Peoples Privacy Policy

We may collect your personal information to establish and manage our relationship, provide you with products or services you have requested, and to comply with our legal and regulatory requirements.  Your personal information is collected and maintained while you are a current, prospective or former user of our products and services.  By providing us with your personal information, you are consenting to the collection, disclosure, use and sharing of your information as set out in this Privacy Policy.

Personal Information is collected: 

(a) from you directly; 

(b) from sources available to the public which may include government registries, public records, credit reporting agencies and law enforcement authorities, and 

(c) from third parties, partners or other organizations with whom you have interacted in accordance with their terms and conditions and privacy policies. Examples of third parties who may share personal information with us include:

• payment service providers;
• payment platforms;
• identity verification companies;
• fraud screening providers;
• other financial institutions;
• technology service companies;
• mortgage processing service providers;
• card program managers; and
• merchants and other businesses.

You may interact with us in a number of ways including through our website, online banking portal, mobile application (app), in person as well as by written communication and phone services.  Peoples may monitor or record our telephone calls with you for training and quality assurance purposes and to detect or prevent fraud.  If you do not want to have your call recorded, you can let us know and we can provide you with other options to access our services or to communicate with us.

Depending on the product being offered, the third party may be our service provider or we may act as a service provider on behalf of third parties.  Where we process personal information in conjunction with or on behalf of third parties, your personal information will be shared with such third party.  You authorize the collection of personal information from these third party sources and, where applicable, you authorize these sources to provide us with your personal information.

In instances where Peoples is acting as a service provider on behalf of third parties, your personal information is subject to the third provider’s privacy practices.  For example, your personal information may be processed by program managers in connection with the ongoing administration of a prepaid card.  Please review the third party’s Privacy Policy to understand how they handle your personal information.

The categories of personal information we collect depend on the products and services you have with us. The information we may collect includes:

• Contact information such as name, address, telephone number and email address;
• Background information such as date of birth, occupation and Social Insurance Number (SIN); 
• Profile information such as digital identification, passwords, service preferences;
• Identification documents such as driver’s license, passport and other government issued documents;
• Financial status information including your employment information and history, references, annual income, assets and liabilities as well as information about your balances and account transactions including bank, investment and mortgage account activity and payment history;
• Credit related information such as credit accounts, payment history, credit utilization and length of credit history;
• Biometric information such as an image of your government issued identification along with a real time image or video to verify your identity and information from your identification document along with the final result of the identity verification process; 
• Behavioural and interaction information including physical usage and device based engagement activities with our services;
• Online browsing information including type of web browser, geolocation data and tracking tools such as cookies, pixels and IP addresses; and
• Device information including mobile device identification number, operating system of device, device ID, type of device and other device configurations or settings.

When you first visit our website using a new browser or device, a cookie banner will appear explaining how we use cookies and similar tracking technologies. You may provide or withdraw your consent with respect to optional tracking preferences. Additional information regarding our use of cookies is available in our Cookie Policy.

We use your personal information to help us deliver and manage our products and services including to:

• evaluate and process your application, accounts, transactions and reports;
• assess your eligibility and suitability for our products and services;
• determine your credit worthiness;
• verify your identification and demographic information;
• communicate with you, including responding to your inquiries;
• market our products and services either directly, or through a third party service provider;
• provide ongoing service and information about products and services you hold with us;
• establish credit, transaction or account limits;
• improve our products and services;
• prevent and detect fraud;
• enforce an obligation or collect a debt you owe us;
• assess and analyze our risk, operations and relationship with you; 
• develop and improve our security measures and risk management capabilities; and
• comply with legal, regulatory, governmental and contractual requirements.

To help manage your relationship with us, we share your personal information within Peoples, including amongst our subsidiaries and affiliates, and with outside service providers and third parties for the uses outlined in this Privacy Policy.  We may use outside service providers and third parties on our behalf to support activities such as those related to account administration, data processing and analytics.  Examples of service providers may include:

• credit and loan processors;
• credit reporting agencies;
• mortgage brokers or originators;
• mortgage closing services;
• other banking and financial institutions;
• risk management service providers;
• marketing and research companies;
• debt collection firms;
• payment card networks;
• payment processors;
• card program managers;
• legal and accounting firms;
• technology service providers;
• mobile wallet providers; and
• government authorities, law enforcement, self-regulatory organizations and regulatory bodies.

Service providers and third parties may only access and use your personal information to provide the services under their agreement with us. Your personal information may be maintained and processed by us, our affiliates and other third party service providers in Canada as well as in other jurisdictions outside Canada including Europe, the United Kingdom and the United States. By submitting your personal information to us, you agree to this transfer, storage and processing.

From time to time, we may buy new businesses or sell some of our businesses.  In the event of a merger, acquisition, bankruptcy or dissolution of our business, or reorganization or other change in corporate control, your personal information may be transferred to an acquiring business or third party, including in contemplation of a related due diligence for such business transactions.

When someone is acting as your representative or we reasonably believe is acting with proper authorization, such as a legal guardian, person having a power of attorney, estate representative, lawyer or accountant, we may share information with and take instructions from them including sharing information as instructed by such representative. 

We may share your personal information as we believe necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of Peoples, including our employees, agents, customers or business partners, to detect, suppress or prevent fraud or where otherwise permitted by applicable law including responding to a search warrant or other legally valid requests from public and government authorities.

We retain your personal information only as long as we need it for the purposes for which it was collected, used, disclosed or to meet our legal obligations.  The length of time for which we will retain your information varies depending on the product, service, sensitivity of the information and the purpose for which we use it.  For these reasons, we may retain your information beyond the end of your relationship with us.  For example, we may need your information to:

• support legal or regulatory matters;
• support fraud prevention organizations and other risk assessments;
• respond to issues that may arise at a later date;
• support credit reporting systems; or
• manage security matters.

We have procedures to guide what we do when we no longer need your information for any purpose. We may securely destroy, delete or erase it.  Alternatively, we may convert your information to an anonymous form.

We have implemented administrative, technological and physical measures designed to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use and disclosure.  We restrict access to personal information to employees and authorized service providers who require access to fulfil their job responsibilities. To the extent a service provider requires access to your personal information for an authorized purpose, we require the service provider to implement similar safeguards to protect the security of your personal information.

We may send your personal information outside of Canada (and outside of Quebec), including Europe, the United Kingdom and the United States, in connection with the collection, use and sharing parameters set out in this Privacy Policy, including for processing and storage by service providers in connection with such collection and uses. You should note that to the extent any personal information is out of the country, it is subject to the laws of the country in which it is held, and it may be subject to disclosure to the governments, courts, law enforcement, national security or regulatory agencies of such other country.

You have the right to access, rectify or delete your personal information held by us.  You may also have the right to ask for an overview or copy of your personal information. You can help us maintain the accuracy of our records by keeping us informed of any changes or updates to your personal information. We may ask you to verify your identity when accessing, changing or updating your personal information.

There are some limitations to these rights.  We will not be able to provide you with access to information about you from our records that would reveal information about another party, is subject to legal privilege, contains confidential commercial or proprietary information to Peoples, relates to an internal investigation or risk assessment, or cannot be disclosed for other legal reasons.  If we cannot fulfil your request, we will provide you with the reasons that we are unable to do so.       

You can refuse or withdraw your consent to our collection, use and sharing of information at any time by giving us reasonable notice.  In certain circumstances, your consent cannot be withdrawn.  For example, you may not withdraw your consent where our collection, use and sharing are permitted by law, is required to ensure we have correct and up to date information or is necessary to manage our business. Withdrawing your consent may also limit or prevent us from providing you with our products and services. 

Please contact our Privacy Officer if you have any questions about this Privacy Policy or our privacy practices, to submit an access, rectification, deletion or update request or to withdraw your consent to our use of your personal information as set out in this Privacy Policy.  We will investigate and review all questions and requests.

We take your concerns seriously.  If you are not satisfied with our response, you may refer your concerns or complaints to the Resolving Your Concerns procedures found on our website at www.peoplestrust.com. If your concern or complaint is not resolved by us, you may file your concerns or complaints with the appropriate federal or provincial privacy regulatory authority.  Please contact us if you need help to identify the right regulator.

Canada www.priv.gc.ca
British Columbia www.oipc.bc.ca 
Quebec www.cai.gouv.qc.ca/ 
Alberta www.oipc.ab.ca

We may modify this Privacy Policy from time to time to take into consideration changes in legislation or other issues that may arise at our sole discretion.  Any changes we make to this Privacy Policy will be effective when it is posted on our website: www.peoplestrust.com/en/legal/privacy-security/privacy/

Your continued use of our product or services, or provision of personal information after changes have been made to this Privacy Policy constitutes your acceptance of such changes. If we intend to use or disclose your personal information for purposes materially different from what is described in this Privacy Policy, we will take reasonable steps to notify you.  We encourage you to review this Privacy Policy from time to time to stay informed about our privacy practices.