Amber Financial Services Corp.
Personal Information Protection Policy
Updated February 19, 2016
At Amber Financial Services Corporation, we are committed to providing our users with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our users, protecting their personal information is one of our highest priorities.
We have always respected our users privacy and safeguarded their personal information. We will inform our users of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy outlines the principles and practices we will follow in protecting users' personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our users' personal information and allowing our users' to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to us and our subsidiaries including Amber Financial.
This policy also applies to any service providers collecting, using or disclosing personal information on our behalf.
Personal Information– means personal information collected and includes but is not limited to, name, age, home address, phone number, social insurance number, income, credit history, employment information. To clarify, personal information does not include contact Information.
Contact information– means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy.
Privacy Officer– means the designated ndividual responsible for ensuring that we comply with this policy.
Policy 1 – Collecting Personal Information
- Unless the purposes for collecting personal information are obvious and the user voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
- We will only collect a user information that is necessary to fulfill the following purposes:
- To verify identity.
- To verify creditworthiness.
- To identify users preferences.
- To understand the needs of our users.
- To open and manage an account.
- To deliver requested products
- To send out association users information.
- To contact our users.
- To ensure a high standard of service to our users.
- To meet regulatory requirements.
- To collect and process loan payments.
Policy 2 – Consent
- We will obtain a user's consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
- Consent can be provided in writing, electronically, through our website or WeChat platform] or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the user voluntarily provides personal information for that purpose.
- Consent may also be implied where a user is given notice and a reasonable opportunity to opt-out of his or her personal information being used for emails, mail-outs, the marketing of new services or products, and the users does not opt-out.
- Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), users can withhold or withdraw their consent for us to use their personal information in certain ways. A user's decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the user in making the decision.
- We may collect, use or disclose personal information without the users' knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
- We will only use or disclose a user's personal information where necessary to fulfill the purposes identified above or:
- To conduct users surveys in order to enhance the provision of our services;
- To contact our users directly about products and services that may be of interest;
- We will not use or disclose user personal information for any additional purpose unless we obtain consent to do so.
- We will not sell user lists or personal information to other parties.
Policy 4 – Retaining Personal Information
- If we use a user's personal information to make a decision that directly affects the user we will retain that personal information for at least one year so that the user has a reasonable opportunity to request access to it.
- Subject to policy 4.1, we will retain user personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
- We will make reasonable efforts to ensure that a user's personal information is accurate and complete where it may be used to make a decision about the user or disclosed to another organization.
- A user may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
- If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the user correction request in the file.
Policy 6 – Securing Personal Information
- We are committed to ensuring the security of users' personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
- The following security measures will be followed to ensure that user personal information is appropriately protected:
the use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access), contractually requiring any service providers to provide comparable security measures.
- We will use appropriate security measures when destroying a user's personal information such as shredding documents, deleting electronically stored information.
- We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Users Access to Personal Information
- Users have a right to access their personal information, subject to limited exceptions.
- A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
- Upon request, we will also tell users how we use their personal information and to whom it has been disclosed if applicable.
- We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
- A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the users of the cost and request further direction from the users on whether or not we should proceed with the request.
- If a request is refused in full or in part, we will notify the user in writing, providing the reasons for refusal and the recourse available to the users.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
- The Privacy Officer is responsible for ensuring our compliance with this policy and applicable legislation.
- Users should direct any complaints, concerns or questions regarding our compliance with this policy in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the users may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for the Privacy Officer:
Name: Ryan Cheung
Phone: +1 (778) 297-4999