Privacy Policy for CTM Financial Services

Effective Date: January 01, 2024
Last Updated: January 12, 2025

CTM Financial Services ("CTM," "we," "our," or "us") is committed to protecting the privacy and confidentiality of our customers' information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), relevant Ontario privacy laws, and other applicable regulations in Canada. This Privacy Policy outlines how we manage your personal information, ensuring transparency and trust.

1. Scope of Policy

This Privacy Policy governs the collection, use, and disclosure of personal and financial information collected by CTM Financial Services through online and offline interactions, or by other means, including our website, services, and communications, ensuring compliance with Canadian privacy legislation.

2. Accountability

We take full responsibility for the management of your personal information. CTM has appointed a Chief Privacy Officer (CPO) who oversees compliance with this Privacy Policy and applicable privacy laws. If you have concerns or complaints regarding our privacy practices, please contact our CPO at [Insert Contact Information].

3. Information We Collect

We may collect the following types of information:

  • Personal Information: Name, contact details (address, phone number, email), identification numbers (e.g., SIN), and other personal identifiers.
  • Financial Information: Bank account details, transaction histories, payment information, and invoicing data.
  • Technical Information: IP address, browser type, device details, and usage data from our digital platforms.
  • Third-Party Data: Information received from vendors, partners, or financial institutions, such as bank statements or transaction histories.
  • Voluntary Information: Any data shared during customer interactions or when using our services.

4. Identifying Purposes

We collect your information for the following purposes:

  • Delivering services, including payment processing, cash management, and treasury solutions.
  • Maintaining accurate records of transactions and providing real-time financial insights.
  • Communicating with you about your account, services, or updates.
  • Preventing fraud, unauthorized access, and ensuring data security.
  • Complying with legal and regulatory requirements.
  • Improving our products and services through anonymized, aggregated data analytics.

We commit to identifying the purposes for which information is collected at or before the time of collection.

5. Consent

We obtain your consent for the collection, use, or disclosure of your personal information, except where otherwise permitted or required by law. Consent may be express (written, verbal) or implied based on your actions and interactions with us. You may withdraw your consent at any time, subject to legal or contractual restrictions.

6. Limiting Collection

We limit the collection of personal information to what is necessary for the identified purposes. Information is collected in a fair and lawful manner, ensuring compliance with the principle of data minimization.

7. Limiting Use, Disclosure, and Retention

Your personal information will not be used or disclosed for purposes other than those identified, except with your consent or as required by law. We retain personal information only for as long as necessary to fulfill the purposes outlined or to comply with legal obligations. When no longer required, information is securely deleted or anonymized.

8. Accuracy

We make every effort to ensure that your personal information is accurate, complete, and up-to-date. You can request corrections to your information by contacting us at [Insert Contact Information].

9. Safeguards

We implement robust security measures to protect your information:

  • Encryption: Personal and financial data is encrypted during transmission (e.g., TLS) and at rest.
  • Access Controls: Access to sensitive data is limited to authorized personnel and systems with strict authentication protocols.
  • Monitoring: Continuous monitoring for unauthorized access, breaches, and fraud.
  • Compliance: Adherence to Canadian cybersecurity standards, including guidelines set by the Office of the Privacy Commissioner of Canada (OPC).

10. Openness

This Privacy Policy is available to the public through our website and upon request. Additional information about our privacy practices is available by contacting our Chief Privacy Officer.

11. Individual Access

You have the right to:

  • Request access to your personal information held by us.
  • Request corrections to your personal information to ensure its accuracy.
  • Request your information in a structured, machine-readable format (data portability).

To exercise these rights, please contact us at [Insert Contact Information]. We will respond within the timeframes required by law.

12. Provide Recourse

If you have concerns or complaints regarding our handling of your personal information, you can:

  • Contact our Chief Privacy Officer.
  • File a complaint with the Office of the Privacy Commissioner of Canada (OPC).

13. Cross-Border Data Transfers

If your information is transferred outside of Canada, CTM ensures that it is protected by contractual clauses or equivalent safeguards, in compliance with PIPEDA and relevant provincial laws.

14. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance user experience, analyze website traffic, and improve our services. You can manage or disable cookies through your browser settings. For more details, refer to our [Cookie Policy] (link).

15. Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Updates will be communicated through our website or other appropriate channels. Continued use of our services after updates constitutes acceptance of the revised Policy.

16. Contact Us

If you have questions, concerns, or complaints regarding this Privacy Policy, please contact us at:

CTM Financial Services (Canada)
info@ctmfinancial.ca

17. Legal Compliance

This Privacy Policy complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and relevant privacy regulations in Ontario and across Canada, ensuring transparency and trust for customers while safeguarding their personal and financial information.