CWB Financial Group Privacy Statement 

This section outlines what our Privacy Statement covers and what it does not cover. It also explains what we mean by “personal information”.

What this Privacy Statement covers

• This Privacy Statement applies to CWB Financial Group’s collection, use, and disclosure of personal information. Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, such as contact information (name, address, personal identification), account numbers, or details such as age, marital status, and financial information. Personal information includes information that can be used on its own or with other information to identify, contact, or locate a single person.
• We collect personal information from individuals who have personal accounts, products or services with us. We may also collect personal information from and about individuals in the course of establishing and maintaining a commercial relationship with our legal entity customers such as corporations or trusts. For example, we may collect personal information from and about individuals who are authorized signors, officers, owners, directors, and/or guarantors of the legal entity.
• We may also collect information from individuals who visit our websites, subscribe to receive marketing materials from us, or ask for information about our products and services.
  

What this Privacy Statement does not cover

• This Privacy Statement does not apply to information about our legal entity customers, such as corporations and trusts, with the exception of information about individuals associated with those legal entity customers as described in the section above. While many of the practices described in this Privacy Statement protect legal entity information, it is our contracts with our legal entity customers that govern our handling of legal entity information.

The primary purpose for our collection and use of your personal information is so that we may deliver the products and services you request, and that are suited for your needs. However, we sometimes request or use your personal information for additional purposes. Some of these additional purposes follow. If we collect or use your personal information for a new purpose, then where required, we will identify that purpose to you and ask for your prior consent.

To verify your identity

• We may request and use information about you, including your name, address, telephone number, email address, Social Insurance Number*, date of birth, occupation, and details from government-issued identification, to verify your identity. We may also ask for certain biometric information, like face ID, to securely verify your identity. During the course of our relationship, we may ask you for other personal information to authenticate you (confirm your identity) from time to time.
  
  *You are not required to provide us with your Social Insurance Number to verify your identity, however it does facilitate confirming your identity with credit-reporting agencies. Your Social Insurance Number may be required for income tax reporting purposes or to fulfill other regulatory reporting requirements as described below.

To better manage your relationship with us, respond to any questions you may have, and improve our products and services

• We may request and use information, including language and communication preferences, location, demographics, and interests, to help us understand more about you and how you like to use our products or services. We may also request and use information such as your telephone number, address, or email address to contact you about our products and services.
• We may also request that you provide information about individuals other than yourself. This could be information about beneficiaries, spouses, common-law partners or dependants under an insurance product or registered plan. It could also be information about an authorized user for your account. If you provide us with information of another individual, we will assume you have that individual’s consent.

To perform data analytics and assess risks

• We may request and use credit and other information about you to assess your creditworthiness and to manage and assess our risks, including to perform data analytics and assess credit and business risks.

To determine your eligibility for the products and services you request

• We may request and use information, including financial information, such as age, employment and financial history, income, credit reports, net worth, investment knowledge and goals, security, assets, and liabilities, to determine your creditworthiness or eligibility for, or appropriateness of, the products or services you request or receive from time to time.

To keep our employees and customers safe and to protect against theft, fraud and property damage

• We may request and use information from you to maintain service quality and to ensure the safety of our clients, employees and others, and to protect against or detect potential illegal activities, such as, theft, fraud, and vandalism.

To collect debts, enforce obligations, and to manage and assess risk

• We may collect and use information from you to collect a debt that you may owe to us, to enforce the terms of any agreement you have with us, and to manage and assess our risk.

To comply with legal or regulatory requirements

•  We are required to collect personal information about you to comply with certain legal and regulatory requirements. For example:
  
  • To comply with Canadian anti-money laundering laws, we may request information about you, including employment information, your purpose in requesting products or services, and the identity of individuals who own or control legal entity customers. We are also required by anti-money laundering laws to ensure this information is current, so we may need to confirm this information from time to time.
  • To comply with income tax laws, we may request information, such as your Social Insurance Number, beneficiary information, and citizenship/ residency information.
  • To comply with securities law requirements, we may ask about your investment knowledge and experience, investment horizon, risk tolerance, and ownership/involvement in public companies.

• CWB Financial Group companies, who are members of self-regulatory organizations (SROs) like the Canadian Investment Regulatory Organization (CIRO) (formerly the Mutual Fund Dealers Association of Canada and Investment Industry Regulatory Organization of Canada), may be required to collect and disclose personal information to these SROs from time to time. SROs collect, use, and disclose personal information to ensure member organizations and regulated individuals are complying with SRO rules and regulations.

To better understand your financial needs and determine what additional products and services we offer that may interest you

• From time to time, we may proactively inquire about your financial needs and / or use existing information we have to determine additional products and services that may be of interest or beneficial to you.

To keep our data accurate

• Throughout your relationship with CWB Financial Group, we may ask for and collect and use information to ensure our information about you remains accurate and up to date.

For marketing insights

• We may collect and use information from you to derive sales and marketing insights including those related to customer and prospective customers’ demographics, interests, and behaviours, to measure the success of our advertising campaigns, to identify new prospective customers, and to improve our products and services or develop new ones. When doing so, we generally will use your information in aggregated format or with direct personal identifiers removed.

Most of the personal information we collect about you will be collected directly from you (for example, from application forms you complete). However, we collect personal information in other direct and indirect ways. Some examples include:

From your use of our products and services

• Using most of our products and services create transactional records that we periodically report to you.
• At account opening, we will ask to review and record information about your identification documents, such as your driver’s license and passport.
• Depending on the product or service you request, we may ask you for information about your assets, liabilities, income and expenses.
• For certain insurance products, we may ask you for health information.
• During the course of our relationship, we may ask you for personal information to verify your identity from time to time.

From your interactions with our staff

• Your interactions with our staff, whether in person, over the phone, over email, or over other electronic channels may result in us collecting personal information from you.
• We may monitor, record, and retain phone calls or our email exchanges with you.
• We may collect video surveillance in and around our offices, branches and automated banking machines.

From your use of our website and mobile applications

• We monitor the use of our websites, mobile applications and networks to guard against cyberattacks.
• When you navigate our websites, we may monitor and record information about how you interact with our websites. Generally, this collection will not involve personal information but rather computer Internet Protocol (IP) addresses.
• When you access our applications on mobile devices, we may collect location data. You may disable this collection through your mobile device’s settings.

 From third parties

• Assessing your eligibility for certain products and services may require us to obtain information about you from third parties, including credit reporting agencies. We will obtain your explicit consent prior to collecting any such information.
• To lessen the risk of being provided incorrect information, we may request that you provide your Social Insurance Number. You are under no obligation to provide your Social Insurance Number to us for this reason. However, providing us with your Social Insurance Number lessens the chance that credit reporting agencies will provide us with incorrect information about you.

Most of the personal information we collect about you will be collected directly from you (for example, from application forms you complete). However, we may collect personal information in indirect ways. The ways that we may collect your personal information is set out below. Prior to collecting your personal information in any other way, we will identify that personal information is being collected, the purpose of such collection, and ask for your prior consent.

From your use of our products and services

•  Using most of our products and services create transactional records that we may periodically report to you.
• At account opening, we will ask to review and record information about your identification documents, such as your driver’s license or passport.
• Depending on the product or service you request, we may ask you for information about your assets, liabilities, income, expenses, family situation, dependant, and beneficiaries. For certain insurance products, we may ask you for certain health information.

From your interactions with our staff

• Your interactions with our staff, whether in person, over the phone, over email, or over other electronic channels may result in us collecting personal information from or about you.
• We may monitor, record, and retain phone calls and our email exchanges with you.
• We may conduct video surveillance in and around our offices, branches and automated banking machines which may result in the collection of your image and other information about you.

From your use of our websites

• We monitor the use of our websites and networks to guard against cyberattacks and fraud.
• When you navigate our websites, we may monitor and record information about how you interact with our websites. Generally, this collection will not involve personal information but rather computer Internet Protocol (IP) addresses, Cookies or device data.
• Our websites may contain certain applications, tools and form submissions, such as when you fill out and submit a form on our websites or use our business valuation tools and other calculators. If you use these applications, tools and form submissions, we may collect and use the information you enter on those applications. This may include your name, email, age, and certain financial data used in our financial calculators.
• For more information about how your personal information may be collected through our website, see our Online Privacy and Interest-Based Advertising Statement at cwb.com/about-us/privacy.

From your use of our mobile applications

• We monitor the use of our mobile applications and networks to guard against cyberattacks and fraud.
• When you use our mobile applications, we may monitor and record information about how you interact with our mobile applications. This collection may include information you provide through the mobile app, geolocation (if enabled), IP address, and device related information.
• When you access our applications on mobile devices, we may also collect location data or biometric information such as face ID to assist in providing you service. To collect this information and as permitted by law, we may enable these applications on your mobile device. You may enable and disable the collection of your location through your mobile device’s settings. Your can enable and disable the collection of your face ID through the settings in our mobile application.
• For more information about how your personal information may be collected through our mobile applications, see our Online Privacy and Interest-Based Advertising Statement at cwb.com/about-us/privacy.

From third parties

• Assessing your initial and continuing eligibility for certain products and services may require us to obtain information about you from third parties, including government institutions, credit reporting agencies, insurance bureaus and other registries and publicly available sources or records.

We may use your personal information to make automated decisions about you. A decision is automated when no employee is involved in the decision-making process.  Automated decision making (also known as automated processing) often involves the use of software to evaluate your personal information and other factors to address risks and potential outcomes. For example, we may make automated decisions about you when responding to requests for certain types of credit and financing products, when determining your credit worthiness, when monitoring your account for fraud or other financial crime, to determine the types of services that may be suitable for you, or for other reasons that we’ll disclose to you from to time.

Sharing within CWB Financial Group

To provide service to you and manage our risks

• We may share information within CWB Financial Group in order to provide our products or services, to manage our risks, including to perform data analytics to aggregate and analyze our credit and business risks, to meet legal and regulatory obligations, and to ensure our information is accurate and complete.

To inform you of CWB Financial Group products and services

• We may share your information within CWB Financial Group so that we may better serve you and understand your financial needs. Provided you have not withdrawn your consent as outlined in Section 9, information may also be shared so that we may identify and inform you about products and services they think may be of interest to you.
  
  

Sharing with Others

• We will generally only share or disclose your personal information to third parties to provide you with the products and services you request. Outside of the purposes described below, we do not sell or disclose your personal information to other companies outside of the CWB Financial Group without consent, unless required or permitted by law.  

To facilitate and optimize how we deliver products and services to you

• We may disclose your personal information with your joint account holders, executors, beneficiaries or with your agents (for example, mortgage brokers) and legally appointed representatives (for example, powers of attorney) if we determine they are authorized to act on your behalf.

• From time to time, we contract with third party service providers to assist us in providing you with our products and services, help run our operations, or to perform services on our behalf. This may require us to share your personal information with these third parties.
• Our service providers may provide us with various services such as printing, postal mail, marketing insights, advertising, analytics, processing, authorizing and authenticating your transactions. Some of our service providers are located outside of your province of residence or outside of Canada and your personal information may be accessed or processed in the United States or other jurisdictions.

To assess credit and collect on debts owing to us

• We may periodically disclose your credit information, including payment history, to credit reporting agencies to fulfill the contracts governing our use of these services.
• We may need to disclose your personal information to confirm ownership and details of loan collateral
• We may need to disclose your personal information with collection agencies, professional advisers, or other financial institutions to collect on debts owing to us should we refer your file to collection. 

If we sell or pledge our assets

• If we sell a CWB Financial Group company or sell or transfer a portion of the business or assets of a CWB Financial Group company, or in the event we sell, assign or securitize your loan, mortgage or other debt, we may disclose your personal information to the prospective purchaser or investor. The personal information we disclose in such circumstances may include financial information obtained in support of your loan, mortgage or other debt.

For marketing and advertising

• We may share your personal information with our third-party service providers for the purposes of marketing and advertising. The disclosure of your personal information enables us to provide marketing communications and targeted interest-based online advertisements that are more relevant to you and to other people with similar interests, such as prospective customers. Provided you have not withdrawn your consent as outlined in Section 9, we may provide your email address, with personal identifying information removed, to our service providers for such purposes. 

Where required or permitted by law or regulation

• We will disclose your personal information to law enforcement or other government agencies when we are legally compelled to do so by court order, warrant, or other legislative or regulatory authority.
• Privacy law also allows us to disclose personal information without consent in certain situations. For example, we may disclose personal information to government agencies or other organizations where the disclosure is reasonably necessary to combat fraud or money laundering, protect vulnerable individuals or in an emergency where someone’s health or life is at risk.

Where we keep your information

• Depending on the nature of the personal information, your personal information may be stored in the CWB Financial Group office or branch location where you regularly do business, in our computer systems or in the record storage facilities of CWB Financial Group or the storage facilities of our third-party service providers.
• Information may be stored and processed in any country or province where we have affiliates or service providers. By using our products or services, you consent to the transfer of information to other provinces or countries outside of Canada, including the United States, which may provide different data protection rules. CWB Financial Group’s service providers and other third parties with whom we share information, may perform activities outside of Canada. Your personal information may be securely used, stored or accessed in other countries and be subject to the laws of those countries. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries.

Retention

• We will only retain personal information that was collected in accordance with this Privacy Statement or our Online Privacy and Interest-Based Advertising Statement, or that was collected with your consent. Information may be retained in physical or digital format. We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for or for such longer periods as may be required or authorized by law, even if you are no longer a customer. We maintain a retention policy which sets time periods for the destruction of records containing personal information.