General – This Privacy Notice for Canada Residents sets forth the privacy practices of AllianceOne Ltd. (“AOL”) applicable to consumers and individuals who reside in Canada.

Commitment – AOL is committed to respecting and protecting the personal privacy of the personal information of its clients and consumers and all individuals we interact with. Our primary focus is on securely processing personal information and avoiding incidents. Under the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the protection of personal information is required for all inter-provincial disclosures of information outside the province of origin. AOL has invested time and resources to ensuring that the confidential and personal information we receive remains protected as it relates to the collection of debt in Canada and the rights of consumers.

Identifying Purposes– Personal information is collected in order to properly identify, confirm, and administer the accounts of consumers. Consumers must be made aware at or before the time of collection, how we intend to use the information gathered. AOL will only collect, use and disclose personal information to assist in the collection of debts assigned by our clients, or as otherwise permitted or required by law.

Consent – Knowledge and consent of consumers is required for the collection, use, or disclosure of personal information, except when inappropriate, including where permitted or required by law. Under certain circumstances, AOL may provide personal information to its lawyers, agents or third parties to collect a debt, comply with a subpoena or court order, to a government institution requesting information with lawful authority, or as otherwise required by law. Consent is considered valid and sufficient when the consumer has been made aware of the specific intended use of collected information. In the case that information is to be used in the future for another purpose, new consent should be given.

Limiting Collection – The collection of personal information is limited to that which is necessary for the purpose identified and in connection with services provided by AOL to the consumer. We may collect information not available to the public from our clients, authorized third parties acting on the consumer’s behalf, data providers, consumer reporting agencies, as well as the consumer given it was collected by fair and lawful means. Such information may include, but not limited to:

• Name, address, telephone numbers, e-mail address
• History of credit card use, payment and balance history
• Credit history and scores

Limiting Use, Disclosure and Retention – AOL will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the consumer or as required by law. Personal data cannot be used or passed on in a manner inconsistent with the identified purpose. AOL may undertake efforts to see that another party to which AOL shares personal information is under a contractual obligation to use the personal information solely for the purposes for which the information was disclosed. AOL exercises no control over such parties and is not responsible for their conduct, actions, omissions, or information handling or dissemination practices. AOL does not sell personal information about consumers to unrelated parties. All employees are governed by a non-disclosure agreement prohibiting the disclosure or use of any confidential or personal information other than for the stated purpose. AOL retains personal information only for the length of time required for business purposes or as required by federal and provincial laws.

Accuracy – Reasonable steps will be taken to ensure that personal information under AOL’s control is as accurate, complete, and current as is necessary for the purposes for which it is to be used. Personal information will be updated to fulfill the purposes for which the information was collected and to minimize the possibility of using incorrect information.

Safeguards – Protecting personal information is fundamental to AOL. AOL has implemented physical, electronic, as well as procedural security measures to safeguard against the unauthorized release of or access to personal and private information. All employees are trained on the importance of security awareness and privacy laws as well as the requirements in our Privacy Policy. Personal information is only accessible by appropriate personnel based on role within the organization.

Openness – The AOL website can be visited for company information and informational tools without revealing any personal information. In the event that a consumer requests an Internet delivered service, it would be necessary for us to obtain personal information to identify and honor the consumer’s request.

Rights to Access – Individuals have the right to access the information that AOL has in its records. Requests for information that AOL may have about an individual can be forwarded in writing to:

• AllianceOne Ltd.
• Attn: Privacy Officer
• 75 Eglinton Ave E. Suite 200
• Toronto, ON
• M4P 3A4

In order to protect the consumer, AOL will take steps to confirm the identity of the requestor prior to providing any information. Updates will be made to AOL’s records if information is incomplete or inaccurate. AOL will respond to the request within a reasonable timeframe, and not later than 30 days after receipt of the request in accordance with PIPEDA regulations.

Registering a Privacy-Related Complaint – AOL will investigate all complaints and take appropriate measures, including amending policies and procedures if necessary. To register a complaint, our Compliance Department can be contacted:

• In writing:
  • AllianceOne Ltd.
  • Attn: Compliance Department
  • 75 Eglinton Ave E. Suite 200
  • Toronto, ON
  • M4P 3A4

• Phone: (800)858-4472
• Online via AOL’s website www.allianceoneinc.com/contact-us/

AOL is committed to servicing consumers to come to a fair and timely solution. In the event that there are still unresolved concerns regarding the handling of personal information, subsequent written correspondence should be addressed to AOL’s privacy officer.

AllianceOne Ltd.
Attn: Privacy Officer
75 Eglinton Ave E. Suite 200
Toronto, ON
M4P 3A4

This Canada Consumer Privacy Policy is effective January 1, 2020. Any previous version of this policy is superseded going forward by this version.