Please read this Policy carefully. If you do not agree with this Policy, you should not access or use our website or services. This Policy should be read in conjunction with the REFY website terms and conditions (the “Terms and Conditions”) available at www.refyfinancial.com/terms, into which this Policy is incorporated by reference.
This Policy was last updated on July 17, 2019. We reserve the right to revise this Policy at any time and, as such, you should review its terms each time that you use the website or services. Any changes to this Policy will be promptly communicated on this page, but will not go into effect until at least five (5) days after they are posted.
REFY is responsible for personal information under our control. We have established policies and procedures to effectively safeguard any confidential personal information that we have on file or which we collect, and to deal with complaints and inquiries. We are committed to maintaining the accuracy, confidentiality, and security of your personal information, and we will ensure that you have access to information regarding the policies and procedures that we use to manage your personal information.
REFY has designated a privacy officer (“Privacy Officer”) who is accountable for our compliance with this Policy, and for ensuring that information about our policies and practices relating to the management of personal information is easily accessible. All questions or concerns regarding this Policy and our compliance with it should be directed to the Privacy Officer in writing, and sent by email to email@example.com, or by post to:
400 – 4180 Lougheed Highway, Burnaby, BC V5C 6A7
Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user. If you are located in Canada, you may contact the Office of the Privacy Commissioner of Canada at 30 Victoria Street, Gatineau, Quebec K1A 1H3 or https://www.priv.gc.ca/ with any complaints regarding this Policy. If you are located in the United States of America, you may contact your state or local consumer protection agency. A list of these agencies can be found at https://www.usa.gov/privacy.
By using our website and services, you signify your agreement to the terms and conditions of this Policy and to our collection, use, and disclosure of your personal information as set out herein. You may change or withdraw your consent to the collection, use, or disclosure of your personal information at any time by contacting the Privacy Officer in writing at the address listed above. In some circumstances, a change or withdrawal of consent may affect your ability to use our website or services.
We collect personal information only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information). Personal information that is collected may include, but is not limited to:
Subject to any legal or accounting requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected. Personal information that is no longer required will be destroyed, erased, or made anonymous, although copies of deleted information may continue to exist on back-up media.
Users may visit our website without telling us who they are, or revealing any information about themselves. However, like many organizations’ websites, our web server automatically logs certain non-identifying information related to a user’s visit to the website, including the Internet Protocol (IP) address of the user’s computer, the user’s Internet service provider (ISP), the type and version of the browser that the user is using, the date and time the user accessed our website, the Internet address of the website from which the user linked directly to our site, the operating system that the user is using, and the pages of the website that the user has visited. We make no attempt to link this information with the identity of individuals visiting our website without express permission of the user(s). We may, however, review server logs and anonymous traffic for system administration and security purposes (for example, to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about website usage). The possibility therefore exists that server log data, which contains users’ IP addresses, could, in instances of criminal malfeasance, be used to trace and identify individuals. In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches.
If you provide comments or other feedback to us, you agree that such comments or other feedback become the property of REFY in accordance with the Terms and Conditions, and we may use and disclose them for any purpose set forth therein, provided that we do not associate them with your personally identifiable information.
A “cookie” is a small piece of information stored on your computer by a web page. It is used to identify you to the web server. It tells the server who you are when you return to a page on the same website. Your browser will only send a cookie back to the domain that originally sent it to you. A cookie cannot run any programs, deliver any viruses, or send back information about your system.
Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or to alert you when cookies are being sent. If you decline cookies, you will still be able to use our website and services, but your ability to access certain features and functions may be affected.
Some of our web pages contain an invisible electronic image known as a “web beacon.” Web beacons are similar in function to cookies, but allow websites on different domains to share information. We may use web beacons to transfer your subscription access information between our websites and domains. Web beacons do not transmit any personal information that we collect to any websites that are not owned by REFY or its affiliates.
We will identify the purposes for which we collect personal information before or when we request the information. We will not collect personal information which is not necessary and, except as specified below, will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected without first obtaining your consent. The information that we collect is used and disclosed only for business purposes. These include:
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, government request, subpoena, oral or written discovery, or court order, or based on our good faith belief that it is necessary to do so in order to comply with such law, request, subpoena, discovery, or court order, or to protect our assets, the users of our website, or the public.
We may disclose your personal information in response to requests from government agencies, law enforcement authorities and regulators, or to satisfy legal or regulatory requirements. We may also disclose your personal information when we buy a business or sell all or part of our business.
Subject to your opting out below, we may sell or otherwise provide your personal information to our affiliates and non-affiliated third parties, including persons or organizations that offer products or services directly or indirectly related to the motor vehicle sales industry, including car financing, insurance, warranties, roadside assistance, and mechanical repair. You acknowledge and agree that our affiliates and the non-affiliated third parties to whom we sell or provide your personal information may, in connection with the purpose for which the information was disclosed, conduct searches in relation to your personal information, including credit checks, or contact you to request additional information. We will use appropriate contractual or other means to require our affiliates and non-affiliated third parties to whom your personal information is disclosed to provide a comparable level of protection while the information is being used by them and to refrain from further disclosing your personal information without your consent, except as provided in this Policy.
You may opt out of receiving communications from us at any time by following the opt-out instructions in the email communication, by emailing us at firstname.lastname@example.org.
You further acknowledge and agree that, in the course of our supply of services to you, we may delegate our authority to collect, access, use, and disseminate your information to third party subcontractors. Third party subcontractors may include web hosts, payment processors, delivery and logistics providers, social network integrators, and membership vendors. If we transfer any personal information to a third party subcontractor, we will provide the subcontractor only with the information needed to perform the subcontracted service, and will use appropriate contractual or other means to provide a comparable level of protection while the information is being used by them. However, you agree not to hold us liable for the actions of any third party subcontractor, even if we would normally be held vicariously liable for their actions, and understand that you must take legal action against them directly should they commit any tort or other actionable wrong against you.
We have implemented reasonable physical, organizational, contractual and technological security measures to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive personal information. We use user IDs, passwords, and encryption technology, maintain our servers and paper files in locked premises, and restrict the employees and contractors who have access to personal information to those having a “need to know” and who are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner. When destroying personal information, we delete electronically stored personal information and shred any tangible materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.
We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. Therefore, by accessing our website, using our services and/or communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization.
REFY has a responsibility to ensure that all personal information contained in our records or which is disclosed to third parties for the purposes described above is accurate, complete and up-to-date. You may make a request in writing for access to your personal information. We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed. You may have reasonable access to your personal information, and if you demonstrate the inaccuracy or incompleteness of personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data, if your personal information changes, or if you wish to have your information removed from our files. All notices and requests should be in writing and sent to the Privacy Officer at the one of the addresses set out above (see: Accountability and Openness / Compliance).
You acknowledge and agree that your personal information may be transmitted, transferred, processed, and/or stored outside of Canada, including in the United States of America. We will use reasonable means to ensure that your information is protected, but cannot guarantee that the laws of any foreign jurisdiction (including, inter alia, the United States of America) will accord the same degree of protection as the laws of Canada. By submitting your personal information to us, you consent to the transmission, transfer, processing and/or storage of your personal information to other jurisdictions outside of Canada, including, but by no means limited to, the United States of America.
Our website may contain optional links to advertiser and other third-party Internet sites and services. You acknowledge that these third parties may collect data from users or their computers. The accessing and use of third-party websites is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites. This Policy applies only to the REFY website, and we encourage you to review the privacy policies contained on each Internet site that you use.
Minors (persons under the age of 19 in British Columbia, although the age of majority may vary in other jurisdictions) are not eligible to use the website or services, and we request that minors do not submit any personal information to us. REFY does not knowingly collect personal information from minors.
You agree that your access to and use of the REFY website, including this Policy, and services is governed exclusively by the laws of the Province of British Columbia and the federal laws of Canada applicable therein (excluding conflicts or choice of laws principles).