Privacy Statement

ravelers Capital Corp. is part of Travelers Financial Group, a Canadian privately held non-bank lender not affiliated with Travelers Indemnity Co. and its subsidiaries and affiliates (“Travelers Capital”, “TCC”, “we”, “us”, “our”, or the “Company”) are committed to respecting your privacy. This Privacy Statement describes TC’s privacy practices in relation to the websites, products, services and programs owned and operated by Travelers Capital. In addition, this policy states how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Statement.

We urge you to read this Privacy Statement so that you understand our commitment to you and your privacy, and how you can participate in that commitment. When you visit our websites, or provide personal information to us through other means, you consent to the use of your information as described in this Privacy Statement.

Travelers Capital may review and update this Privacy Statement periodically to reflect changes to our privacy practices. We will provide notification of material changes to this Privacy Statement through the Company’s website. We encourage you to periodically review this page for the latest information on our privacy practices.

1. Web sites covered

This Privacy Statement covers information practices, including how the Company collects, uses, shares and secures the personal information you provide, of websites that link to this Privacy Statement.

Travelers Capital’s websites may contain links to other websites. The information practices or the content of such other websites is governed by the privacy statements of such other websites. Travelers Capital encourages you to review the privacy policies of other websites to understand their information practices.

Please also note that co-branded websites (i.e., websites where TC presents content together with one or more of our business partners) may be governed by additional or different privacy statements. Please refer to the privacy statement on those websites for more information about applicable privacy practices.

2. Personal information we collect

This Privacy Statement applies to personal information and other information collected by Travelers Capital or its service providers from or about:

1. Visitors to, or users of, its websites;
2. Service providers and business partners;
3. Job applicants; and
5. Other third-parties that it interacts with.

The personal information Travelers Capital collects includes the following:

Travelers Capital utilizes third party recruitment firms for certain recruiting activities. Such firms may send us potential candidate information such as name, email address, physical address, compensation expectations and work history.

Website navigational information. TC may collect certain information about you from your web browser when you visit our websites. This information may include your Internet Protocol (“IP”) address, browser type, browser language, and the date and time of your request. This information could indirectly identify you and gathering this information from you helps us ensure our websites and other services work correctly in support of our customer analytic efforts.

Email communication. We use pixel tags or web beacons in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on an Travelers Capital website. We use these tools to determine potential interest in particular topics, as well as measure and improve the effectiveness of our communications with you.

Cookies and similar technologies. We may collect information about your use of our websites through cookies and similar technology, such as Google Analytics. A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to our websites. Travelers Capital uses cookies to operate and improve our websites as well as to simplify the interaction with you. When you visit our websites, our servers send a cookie to your computer or mobile device to help personalize your experience. Cookies help us better understand user behavior. Cookies only stand to recognize your web browser but information collected from cookies is not personally identifiable. Travelers Capital may also use web beacons or other technologies in conjunction with cookies to gather information about your visit to our websites. Web beacons may be embedded through our website or electronic communications and can allow servers to collect information related to your visit. Web beacons are primarily used to provide content and advertisements that are more relevant to you.

Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features available through our services.

Social media applications. Our websites include social media features, such as the LinkedIn or Twitter button and other widgets that run on our website. These features may collect your IP address and which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the organization providing it.

Third party sources. Travelers Capital may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our services to you, and prevent or detect fraud. We work closely with third parties (for example, business partners, service providers, sub-contractors, analytics providers and search information providers) and may receive information about you from them.

Public forums, blogs and the customer reference program
Travelers Capital websites may feature bulletin boards, blogs or forums. Any personal information that you choose to submit via such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Travelers Capital is not responsible for the personal information you choose to submit in these forums.

3. How we use and disclose personal information

Travelers Capital may use your personal information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your personal information to support our business functions, such as sales, marketing, services, recruitment and legal functions. For example, we may use this information to:

• Fulfill requests;
• Send product and services updates;
• Respond to customer service requests;
• Send marketing communications;
• Improve our websites and marketing efforts;
• Conduct research and analysis;
• Comply with legal and/or regulatory requirements;
• Respond to questions and concerns; and
• Process employment applications and background checks.

Apart from using your personal information to support our own business functions, we may disclose your personal information under the following conditions:

Disclosure of personal information to third parties. Travelers Capital will not rent or sell your personal information to others but may disclose personal information with third-party vendors and service providers that work with Travelers Capital. We will only share personal information to these vendors and service providers to help us provide a product or service to you. Examples of third parties we work with are background check agencies, benefits providers, financial institutions and other service providers that provide corporate functions to us such as human resources and customer relationship management. These third parties only have access to personal information necessary for them to perform their services.

Disclosure of personal information for business purposes. In the event of corporate divestures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, or general business transactions or proceedings, Travelers Capital may buy, sell, divest or transfer your personal information.

Disclosure of personal information for legal and safety reasons. Travelers Capital may be required to disclose personal information to regulatory authorities, law enforcement agencies or government agencies. We may disclose information to:

• comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law;
• respond to lawful requests by public authorities, including to meet national security or law enforcement requirements;
• in the event of an emergency that threatens an individual’s life, health, or security; or
• to the extent permitted by applicable law, in special cases in which we believe it is reasonably necessary to investigate, identify, or take preventive measures or bring legal action against someone who may commit or cause harm, fraud, abuse, or illegal conduct, such as a threat of harm to you or anyone else, interference with our rights or property, or public safety anywhere in the world.

Disclosure of personal Information via links to third party services and applications. Using our websites or services may link you to third party websites, services, and applications. Travelers Capital is not responsible for any personal information collected by such third parties which use is governed through the third party’s website’s privacy policies. Any interactions you have with these websites, services, or applications are beyond the control of Travelers Capital. When you post information to or through such services, those websites’ privacy policies apply. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.

4. Customer data

Travelers Capital’s customers may electronically submit data or information to us for hosting and processing purposes (“Customer Data”). In accordance with the Travelers Capital policy, Travelers Capital will access Customer Data only for providing our products and services or for preventing or addressing service or technical problems (at a customer’s request in connection with customer support matters), or as may be required by law. Travelers Capital will not otherwise review, share, distribute, or reference any Customer Data except as authorized by the applicable customer.

Travelers Capital may transfer personal information to third party companies that help us provide our products and services. Transfers to subsequent third parties are covered by the provisions in this Privacy Statement regarding notice and choice and the service agreements with our customers.

Travelers Capital acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to us by an Travelers Capital customer and you wish to exercise any rights you may have to access, correct, amend, delete, or limit uses or disclosures of such data, please inquire with our customer directly. Because Travelers Capital personnel have limited ability to access data our customers submit to our products and services, if you wish to make your request directly to Travelers Capital, please provide the name of the Travelers Capital customer who submitted your data to our products and services. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.

5. How Travelers Capital protects your data

Security of your information is of the utmost importance to Travelers Capital. Travelers Capital uses reasonable security practices, including technical and physical safeguards, to protect the security of your personal information from misuse and unauthorized access and disclosure. Nevertheless, such security measures cannot prevent all loss, misuse, alteration, or unauthorized access or disclosure of personal information, and we are not able to guarantee absolute security.

6. Access and choice

Travelers Capital may retain your information for a period of time consistent with the original purpose of collection, legitimate business interests, to conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

7. Conflicts with this Privacy Statement

This Privacy Statement may not apply to the extent it conflicts with other controlling terms and conditions (such as, for example, an agreement for our products and services between Travelers Capital and you or your organization) or applicable law or regulation.

8. How to contact us

Any questions, inquiries, complaints, and requests related to this Privacy Statement can be directed to us by mail at:

1055 Dunsmuir Street, Suite 3501
Vancouver, BC V7X 1K8
Canada