This Policy was last updated on July 17, 2023.
For purposes herein, “personal information” means information about an identifiable individual.
THE INFORMATION WE COLLECT
New Leaf offers consumer credit counselling services.
The types of personal information we may collect include: name and contact information, date of birth, language preference, credit information, debt information, income and financial information, as well as social media user identification names. In addition, we may collect certain information such as cookies, IP addresses, web beacons, or other information that cannot be used to directly identify an individual but may still be used to identify the individual when combined with other information which may be available in the public records. We may record calls to or from our staff for purposes of accuracy, performance reviews and training.
HOW WE COLLECT INFORMATION
New Leaf collects information by various methods including information actively provided by its clients, and (with consent) credit checks and information arising from our credit counselling services.
HOW WE USE THIS INFORMATION
The personal information we collect is only used to provide our services to our clients. The client’s contact information may also be used for other internal purposes such as sending New Leaf’s newsletters, updates, announcements and other information or to better serve our clients.
New Leaf may use aggregated or anonymous information which will not be linked to identified individuals for various other uses for itself and third parties.
WHO WE SHARE THIS INFORMATION WITH
New Leaf does not share personal information with third parties except as required to provide or improve our services. The nature of our services requires New Leaf to disclose personal information to creditors. New Leaf may provide personal information to its consultants, subcontractors and professional advisers or other third-parties (each of which shall be bound by privacy obligations) to assist New Leaf uses disclosed herein. If New Leaf refers a client to a third party for advice or services New Leaf does not provide, it will share that client’s personal information with the third party after the client agrees to use such services.
New Leaf will disclose personal information without an individual’s knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of an individual’s personal information. If we receive a request from a police officer or other law enforcement agency for access to your personal information in the course of an actual or potential investigation, our policy is to require the police officer or law enforcement agency to obtain an order, subpoena or warrant, unless the information is urgently required to prevent serious bodily injury or serious damage to personal property. If we receive a written request from a police officer or other law enforcement agency with authority to request access to your personal information in the course of an actual or potential investigation into a breach of a law, our policy is to provide the requested information.
Personal information is stored in a combination of paper and electronic files. These files are protected by security measures appropriate to the nature of the information. Client data on New Leaf’s network is encrypted in transit and all data is encrypted at rest. Backups are run at least once per day and all backups are encrypted, air gapped and zero trust.
You will be promptly notified in writing in the event of theft, loss, unauthorized use or release of your non-public personal information.
Individuals may review their personal information contained in New Leaf’s files by contacting the New Leaf Credit privacy officer at the email address provided at the end of this Policy. If an individual believes that any of their personal information is inaccurate, we will make appropriate corrections.
OPT-OUT POLICY, YOUR NEWSLETTER AND EMAIL SUBSCRIPTIONS
You can opt-out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. Client service-related communications are an integral part of the services you receive from us and you may continue to receive such service-related emails unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided. You may also opt-out of receiving our newsletter or marketing emails by contacting us at firstname.lastname@example.org or by replying to an existing email with your request to be removed from the mailing list or click here https://newleafdebt.ca/subscriptions/
If you have any questions in relation to the cookies we use, please contact us at email@example.com.
(a) What is a cookie?
(b) Cookies we may use and why
- “Strictly Necessary”cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
- “Analytics and Performance”cookies allow us to track analytics by counting visits and traffic sources so we can measure and improve the performance of our Website. They may be set by us or by third party providers Google Analytics, Matamo & Anura to help us to know which pages or videos are the most and least popular and see how visitors move around the Website.
- “Functional”cookies enable the Website to provide enhanced functionality and personalization based on your interaction with the Website. They may be set by us or by third party providers, such as Adobe, whose services we have added to our pages.
- “Advertising and Targeting”cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other websites.
- “Social Media”cookies are set by social media services (e.g., Twitter, LinkedIn, Facebook, YouTube, Pinterest, Instagram) that we have added to the Website to enable you to share our content with your friends and networks. These cookies are capable of tracking your browser across other websites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit.
To view a list of the cookies that are used by the Website, click on “Manage cookie preferences” at the top of this Cookie Notice.
(c) How long will cookies remain on my device?
The length of time cookies will stay on your device will depend on whether it is a “persistent” or “session” cookie. A persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless deleted by you before the expiration date. A session cookie, on the other hand, will expire at the end of your web session, when the web browser is closed.
(d) Cookies that have been set in the past
If you have disabled one or more cookies, we may still use information collected from cookies prior to your disabled preference being set; however, we will stop using the disabled cookie to collect any further information.
(e) How can I control cookies?
You can control and manage cookies in various ways. Please keep in mind, removing or disabling cookies may impact your user experience and parts of this Website may no longer be fully functional.
Click on “Manage cookie preferences” at the top of this page to control which cookies are used on this Website. You may also be able to change your browser settings to manage and control cookies.
For more information on cookies used by other websites or pages, please refer to the specific privacy or cookie notice on those websites.
(f) Email communications
We may also use tracking technologies to determine whether you have read, clicked on, or forwarded certain email communications we send to you so that we can make our communications more helpful and interesting. If you do not wish us to confirm whether you have opened, clicked on or forwarded our communications, you will need to unsubscribe, as it is not possible for us to send these emails without tracking enabled. Registered subscribers can update their communication preferences at any time by contacting us, or you can unsubscribe following the instructions in the individual email communications you receive from us.
(g) Changes to this Cookie Notice
We may modify or amend this Cookie Notice from time to time at our discretion. When we make changes to this notice, we will amend the revision date at the top of this page, and such modified or amended Cookie Notice shall be effective as to you and your information as of that revision date.
We encourage you to periodically review this Cookie Notice to be informed about how we are using cookies.
THIRD-PARTY WEB BEACONS
New Leaf uses third-party web beacons from Yahoo! to help analyze where visitors go and what they do while visiting the Website. Yahoo! may also use anonymous information about your visits to this and other websites in order to improve its products and services and provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by Yahoo! visit https://legal.yahoo.com/us/en/yahoo/privacy/dashboard/index.html to learn how to opt out of this service.
RETENTION OF PERSONAL INFORMATION
New Leaf will keep your personal information for as long as it remains necessary for the identified purposes, as required by law, or in accordance with our retention schedules, which may extend beyond the termination of our relationship with you. New Leaf reserves the right to maintain personal information records for both active and inactive/unsubscribed clients.
CHILDREN AND MINORS
The Website and the services offered on the Website are not directed to children under the age of 13 years. We will not knowingly collect personal information about a child under the age of 13. We do not allow minors (persons who are under the age of majority in their place of residence) to create accounts, make purchases or enter contests or promotions, or otherwise make any use of the Website. If you believe your child entered information on our site, please let New Leaf know so we can remove the information from our site database.
STORAGE OUTSIDE OF CANADA
Your personal information may be used or stored by us or our service providers and our corporate affiliates outside of Canada. We require that our service providers and our corporate affiliates safeguard your personal information. However, if your personal information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.
New Leaf reserves the right to amend this Policy from time to time by posting an updated version on the Website. If such amendments affect how New Leaf uses or discloses personal information already held by New Leaf in a material way, New Leaf will obtain consent.
Notwithstanding the general terms of this Policy, the collection, use, and disclosure of personal information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.
For more information on New Leaf and privacy, please contact our Privacy Officer at: firstname.lastname@example.org. If you are unhappy with the way New Leaf has processed your personal information, you have a right to complain to the Office of the Privacy Commissioner.