PRIVACY POLICY - Updated May 8, 2017

CERTN HOLDINGS, INC. PRIVACY POLICY

 

This Privacy Policy sets out Certn’s approach to the collection, use and disclosure of personal information in connection with our businesses in Canada and the United States, including but not limited to personal information collected, used and disclosed when you access or use our Website.

 

Scope of this Privacy Policy

We are committed to protecting your privacy, and support a general policy of openness about how we collect, use and disclose personal information in connection with our business in Canada and the United States. This Privacy Policy provides an overview of our business and explains how we collect, use and disclose personal information. By using our Website, you consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

 

Definitions

In this Privacy Policy, we will use the following terms:

  • “Cookies” are small text files offered to a user's computer by web servers in order to keep track of the user's browser as a website is navigated.
  • “Personal information” means any information about an identifiable individual.
  • “Principals” means individuals that own and/or are involved in the management of a business.
  • “Us”, “we”, “our” and “Certn” means Certn Holdings, Inc.
  • “Website” means the website operated by Certn and located at http://www.Certn.co

 

About Us

Certn is an information and data analytics company with the goal of offering the highest quality alternative to the current consumer credit-related products and services. Today, we serve the business community by providing consumer and business risk, fraud and identity management information, as wells analytics tools to help our clients make decisions.

 

An Overview of Our Business

We facilitate business-consumer interactions by providing consumer credit, social and behavioural profiles to our clients, which include banks, credit-card companies, finance companies, landlords, property managers and other institutions (the “Clients”). By their nature, our services must include some personal information about our Clients’ potential or existing customers (the “Client Customers”). Accordingly, we regularly collect, use and disclose personal credit, social and behavioural information of consenting Client Customers. Credit grantors, credit bureaus and other institutions provide Certn with factual information about how the consenting Client Customers pay their bills and other debts. Credit reporting agencies, such as Equifax, compile and assemble this information, along with public record information, into a "file" for each Client Customer. In return, credit grantors and authorized institutions, pursuant to the applicable federal, state and/or provincial consumer reporting legislation, are able to obtain credit reports about Client Customers.

 

We facilitate commercial transactions by providing principle credit, social and behavioural profiles to our Clients.  Our services will contain credit information about potential or existing Client Customers including businesses, as applicable.  In some instances, credit information about businesses may also contain  certain personal information as provided in a business credit report about the principals of the business, such as name, address, phone number and percentage ownership in the business.  Similarly, credit information about individual Client Customers may also contain information about the individual’s related businesses and/or affiliations    

 

Our Collection Practices for potential or existing Client Customers

We primarily collect your personal information from the following sources:

  • Reports about you that are provided to us by credit reporting agencies, bureaus, grantors or other institutions that are responsible for obtaining your consent to provide the information to us;
  • Collection agencies;
  • The internet, and public social media profiles;
  • Directly from you in response to any dealings we have with you including the Certn questionnaire; and
  • Public records, federal, state and/or provincial government offices, public registries, and other sources permitted by law.

 

We limit our collection of personal information to include only what is necessary to supply our Clients with the accurate and up-to-date information they need to make meaningful decisions and in order to provide our Clients with the other services described in this Privacy Policy. We periodically review the data in our system to ensure that it only contains information relevant to the services we provide. Furthermore, we ensure that our retention policies comply with the requirements of privacy laws and the applicable federal, state and/or provincial consumer reporting legislation.

 

If you call us, we may record and retain the recording to ensure the accuracy of our discussions and for quality control and record keeping purposes.

 

Information We Collect

(a) What is Included in Our Reports

Certn’s consumer reports may contain the following information:

  • Identifying information: Client Customer name, previous name(s), date of birth, Social Insurance Number (including temporary and/or previous Social Insurance Numbers), current and previous addresses and telephone numbers, and current and previous employers;
  • Credit history: Record of payment history on current and previous bills/debt obligations, including payments on loans, credit cards, lines of credit and mortgages owing to organizations such as retail stores, banks, finance companies and telecommunications companies. 
  • Public records: Information that may affect creditworthiness, such as judgments, bankruptcies, consumer proposals and registered items;
  • Inquiries: A list of credit grantors and other parties authorized by the consumer and/or by law that have received all or part of a Client Customer’s credit information.  Also lists organizations that have received a service from Certn where consumer credit information was used but not necessarily disclosed, such as authentication;
  • Collections: Information about collection matters. This segment may include information about outstanding collections on business accounts if you are personally liable for the debt.  It may also include information about outstanding family maintenance support obligations, if permitted by law; 
  • Banking: Information about bank accounts that were closed by an institution for reasons such as empty envelope deposit, NSF cheques or uncollected overdraft charges;
  • Remarks:  All remarks that have been added to your file, such as a fraud alert or a consumer statement;
  • Behavioural Profiles: Results from the psychometric test questions that may be asked in a Certn questionnaire; and
  • Social Profiles: Results from a scan of the internet and public social media profiles for information containing content published by you, about you or on your behalf.

 

Information We Do Not Collect

Certn reports do not contain:

  • Medical histories;
  • Information about purchases paid in full with cash or cheques;
  • Race, creed, colour, ancestry, ethnicity or political affiliations.

 

Our Use and Disclosure of Your Personal Information

We limit our use of personal information to those purposes which have been disclosed to the Client Customer by us or our Clients and for which appropriate consents have been obtained, or for purposes which are otherwise permitted by law. In connection with our services, we do not have direct relationships with the Client Customers or, where applicable, its principals.  Accordingly, we require our credit-granting and other Clients to inform their Client Customers of the purposes for which they are providing personal information to Certn, or accessing personal information from Certn, and to obtain appropriate consent at the time the information is collected from the Client Customer and/or prior to its use or disclosure by Certn.  We also require our Clients to limit the use of personal information obtained from Certn to purposes that are permitted by law.

 

Certn uses and discloses personal information in the following circumstances:

  • To provide our consumer credit reporting services, business credit reporting services, and other related services to our Clients;
  • To provide authentication, ID verification and/or credit services to Clients purchasing your credit file;
  • To communicate with you regarding services that may be of interest to you;
  • To manage, administer, collect or otherwise enforce accounts;
  • If Certn was ever sold, or if we merged with another company, or transferred part or all of our shares or assets, we may disclose and/or transfer personal information to our successor or assignee who may collect, use and disclose the personal information for substantially the same purposes as described in this Privacy Policy;
  • To assist in the investigation of a contravention of a law and/or fraudulent activities;
  • To fulfill our obligations under consumer reporting and privacy legislation (such as, a request to initiate an investigation); and
  • To act in respect of an emergency that threatens the life, health or security of an individual or for other purposes as permitted or required by law.

 

In addition, we may provide anonymous information (i.e., information that does not identify Client Customers or, where applicable, its principals) in the form of aggregate or demographic data to our Clients or service providers.  We may also generate and use anonymous information to develop, enhance or validate our products, processes or services. Personal information will necessarily be used to generate anonymous information and, when required, to research, validate and test the use of anonymous information in such processes, products, services and enhancements.

 

Certn may share personal information with third parties engaged to assist us in providing services and information to our Clients and to individual consumers. In addition, we may engage third parties to assist us with infrastructure maintenance and support.  These service providers are prohibited from using your personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed by Certn and to comply with the general privacy principles described in this Privacy Policy. Some of these service providers are located outside of Canada.  As a result, your personal information may be subject to local laws, which may permit local law enforcement, government or national security authorities to have access to your personal information in certain circumstances.

 

Obtaining Consent

We collect, use and disclose personal information when the Client Customer is aware of the purposes for which the information will be used or disclosed, and has given his or her consent to such use or disclosure, except where collection, use or disclosure of personal information without consent is permitted or required by law.

 

In most cases, Client Customers will not provide such consent directly to Certn, but to our Clients. We require our Clients to obtain consent prior to providing Certn with personal information, and prior to accessing the personal information contained in our credit files.

 

Our Accountability

We have appointed a Privacy Officer to oversee our compliance with the privacy principles established by the federal Personal Information Protection and Electronic Documents Act, and with provincial privacy and credit reporting legislation. However, protecting personal information does not begin and end there: we are committed to fostering a sense of responsibility amongst our employees for protecting the privacy and accuracy of personal information while it is in our care.

 

Likewise, our Clients have obligations to Client Customers when accessing personal information from us or providing personal information to us.  We have processes in place to encourage our Clients to comply with applicable law and obtain the necessary consents. Such processes include entering into binding agreements with our Clients and conducting random audits of our Clients’ internal procedures; however, the responsibility for the Clients’ compliance ultimately rests with them.

 

Retention of Your Personal Information

Certn retains your personal information in our information database for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. Certn may delete personal information reported about you by a data supplier if our relationship with the data supplier comes to an end.  The end of a data supplier relationship may impede our ability to maintain a current and accurate credit file and/or carry out our investigation procedures.  We may delete personal information in these circumstances to ensure that your file remains as accurate, complete and up-to-date as possible. 

 

Contacting Us

Please contact our Consumer Relations Centre using the contact information below.  Our Consumer Relations Centre is staffed by trained personnel who can assist with your inquiries.  You may also direct your inquiry or request directly to our Privacy Officer.  We may require that you put any request for access or correction in writing.

 

Consumers can also visit our website at www.Certn.co.

Telephone: (844) 822 3786

 E-mail: privacy@certn.co 

Hours of Operation: 8:00 a.m.- 8:00 p.m. ET

 

Adverse Action

When a Client bases its decision to deny a benefit or to increase a charge to the Client Customer,  in part on credit information received from Certn, the Client has a statutory obligation to inform the Client Customer that it obtained the credit information from us. In this situation, Clients must provide individuals who are declined a benefit or where are charge is increased with Certn’s contact information so that the individual can verify the content of his file and, if necessary, request from the credit bureau that information be amended or deleted.  Certn does not play a role in the decision to deny or advance credit or other benefit or to increase or decrease a charge, and accordingly, the Client Customer should deal directly with the institution for more information on the denial of credit or a benefit or any increase in charges .

 

Cookies

Certn's Website makes use of "per-session" cookies. Unlike "persistent" cookies, which are stored on a user's hard drive and can last indefinitely, per-session cookies are stored only in a browser's temporary memory and are deleted when the browser is shut down.

When users visit our Website, our web server offers the user's browser a per-session cookie. As the Website is navigated, this cookie is read back to our web server, allowing us to generate an anonymous "click trail" profile of the visit. From the aggregated information about visits, Certn learns how visitors interact with its Website, how the Website design and content can be improved, and how visitors' experiences can be improved.

 

Certn does not link, share or associate the contents of the per-session cookie with any other information in a way that would enable the identification of visitors to our Website. Nor do we track or link together multiple visits by any single user over time. Our per-session cookies cannot be "read" by any other web servers, so users cannot be tracked or profiled using Certn's cookies if they visit multiple sites on the Internet. Some browsers can be set to reject all cookies. If a user chooses to modify a browser in this manner, some pages of our Website may not function properly.

 

IP Addresses and Server Logs

Unique Internet Protocol (IP) addresses are assigned to all Internet users by their Internet Service Providers (ISPs). IP addresses do not directly identify Internet users; however, through an ISP, an IP address may be linked to a particular user.

 

During a visit to a website, certain information about a user's traffic patterns, linked with the user's IP address, is passively and automatically collected in the normal course of establishing and maintaining a website connection. This information is logged by the web server of the website that is visited.

 

The following information is logged by Certn's web servers during visits to our Website: IP addresses, type of operating system, time and duration of visit, web pages visited and browser type. We do not link server log information to any other information in a way that would enable the identification of visitors to our Website. Server log information is analyzed by us in order to improve our Website and to customize the Website for users. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on our Website. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

 

Links to Third Party Sites

Our Website may offer links to other third party websites. You should be aware that operators of linked websites may also collect your personal information and information generated through the use of cookies or other tracking technologies when you visit their websites. Certn is not responsible for how such third parties collect, use or disclose your personal information, so it is important to familiarize yourself with their privacy policies before visiting their websites or providing them with your personal information.

 

Changes to this Privacy Policy

Certn reserves the right to modify this Privacy Policy at any time without notice. The Privacy Policy posted at any time or from time to time via this website shall be deemed to be the Privacy Policy then in effect.

 

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