PRIVACY POLICY

Protecting personal information is a responsibility that Capital Trust Financial takes very seriously. Capital Trust Financial has adopted a series of Privacy Policies in order to address the specific privacy concerns of certain groupings of individuals and specific issues relating to the use of our website.

This Privacy Policy briefly describes how Capital Trust Financial, hereinafter referred to as “we,” collects, uses and discloses your personal information and applies to the personal information of all individuals, unless the personal information is related to an employee of Capital Trust Financial, as their personal information is dealt with in the Capital Trust Financial "Employee Privacy Policy."

This Privacy Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable. This Privacy Policy has a limited scope and application and the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

What is personal information?

Personal information means information about an identifiable individual but does not include business contact information (such as an individual's name, title, business address, business phone and fax number) when such information is collected, used or disclosed for the purpose of business communications.

What types of personal information do we collect?

We collect and maintain different types of personal information in respect of individuals with whom we interact. This includes:

  • contact and identification information, such as your name, address, telephone number, e-mail address and photograph;

  • product- and service-related information concerning the products and services that we provide to, or receive from, you;

  • credit and financial information such as your payment methods and preferences, and billing and credit history;

  • business relationship information, including information related to your agreements, preferences, advisors and decision-makers; and

  • customer relationship information such as customer service requests and feedback and information requested or provided by or from you.

In the purchase of a new vehicle, Capital Trust Financial may collect personal information such as your name, address, birth date, social insurance number, marital status, living arrangements (rent or own), employment situation (past and present), banking information and credit information. While disclosing your social insurance number to us is not mandatory, we ask that you provide your social insurance number to assist us in identifying you and your credit records. Capital Trust Financial may also require the same information from any spouse, partner or co-signer.

The choice to provide Capital Trust Financial with personal information is always yours. However, your decision to withhold particular details may limit our ability to provide our credit services to you. If we are unable to accommodate your request based on the information that has been provided to us, we may ask for additional details in order to identify other ways to be of assistance. In some instances, Capital Trust Financial may also maintain a file containing contact history that is used for customer inquiry purposes. To help us better understand our markets, we may also gather information for analytical purposes by extracting demographic information from existing files.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why do we collect your personal information?

Your personal information is collected so that we can communicate with you, process your application and provide you with the services you have requested such as auto loans. We also collect personal information to enable us to manage and develop our business and operations, including:

  • to determine your financial situation by collecting credit and other related financial information from our affiliates, strategic partners, credit agencies, other financial institutions and from references provided by you;

  • for reporting purposes under credit regulations and to credit and debit card issuers, financial institutions or other lending services;

  • to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;

  • to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;

  • to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services and work to improve the products and services that you provide to us;

  • to be able to inform you about Capital Trust Financial’s other products and services;

  • to be able to inform you of products and services that third parties who we have carefully selected as partners may wish to offer you, including sending you information promoting the products and services of those members or partners;

  • to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);

  • to protect us against error, fraud, theft and damage to our goods and property;

  • to enable us to comply with applicable law or regulatory requirements; and

  • any other reasonable purpose to which you consent.

How do we use your personal information?

We use your personal information for the purposes described in this Privacy Policy or for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information (which consent may be expressed, deemed or implied, as explained below). We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

With whom may we share your personal information?

We share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with establishing, maintaining and managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that collaborate with Capital Trust Financial in the provision of services to you; and third parties whose services we use to perform our services.

In addition, personal information may be disclosed or transferred to another party in the event of a change in ownership of or the grant of security in all or a part of Capital Trust Financial through, for example, an asset sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Further, your personal information may be disclosed:

  • as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavour to not disclose more personal information than is required under the circumstances;

  • to comply with valid legal processes such as search warrants, subpoenas or court orders;

  • to protect the rights and property of Capital Trust Financial;

  • during emergency situations or where necessary to protect the safety of a person or group of persons;

  • where the personal information is public; or

  • with your consent.

Your consent is important to us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or expressed.

For example, by signing a Capital Trust Financial Finance or Lease Agreement you consent to Capital Trust Financial collecting, using and disclosing your personal information for the purposes described in this Privacy Policy, including contacting parties to the purchase of your vehicle including but not limited to automotive dealers with whom you may have applied for credit with, insurance agents, brokers and companies you may have applied for insurance with; references; employers; financial institutions you may have relationships with; and credit-reporting agencies.

Typically, we will seek your consent at the time that we collect the personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavour to advise you of that purpose before such use or disclosure.

We assume that, unless you advise us otherwise, by receiving a copy of this Privacy Policy or by continuing to deal with us, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to, or acquire products or services from, you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

How do we safeguard your information?

Capital Trust Financial endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Online security

At the Capital Trust Financial website, we do not collect information that could identify you personally unless you choose to provide it voluntarily. You are welcome to browse the website anonymously and privately at any time without revealing any personal or financial information about yourself.

We endeavour to manage our server environment appropriately and to ensure firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis and we endeavour to employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.

Our website uses Secure Socket Layer (SSL) and 128-bit encryption technologies to enhance security when you visit the secured areas of these sites including online credit application. SSL is the industry-standard tool for protecting and maintaining the security of message transmissions over the Internet. When you access your accounts or send information from secured sites, encryption will scramble your data into an unreadable format to inhibit unauthorized access by others.

Websites governed by this Privacy Policy

The website that is governed by the provisions and practices stated in this privacy policy is: http://www.capitaltrustfinancial.com.

The Capital Trust Financial website may contain links to other third-party sites that are not governed by this Privacy Policy. Although we endeavour to only link to sites with high privacy standards, our Privacy Policy will no longer apply once you leave the Capital Trust Financial website. Additionally, we are not responsible for the privacy practices employed by other third-party websites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.

Accessing and amending your information

At Capital Trust Financial, decisions are made based on the information we have. Therefore, it is important that your personal information is accurate and complete. To make a change to the personal contact information contained in your file, you may do one of the following:

  • Contact our office at 1-855-346-5626 and we would be happy to change your personal information in our system; or

  • Send a facsimile to us at 1-888-239-6450 to request a change in your personal contact information.

You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that such communication must be in writing.

When requesting an amendment in, or access to, your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to amend or access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any such fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record-retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons for this, subject to any legal or regulatory restrictions.

Questions, concerns and complaints


If you have a concern, question, comment or complaint about our privacy, confidentiality or personal information handling practices, please contact:

Capital Trust Financial

100 York Boulevard Suite 205

Richmond Hill, ON, L4B 1J8
Phone: 1855-346-5626
Fax: 1-888-239-6450
Email: privacypolicy@capitaltrustfinancial.com

Updating this Privacy Policy

Any changes to our privacy policy and information handling practices will be acknowledged in this Privacy Policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of this Privacy Policy.