical, physical and administrative safeguards designed to protect Personal Information from unauthorized access, use, modification, disclosure, or other breach of privacy. We have comprehensive physical and logical security policies and procedures, based on industry best practices, designed to address practices for the secure access, storage, transmission, and disposal/destruction of Personal Information. We will maintain appropriate security upon the disposal and destruction of Personal Information.

In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of Personal Information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

Information Security

When you transmit Personal Information to us through the Services website, that information is encrypted using the 128 bit SSL security protocol (Secure Sockets Layer) which encrypts the information channel from your computer to our server over the Internet. We also use SSL to allow you to securely view your on-line account and registration information. Furthermore, your credit/debit card information is encrypted using the 256 bit AES (Advanced Encryption Standard) encryption algorithm and stored in a database.

Other than limited access by us in order to carry out the Services as described above, your Personal Information is accessible only by you using a password created by you. To protect the security of your Personal Information, you must keep your password confidential. You are responsible for all uses of Services by anyone using your password, including any disclosures of Personal Information.

Openness

We will make available information about our general policies and practices relating to the processing of Personal Information. We will not make available information about processing or management of Personal Information for a specific customer except to that customer or as directed by that customer.

Accuracy of Personal Information and Access

We rely on you to ensure the Personal Information you provide to us is accurate and up to date for the purposes set out in the Policy.

You may update, review or correct your Personal Information at any time on-line by accessing your password protected registration page or by contacting our Chief Privacy Officer as specified under “Questions or Concerns About Your Privacy” below.

Limiting Retention

We will keep Personal Information that remains relevant for the intended purposes or as required by law. We may keep Personal Information about you in our records as long as it is needed for the purposes described above, including statutory or regulatory retention requirements, even if you cease to be a customer.

Your Services may been offered to you in association with your financial institution. If directed by your financial institution, we transfer your account information and Personal Information to your financial institution or to your financial institution’s new service provider, in accordance with the terms of any agreement between us and your financial institution. After the transfer, we will retain your Personal Information only for the period of time necessary for purposes described in this privacy policy. You are advised to consult with your financial institution directly with respect to its treatment of your Personal Information and account information.

Once Personal Information is deleted, you will not be able to access it any longer.

Changes to the Privacy Policy

We regularly review all of our policies and procedures and as a result may change this Privacy Policy from time to time. The most recent modification date of this Privacy Policy will appear at the top of this page. If we materially change our practices in processing Personal Information, we will post an updated policy in place of this Privacy Policy, to keep you informed of what information we collect, how we use it and with whom we share it. Your continued access and use of the Services after the effective date of any changes to this Privacy Policy constitutes your acceptance of all such changes.

Links to Third Party Websites

The Services website may contain links to other websites that operate independently of the Services and that are not under our control. We provide links to other websites solely for your convenience and information. Other websites may have their own privacy policies, which we suggest you review if you visit any linked websites. We are not responsible for information that is collected through those websites or for any other use or disclosure of information by the operators of those websites.

Questions or Concerns About Your Privacy?

We welcome you to contact us at any time should you have any questions, comments or concerns regarding this Privacy Policy or the manner in which we or our service providers treat your Personal Information. Please contact our Chief Privacy Officer at the coordinates listed below:

Chief Privacy Officer
D+H
120 Bremner Blvd.
30th Floor
Toronto, ON M5J 0A8
Email: Privacy.officer@dh.com