Last revised April 2009

In this Agreement, “we”, “our” and “us” mean, as applicable, any First Class Financial Services Inc. Member; “you” and “your” mean an individual who has made application to us for any personal or commercial credit service offered by us (“Service”), including any co-applicants, guarantors or personal representatives.

Collecting, Using and Disclosing Your Information

1. When you apply for, or provide a guarantee in respect of, or use any Service and while you are our customer, you agree that:

   We may collect personal information from you and about you such as:

   • Your name, address, occupation and date of birth, which is required by law;
   • Identification, such as a valid Canadian driver’s license or passport or birth certificate issued in Canada. We may also ask for documents such as a recent utility bill to verify your name and address;
   • Your annual income, assets and liabilities and credit history;
   • Information about your transactions, including payment history and account activity;
   • Other information we may need in order to provide you with a Service such as health information if you are applying for certain insurance products.

   We may collect from, and use and disclose this personal information to, any person or organization for the following purposes:

   • To confirm your identity;
   • To understand your needs;
   • To determine the suitability of our Services for you;
   • To determine your eligibility for our Services;
   • To set up, manage and offer Services that meet your needs;
   • To provide you with ongoing Service;
   • To meet our legal and regulatory requirements;
   • To investigate and adjudicate insurance claims; and
   • To detect and prevent fraud or other criminal activity.

   We will use health information strictly for the provision of an insurance Service.

   We do not provide directly all the services related to your relationship with us. We may use third party service providers to assist us with various services such as printing, mail distribution and marketing and you acknowledge that we may release information about you to them. When personal information is provided to our service providers, we will require them to protect the information in a manner that is consistent with First Class Financial Services Inc. privacy policies and practices.

2. We may collect, use and disclose your Social Insurance Number (SIN) for income tax reporting purposes, as required by law. In addition, we may ask you for your SIN to verify and report credit information to credit bureaus and credit reporting agencies as well as to confirm your identity. This allows us to keep your personal information separate from that of other customers, particularly those with similar names, and helps maintain the integrity and accuracy of your personal information. You may refuse to consent to its use or disclosure for purposes other than as required by law.
3. We may verify relevant information you give us with your employer or your references and you authorize any person whom we contact in this regard to provide such information to us. If you apply for a Service and during the time you have the Service, we may consult various financial service industry databases or private Investigative Bodies maintained in relation to the type of Service you have applied for or have. You also authorize us to release information about you to these databases and Investigative Bodies. Investigative Bodies are designated under the regulations of the Personal Information Protection and Electronic Documents Act (PIPEDA) and include such organizations as the Bank Crime Prevention and Investigation Office of the Canadian Bankers Association and the Investigative Services Division of the Insurance Bureau of Canada.
4. We may monitor or record any telephone call we have with you. The content of the call may also be retained. We may inform you prior to proceeding with the call of this possibility. This is to establish a record of the information you provide, to ensure that your instructions are followed properly and to ensure customer service levels are maintained.
5. If you have a Service with us, we may use, disclose to and collect from credit bureaus or financial service industry databases, credit and other information about you in order to offer you pre-approved credit products. We may also do this after the Service has ended. You may withdraw your consent at any time by giving us reasonable notice (see below).
6. We may give information (except health information) about you to other financial service providers (where the law allows this) so that these companies may tell you directly about their products and services. The First Class Financial Services Inc. includes companies engaged in the following services to the public: loans and other personal financial services; mortgage loans; insurance services; extended warranties. This consent will apply to any companies that form a relationship with First Class Financial Services Inc. in the future. You also agree that we may provide you with information from third parties we select. Your consent to this is not a condition of doing business with us and you may withdraw it at any time (see below).
7. If we sell the company or a portion of the business of First Class Financial Services Inc., we may release the information we hold about you to the prospective purchaser.
8. We may keep and use information about you in our records for as long as it is needed for the purposes described in this Agreement, even if you cease to be a customer.
9. All information that you give us will, at any time, be true and complete. If any personal information changes or becomes inaccurate or out of date, you are required to advise us so we can update our records.