BOTH AFCO AND CAFO PRIVACY STATEMENT(S) ARE IN THIS DOCUMENT.
I. AFCO CREDIT CORPORATION
AFCO ACCEPTANCE CORPORATION
AFCO Privacy Statement
We take the issue of privacy very seriously. We want to assure users of our Web site of the security, privacy and confidentiality that they expect from a premier financial services institution. As technology evolves, we will continue to look for better ways to gather and use information in order to offer products and services that best meet your needs and to protect and safeguard information about you and your accounts.
We do not collect any personal information from anyone who is merely visiting this Web site other than requesting the user id and password to access the site. Personal information may be requested if a user requests a password be reset.
Account Inquiry Access We offer online account inquiry access and only collect personal information necessary to provide data requested by the visitor (for example, account balances).
AFCO requires a user ID and password for the protection of the user. AFCO utilizes security and encryption technology that is consistent with industry best practices. E-mails sent to AFCO over the Internet from a source other than the AFCO Web site may not be secure and, since the security is out of AFCO's control, AFCO cannot be responsible for their security.
To protect the confidentiality of the information submitted via this Web site, we use secure socket layer (SSL) technology. SSL technology establishes a "secure" Internet session and encodes the data submitted to the Web site, ensuring that the information is accessible only to an authorized representative and the customer. A customer can tell whether a document comes from a secure server by looking at the location (URL) field. If the URL begins with https:// (instead of http://), the document comes from a secure server.
E-Mail and Product Inquiry
Through use of an e-mail link, we invite users of this Web site to send e-mail messages to AFCO customer service so that service representatives may respond to inquiries regarding AFCO or its products or services. AFCO retains copies of these e-mail messages. The information provided by a user will only be used to respond to the user and to provide better customer service.
A cookie is a small piece of information about an Internet session that may be created when a user accesses a Web site. Presently, we use session cookies, which are temporary cookies that are deleted from your computer when you close your browser, to facilitate easier navigation within the site and provide a higher level of convenience for the user.
Use of Information Collected
Information collected from users of this Web site is used to address the specific needs of those users and to provide better customer service. The information collected also is used to provide a record of communications between AFCO and its Web site users and to comply with any applicable legal and/or regulatory requirements.
Access to Information Collected
Our employees have limited access to customer information based on their responsibilities. Certain AFCO service associates will be provided with a user's information in order to respond to that user's needs. This access enables them to assist you in resolving any service issues that may arise. Our employees are instructed to use strict standards of care in handling all customer information. AFCO associates who do not conform to the AFCO confidentiality rules are subject to disciplinary sanctions that may include dismissal.
AFCO Affiliates / AFCO Service Providers
> AFCO affiliates, along with non-related service providers that assist us in meeting the needs of our users, may receive personal information collected from a Web site user. Such information will be disclosed only to respond to the user's needs.
> We do not transmit any information collected through our Web site to any third party marketers. We offer the opportunity to our Web site users to link to the Web pages of third parties who provide products and services not offered by AFCO. On occasion, laws and regulations may require us to provide information about you and your transactions to government agencies or regulators. In addition, federal and state laws give third parties involved in lawsuits or other legal proceedings the right to obtain records and information from us. We share only the information that we are required or authorized to share.
Third Party Sites
Access to third party Web sites linked to the AFCO Internet Web site is at the user's discretion. AFCO is not responsible for the reliability of content found in third party Web sites that are linked to the AFCO Internet Web site. Additionally, AFCO is not responsible for third party Web sites that collect information on parties who visit their Web sites through links on the AFCO Internet Web site.
II. CAFO, INC. ("CAFO")
CAFO Privacy Statement
At CAFO, privacy is protected. An important part of our commitment to service excellence is our commitment to the privacy of personal information entrusted to us.
Keeping that information in strict confidence is a cornerstone of our business. The range of products and services we offer continues to expand and the technology we use continues to change. But no matter how the business changes, we will protect the privacy of personal information.
Our policies and procedures, which we practice in order to protect this information, are in place across CAFO. In the following pages, we describe these policies and procedures.
PROTECTING PRIVACY MEANS:
- We keep your personal information in strict confidence.
- You have control over your information and have access to it.
- We respect privacy when we market our products and services.
Why We Need Information and How We Use It
CAFO may collect personal information when an individual finances its insurance premiums with us and enters into a Premium Installment Contract. In this policy, the words "you" and "your" refer to that individual. CAFO uses that information to carry out the functions associated with this contract. Examples of such information include:
- Information we receive from you, such as your name, address, assets and income, as provided, for example, with a premium installment contract.
- Information about your transactions with us, our affiliates, and others, such as balances, payment history, parties to transactions, and account usage.
- Banking account information that you provide for payment purposes.
- Information we receive from affiliates, credit reporting agencies and other third parties not affiliated with us, such as your creditworthiness and credit history.
Personal information may be shared with affiliated companies or third parties who have been retained by CAFO to assist us in carrying out functions associated with your contract. The third parties with whom customer information may be shared include:
- Companies that provide services necessary to effect a transaction that you request or to service your account.
- Companies or others that provide specialized services on our behalf, such as programming contractors, or credit bureaus.
- Government agencies, courts, parties to lawsuits, or regulators to whom we may provide information about you and your transactions. For example, federal and provincial laws give people involved in lawsuits or other legal proceedings the right to obtain records and customer information from us. In such cases, we share only that the information that we are required or authorized to share.
We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances.
This policy applies whether your information is collected in paper, electronic or other form. CAFO does not collect any personal information from visitors browsing our website, although personal information may be requested via the website if a visitor chooses to respond to on-line surveys, send CAFO an e-mail message or use one of our website tools.
Information obtained when you finance insurance premiums and enter into a Premium Installment Contract is only disclosed to third parties with your consent.
There are some exceptions to the above rule. For example, we may collect, use and disclose information if we:
Use an outside company to process information.
At times, we may use the expertise of an outside company to do work involving some personal information. When we do, we select the company carefully and confirm that it uses standards comparable to ours.
Must disclose information for legal reasons.
We may be compelled to release information by legislation, a court of law, to a regulatory authority, or as part of a sale or reorganization of our business. If so, our policy is to release information only to the extent we have to.
Have to protect the interests of CAFO.
In certain circumstances, CAFO may have to collect, use or release information for our protection - for example, in collecting accounts or in the detection or prevention of fraud.
Where we have been appointed by you, we will only use personal information with consent.
Consent can be express or implied. Express consent can be verbal or written. For example, the Premium Installment Contract may contain a written consent for our use of your information to carry out the functions associated with your account. Or you might consent to release the information over the phone.
Consent is implied when we can reasonably conclude that you have given consent by an action you have taken or not taken, or where the context reasonably requires that we have and use information to carry out what you have asked us to do.
You can withdraw your consent any time after you have given it to us, provided there are no legal requirements to prevent this. If you do not consent to certain uses of information or if you withdraw your consent, we may not be able to finance your insurance premiums. If so, we will explain the situation to you to help you with your decision.
WE PROTECT YOUR INFORMATION FROM ERROR, LOSS AND UNAUTHORIZED ACCESS
Our employees who have access to personal information are made aware that it is confidential. Each employee must certify annually that he or she has maintained the confidentiality of information entrusted to him or her.
Our computer security specialists build security into all our computer systems. This protects personal information while it is stored in data files and when employees are using it. Our systems also protect information when it is transmitted.
Information sent via the Internet, however, can be intercepted by a third party. It is relatively easy for a third party to intercept and read information sent via unencrypted e-mail. Where CAFO's website requests or accepts confidential information, we transmit that information with encryption.
YOUR INFORMATION IS DESTROYED WHEN IT IS NO LONGER NEEDED
We keep your information only so long as we need it for the products and services we have been hired to deliver or to meet legal requirements. We have standards that meet these requirements. We either destroy information or render it anonymous when it is no longer needed.
ACCESS TO AND ACCURACY OF PERSONAL INFORMATION
You can check your information to verify, update and correct it, and to have obsolete information removed. We will ask for the request in writing.
There is no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records or if special expense is involved in retrieving your information. We will advise of any charges in advance.
YOU CAN FIND OUT TO WHOM INFORMATION IS GIVEN
If you ask, we will let you know the names of outside companies or organizations we have given your information to. This will not include information given to outside companies used to do work for us. It also will not include disclosures to Canadian or provincial governments, and it will not include disclosures where we are prohibited by law from advising the individual of the disclosure.
WE RESPOND TO REQUESTS PROMPTLY
We will deal quickly with your request to see your information, and within 30 days. If we need to extend the time, or we have to refuse the request, we will tell you why (subject to any legal restrictions) and we will notify you of the reasons for the extension and your rights under applicable legislation with respect to the extension.
WE CORRECT THE INFORMATION
Whenever possible, we will correct any information we may have given to any other organization. If we have received the information from another party, we will let you know the name and address of the party so that you can ask them to correct it.
WE PROTECT OTHER PEOPLE'S PRIVACY WHEN WE MAKE INFORMATION AVAILABLE TO YOU
There may be files that include information about you and other people which is confidential to CAFO or our corporate clients, or which is the property of CAFO or such clients. Because we value everyone's confidentiality and legal rights we cannot make these files available outside of CAFO or our related companies. However, where we can separate your information from the information of others without affecting another's confidentiality or legal rights, we will make available to you the information contained in the files about you.
WE MONITOR OUR COMPLIANCE WITH THE CAFO PRIVACY POLICIES
We have procedures in place to assist our employees in the practice of the policies. Our internal auditors and Compliance Department monitor the adherence to these policies and report any findings to a committee of the Board of Directors of CAFO.
WE ARE COMMITTED TO UPHOLDING THE CAFO PRIVACY POLICIES
If there are any questions or complaints about our privacy policies, or about our living up to them, let us know right away.
RESOLVING CONCERNS IS IMPORTANT TO US
CAFO is committed to treating everyone with the greatest respect and consideration and to providing the highest level of service. Even so, from time to time there may be something wrong. There may be a misunderstanding, or someone may feel treated unjustly. Whatever the circumstances, our primary concern is resolving the problem.
How to Contact Us
Any questions or concerns regarding our policies or procedures on personal information can be directed to our Privacy Officer by any of the following means. We may ask for further documentation or information in order to verify your identity when you make your request.
By Mail: CAFO Privacy Officer
P.O. Box 17
95 Wellington St. West, Suite 1706
Toronto, Ontario M5J 2N7
By Fax: (416) 868-0125
By Phone: (416) 868-6777
Note: We may change this policy from time to time, and, if we do, the most current version can be obtained by contacting us as above.