Apollon Investments Ltd is committed to protecting the privacy and security of customer personal information (including persons holding securities in respect of which we act as Trustee). This policy explains the types of personal information we collect, how it is used, and the steps we take to ensure customer personal information is handled appropriately.
Our policies and practices have been designed to comply with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) or corresponding provincial privacy acts, as applicable (collectively “Privacy Laws”).
What is Personal Information?
Personal information is any information about an identifiable individual including unrecorded information or information recorded in any form. Personal information includes such things as residential address, age, income, date of birth, ethnic origin, medical history, credit history, payment records and credit card number. The following types of information about individuals are not considered personal information:
- Business contact information (e.g. business phone and fax number and address)
- Public telephone directory information, where the subscriber can refuse to be listed
- Professional and business directories available to the public
- Certain public registries and court records
- Certain other publicly available printed and electronic publications
Our commitment to privacy is governed by the following privacy principles:
1. We are accountable to you
Apollon Investments Ltd is responsible for all personal information in its possession or control, including any personal information that is provided to us by our agents or transferred to third parties for processing, storage or other purposes. We have a designated Privacy Officer who is accountable for compliance with this policy.
2. We tell you how we use your personal information
In most situations, the reason why we are collecting personal information and its use is obvious from the context. In other situations, Apollon Investments Ltd identifies the purpose for which your personal information is collected and its use. We do this explicitly or by implication where the purpose of using such information is reasonably apparent to you by virtue f its nature or the context in which it is being collected.
3. We obtain your consent to collect, use or disclose your personal information
Apollon Investments Ltd obtains your consent to collect, use or disclose personal information. The method of obtaining consent will be appropriate to the type of personal information being collected, used or disclosed.
Apollon Investments Ltd will obtain your express consent (verbal, written or electronic agreement) to collect, use or disclose sensitive personal information such as medical data or personal financial information.
Apollon Investments Ltd will rely on implied consent to collect, use or disclose your personal information where the intended use of the information is reasonably obvious from the context in which it is obtained and you provide the information voluntarily.
In some circumstances where permitted by Privacy Laws, we will collect, use and disclose your personal information without your consent, including situations of urgency when it is impractical to obtain your consent, when Apollon Investments Ltd or its affiliates need to collect monies or in connection with an investigation or proceeding by Responsible Finance Corporation or a law enforcement agency.
You can change your consent to any collection, use or disclosure of your personal information at any time on reasonable written notice, subject to permitted or required exceptions under Privacy Laws (e.g. where withdrawal of consent would frustrate a legal obligation such as collecting on a loan). In many situations, withdrawal of consent may also deprive you of a benefit or service. To change your consent to collection, use or disclosure of personal information about you, refer to the “How to Contact Us” section below.
4. We limit collection of your personal information
Apollon Investments Ltd collects personal information required to provide our products and services, including collections. We will collect personal information only by reasonable and lawful means. Examples of why we collect personal information include:
- Communicating with you about your deposits
- Accepting deposits
- Processing and keeping track of transactions and reporting back to you
- Protecting against theft, fraud and error
- Analysis of information to determine that relevant services are offered to those who may need them
- Providing products and services requested by you
- Advising you of products and services that Apollon Investments Ltd believes will be of interest to you and provide value to you, assuming you
- have consented to such uses
- To monitor security
- To comply with legal and governmental requirements
5. We limit use, disclosure and retention of your personal information
Apollon Investments Ltd uses and discloses your personal information only for the purposes for which it was collected unless permitted by Privacy Laws. Apollon Investments Ltd does not sell or rent personal information to any organization or person for any reason.
We may have third party organizations collect personal information on our behalf, or we may disclose personal information to third party organizations to assist in providing customers with services or to obtain services to assist us in our business. If your personal information is collected by or shared with third parties, Apollon Investments Ltd will require them to comply with this policy when dealing with your personal information.
Apollon Investments Ltd regularly receives and sends customer personal information from and to its deposit-taking agents as well as third party organizations who provide services to Apollon Investments Ltd in support of Apollon Investments Ltd prepaid card program (who may in turn share such personal information with its sub-contractors) as part of carrying on its business and to ensure proper service and accounting procedures are followed.
In order to maintain our high service level and relevant offerings, Apollon Investments Ltd or a third party organization acting on our behalf, may use customer personal information to advise you of promotions, offers or new services (where you have opted-in to such communication) and to send you surveys about or related to our services and/or product offerings. Rest assured that the information collected through our surveys will be aggregated and not linked to your personal information.
Apollon Investments Ltd retains your personal information only as long as it is required for our business relationship or as required by applicable laws.
Please note that the third party organizations outlined in this section may collect, transfer, process and store your personal information in the United States. The data protection laws in the United States and Europe differ from those in Canada. By providing us with your personal information, you consent to the collection, transfer and processing of your personal information to and from both Europe, the United States and Canada and agree that your personal information may be subject to access requests from governments, courts or law enforcement in the United States per the laws of the United States.
6. We strive to keep your personal information current and accurate
Apollon Investments Ltd endeavours to keep your personal information up to date, accurate and relevant for its intended use. You can assist us by updating your personal information (e.g. change of address) with us (see the How to contact us section below for details).
7. The security of your personal information is a priority for Apollon Investments Ltd
We take steps to safeguard your personal information, regardless of the format in which it is held, including:
- Physical security measures such as restricted access facilities and locked filing cabinets
- Shredding of documents containing personal information
- Electronic security measures for computerized personal information such as password protection, database encryption and personal identification numbers
- Organizational processes such as limiting access to your personal information to a selected group of individuals
- Requiring third parties given access to your personal information to protect and secure your personal information
8. We provide access to your personal information kept by Apollon Investments Ltd
You can request access to your personal information kept by Apollon Investments Ltd. Customers who wish to contact us should refer to the “How to contact us” section below. You may request any of the following:
- What types of personal information we have on record or in our control, how it is used and to whom it may have been disclosed
Reasonable access to your personal information so you can review and verify its accuracy and completeness and request changes to the information. Apollon Investments Ltd reserves the right to decline to make a requested correction but will append a notation to the record of your requested alternative information
Updates to your personal information subject to applicable exceptions under Privacy Laws, such as where:
- Your request would divulge confidential competitive business information of Apollon Investments Ltd
- The information is not readily retrievable and the burden or cost of providing access is disproportionate to the nature of the request
- Access could interfere with or prejudice an investigation or proceeding by Apollon Investments Ltd or law enforcement agencies
9. How you can protect your personal information
In addition to the steps we take to safeguard your personal information, we believe there are measures you should take to protect yourself as well.
We advise you to not share any personal or financial information with others unless you clearly understand the purpose of them requesting the information and that you have confirmed you are dealing with a legitimate contact. We also recommend that you not share any significant personal or financial information via email or Voicemail.
10. How to contact us
If you are uncomfortable about any information or requests you receive from Apollon Investments Ltd via phone, fax or email, please contact us immediately at (206) 801-0300 to confirm the information or request is legitimate or to discuss the concern with our Privacy Officer.
By e-mailing : firstname.lastname@example.org
By mail to:
Apollon Investments Ltd
225 West 8th Ave, Suite 300
Vancouver BC, V5Y 1N3
If your questions, concerns and complaints have not been resolved to your satisfaction, you may also complain to the Privacy Commissioner within your jurisdiction, where applicable.