Last Updated: March 26, 2024

Northlake Financial ULC and our corporate affiliates (variously referred to as “Northlake”, “we”, “us” or “our”) respect your privacy. This privacy policy (this “Policy”) describes the manner in which we collect, process, disclose, and protect your personal information. This Policy is incorporated by reference into the terms of use for Northlake’s website, located at NorthlakeFinancial.ca (the “Terms of Use”). Capitalized terms not otherwise defined in this Policy have the meanings given to them in the Terms of Use.

Please read this Policy carefully to understand our policies and practices for collecting, processing, disclosing and protecting your personal information. We will only use your personal information in accordance with this Policy except where otherwise permitted or required by law. By using the Website or by clicking to accept the Northlake Terms of Use, you consent to the practices described in this Policy.

The Website may contain links to other third-party websites or other internet resources. Clicking on those links may allow third parties to collect or share data about you. We do not accept any responsibility or liability for the privacy practices of third-party websites and other resources. You are encouraged to review the privacy policy of every website you visit.

 1.  What Information Do We Collect?

 The types of information we collect depends on the nature of your interaction with us. We may collect and use several types of information from and about you, including:

Personal information. Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Here are the types of personal information we may collect when you navigate our Website:

  • Contact information. For example, your name, home address, telephone number, email address and login credentials.
  • Identity Information. For example, date of birth, social insurance number, credit history reports and copies of any documents that you provide us for identity verification purposes.
  • Your personal preferences. For example, preferences based on page interaction information (including the timing, frequency and pattern of use), time zone, language settings, location information and your consent to receive marketing materials.
  • Your transaction information. For example, account balance, payment history and account activity.
  • Technical information. For example, device ID, IP address, geographical location, browser type and version, operating systems, length of visits on the Website, page views and website navigation paths.
  • Other information you provide us. For example, information contained in or relating to any communication that you send to us (including the communication content and metadata associated with the communication) or any other personal information that you choose to send to us.

2.  How Do We Collect Information?

We use different methods to collect your information, including through:

  • Direct Interactions with You. We collect information you directly provide us by, for example, filling in forms or corresponding with us.
  • Cookies and other Tracking Tools. The Website use “cookies”, a tiny element of data that our Website sends to your browser, which may then be stored in a small file placed on the hard drive of your computer. Cookies enhance the convenience and use of the Website. For example, we send a “session cookie” to your computer any time you log in to your account. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we do not need to ask you for your password on each page. We use these technologies to recognize you as a user, customize content, improve our services and collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety. Our Website will automatically issue cookies when you visit our Website unless you adjust the applicable settings on your browser to refuse cookies. However, if you refuse to accept cookies, you may be unable to access certain parts of our Website.
  • Our Partners. We collect information from our partners, including our affiliates, credit reporting agencies and your original creditors.

3.  For What Purposes Do We Use Personal Information?

We use your personal information to operate, provide, develop, and improve our products and services, including in connection with:

  • Account management. We use your personal information to verify your identity and manage your account.
  • Transactions. We use your personal information to process your orders and payments and to communicate with you about your account, orders, services and promotional offers.
  • Recommendations and personalization. We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences and personalize your experience with the Website.
  • Improve Northlake and manage credit risks. We use your personal information to operate, evaluate and improve our business, including to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of the Website.
  • Other. We may use your personal information to prevent fraud or criminal activity, to protect or enforce the rights of Northlake, to safeguard the security of our customers, Northlake and others and as required or permitted by applicable law.

4.  How We Share Personal Information

Northlake does not sell your personal information. However, in the normal course of business, we may share some of your personal information for our legitimate business purposes and as required or permitted by law, including:

  • With affiliates. Northlake may share personal information amongst our corporate affiliates that are also subject to this Policy.
  • With suppliers and service providers. Northlake may disclose your personal information to Northlake’s suppliers and service providers who perform services on our behalf such as payment processors, data processors and marketing, fraud detection and credit management providers. When we do use an outside company, we use contractual or other appropriate means to ensure that your personal information is protected substantially in accordance with this Policy.
  • With your consent. Northlake may disclose your personal information with your consent. You can withdraw your consent at any time by contacting us using the contact details provided in Section 8 of this Policy.
  • With any successor to all or part of our business. Northlake may disclose your personal information in connection with a proposed or actual business transaction, such as a corporate reorganization, merger or acquisition, or the sale of some or all of Northlake’s business or assets, provided that Northlake will require that the information recipient agree to protect the privacy of your personal information in a manner that is consistent with this Policy.
  • Other. Northlake and its service providers may disclose your information as required to comply with any court order, law, or legal process, including to respond to any government or regulatory request. We may also disclose your personal information to prevent fraud or criminal activity, to protect the rights and interests of Northlake, to safeguard the security of our customers, Northlake and others and as otherwise may be required or permitted by applicable law.

You authorize us to make enquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such enquiries. When we carry out these enquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our enquiries in full. This is an identity check only and should have no adverse effect on your credit rating.

5.  Retention, Location, and Protection of Personal Information

Northlake retains your personal information for the period necessary to fulfill the purposes outlined in this Policy or such longer retention period as may be required or permitted by applicable legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymized data for any legitimate business purpose without further notice to you or your consent.

We may process, store, and transfer your personal information in and to a foreign country, such as the United States, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, law enforcement or regulatory agencies of that country may be able to obtain access to your personal information in accordance with the laws of the foreign country.

Northlake employs safeguards, including organizational, technical, and physical measures, appropriate to the sensitivity of the personal information in its possession or under its control to protect that information from unauthorized access, collection, use, disclosure, disposal or similar risks. While Northlake uses reasonable efforts to protect your information, no method of transmission over the internet, or method of electronic storage is 100% secure, and therefore, Northlake cannot guarantee absolute security of your personal information.

6.  Accuracy, Access and Withdrawing Consent

By law you have the right to request access to and to correct the personal information that we hold about you. You may review, verify or correct your Northlake account information through the Website. You may also contact us using the information provided below under Section 8 of this Policy to request access to, correct, or delete any personal information that you have provided to us.

We may request specific information from you to help us confirm your identity and your right to access and provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Where you have provided your consent to the collection, use, and transfer of your personal information, you have the legal right to withdraw your consent subject to legal and contractual restrictions. To withdraw your consent, contact us using the information provided below under Section 8 of this Policy. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service.

7.  Changes to the Policy

We reserve the right to change, modify, or adjust this Policy from time to time. A revised Policy only applies to data collected subsequent to its effective date. Any revisions will be posted at least 10 days prior to its effective date. We include the date this Policy was last revised at the top of this Policy.

8.  Contact Us

If you have complaints or additional questions regarding this Policy, please contact us by email at CustomerService@NorthLakeFinancial.ca .

You can write to us at:

Northlake Financial ULC
201 Minets Point Road
Barrie, ON, L4N 4C2
Attn: Privacy Officer