At Habib Canadian Bank (HCB), we have always made it a priority to protect your personal information. HCB is committed to keeping customers’ information accurate, confidential, secure and private. HCB’s relationship with its customers is built on this commitment.

1. Accountability

 

We value the trust you have placed in us by choosing HCB as your financial services provider. HCB has appointed a Chief Privacy Officer to oversee HCB’s privacy practices and this privacy policy. We also encourage you to read this privacy policy so that you can understand how we collect, use, share and protect your personal information and how you can manage your information in a way that best suits you. To help you understand our privacy policy, here are some important terms you should know:

“Personal information” or “Information” means information about an identifiable individual such as contact information, account numbers, or details such as age, marital status, and financial information. This information can be in any form including paper, electronic, video or voice recording. “HCB”, “we”, “our”, “us” or the “Bank” means collectively Habib Canadian Bank and “you” and “your” refer to an individual who has completed an application for opening an account with HCB, or for any banking product or service offered by us, or has provided a guarantee for any banking product or service offered by us.

“HBZ” or “Group” means Habib Bank AG Zurich, its branches and subsidiaries, including Habib Canadian Bank.

1.1 Who is Responsible for Data Processing and How Can I Contact Them?

 

The legal entity responsible for processing your personal data is:

Habib Canadian Bank
6450 Kitimat Rd Mississauga,
ON L5N 2B8

Our Privacy Officer can be reached at:

Phone: +1 (905) 276 5400

Email: concerns@habibcanadian.com

2. What Information Do We Collect?

 

When you apply for, use, or guarantee any service, HCB collects personal information as required by applicable laws and regulations, or as necessary for the products and services you request.

The information we collect may include:

• Name, address, occupation, and date of birth
• Social Insurance Number (SIN) for income tax reporting purposes, and other identification such as a valid driver’s license or passport
• Recent utility bills to confirm your name, address, and contact details
• Annual income, assets, liabilities, credit history, transactions, and account activity
• Specimen signatures
• Public records, credit bureaus, references, or other third parties such as employers, government agencies, and financial institutions

We may monitor or record communications (e.g., phone calls) to enhance service quality, confirm discussions, or for security purposes. Surveillance, including videotaping, is also used in and around branches and ATMs to ensure the safety of clients, employees, and assets.

3. How Do We Use Your Information?

 

HCB collects and processes personal information for the following purposes:

• To establish and verify your identity
• To assess your needs and the suitability of products or services
• To manage and deliver products and services
• To meet legal and regulatory requirements (e.g., tax reporting, anti-money laundering, and Know Your Client obligations)
• To investigate and process insurance claims
• To understand and anticipate your needs for better service delivery
• To maintain the integrity of information shared with credit reporting agencies

We collect information from a variety of sources, but much of it comes from you (e.g., applications for or use of our products or services, and communications with us). Because it is important that we keep your trust, we will only ask for the information we need. When we ask for information, we will let you know why we need it. To the best of our ability, we will seek your prior consent to verify and supplement the information with external sources, such as credit or other bureaus or employers.

We may monitor or record communications between you and our representatives (e.g., telephone calls) in order to enhance and maintain client service quality, to protect you and HCB, to confirm our discussions with you, or for training purposes. We use surveillance, including videotaping, in and around our branches, ATMs, and other locations for the safety of our clients, employees and others, to protect against illegal activity, such as theft, vandalism and fraud, or to enhance and maintain client service quality.

4. Purpose and Legal Basis of Using Your Information

 

4.1 For the Fulfillment of Contractual Obligations

 

The processing of your data allows Habib Canadian Bank to provide you with the contractually agreed services, or to carry out pre-contractual measures that occur as part of a request from an interested party. The purposes of data processing are primarily in compliance with specific banking products (e.g. accounts, loans, securities, deposits, brokerage services). Your data will be used, among other purposes, for the analysis of any potential needs, the provision of advice, wealth management, and to support the execution of transactions.

Further details can be found in your contract documents or in the website Terms & Conditions.

4.2 For the Safeguarding of Habib Canadian Bank’s and Third-Party Interests Where Required

 

We process your data beyond the actual fulfillment of the contract for the purposes of the legitimate interests pursued by us, or a third-party to:

• Consult with credit rating agencies to investigate creditworthiness and credit risks
• Review and optimizing procedures for needs assessment for the purpose of direct client discussions
• Obtain personal data from publicly available sources for client acquisition purposes
• Test and optimization of processes for requirement analysis or client contact
• Measure for business management and further development of services and products
• Manage risk control at Habib Canadian Bank and Habib Bank Group
• Assert legal claims and a defense in legal disputes
• Guarantee of Habib Bank Group’s IT security and IT operations
• Prevent and investigation of crimes
• Video surveillance and measures to protect the rights of an owner of premises to keep out trespassers and to provide security (e.g. access controls)

5. Sharing Your Information

 

Under certain circumstances, your personal information may be shared among the Group or with other third-parties. Sharing your personal and financial information within the Group, enables us to build and maintain a positive relationship with you. We may use this information to better understand your financial needs and to promote products and services we believe may interest you. Sharing your personal information with such third-parties will enable us to provide you with certain services.

5.1 Joint Accounts Or Representatives

 

Where you hold a product or service jointly with another person (joint accounts) or where someone is authorized to use or access your product or service, or where liability is shared with others (e.g., someone has provided a guarantee or indemnity for your obligations), we may share your information with them (or their representative) in connection with the product or service. Where someone is acting as a representative or we reasonably believe is acting with proper authorization (e.g., legal guardian, a person having power of attorney, estate representative, a lawyer, an accountant, and, for minor children, a parent or guardian) we may share information with and take instructions from them.

5.2 Our Employees

 

Access to your information is restricted to authorized employees who have a legitimate business purpose for accessing it. For example, when you call us, visit a branch, or email us, designated employees will access your information to verify that you are the account-holder and to assist you in fulfilling your financial requests. Unauthorized access to and/or disclosure of client information by an employee at HCB is strictly prohibited. All employees are required to always maintain the confidentiality of client information at all times and failing to do so results in appropriate disciplinary measures, which may include dismissal.

5.3 Outside Service Suppliers

 

We may use service providers to perform specialized services on our behalf, such as cheque-printing, research, marketing, mail distribution, or data processing. These service providers may process or handle personal information.

They are provided only the information necessary to perform the services. Where service providers might have access to your information, we select them carefully and require them to meet HCB’s privacy and security standards through contractual agreements. If our service provider is located in a foreign jurisdiction, they are bound by the laws of the jurisdiction where they operate, which may include disclosing personal information according to those laws.

5.4 Other Third-Parties

 

We are committed to keeping your personal information confidential. We will only share your information with other third-parties as indicated under your account agreement and under the following special circumstances to:

• Help prevent fraud
• Ensure it is permitted or required by law, to comply with laws, regulations, subpoena or court order
• Respond to valid and authorized information requests from domestic and international authorities
• Protect the personal safety of employees, clients or other third-parties

6. Protection

 

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include strong access controls, encryption of data in transit etc.

Where you might be a victim of fraud, financial abuse, other illegal activity or where we have reasonable grounds to believe your interests can best be served by taking action, we may share information with the appropriate legal or governmental authorities, your next of kin or any other appropriate person (e.g., notification of our concerns regarding potential financial abuse may be provided to a public guardian or trustee’s office). In these circumstances, we will only share information we believe is reasonably necessary to protect your interests.

We may also share information to protect our rights or interests. For example, where we are involved in judicial, administrative or regulatory proceedings, or other similar processes including enforcing our rights (e.g., to collect on a debt). Or, in order to comply with any legal and regulatory obligations including any subpoena, warrant, or any judicial, administrative orders or demands.

7. Your Rights

 

7.1 Keeping your information accurate

 

We take care to keep information in our records as accurate, complete and up to date as necessary for the purposes for which it is used. However, we also rely on you to tell us when your information changes. If any personal information changes or becomes inaccurate or out of date, you are required to inform us so we can update our records. Keeping your information accurate and up-to-date allows us to continue to offer you the highest quality service. If we do not agree to change your personal information, you may challenge our decision. Customers may, in writing, challenge the accuracy and completeness of their personal information and request that it be amended as appropriate.

7.2 Your Right To Access Your Personal Information

 

You are entitled to receive periodic access to information in the form of transaction activity records, including account statements and trade confirmations. This information is routinely available to you through mailings, secure online websites and telephone banking. If you want to verify the accuracy of other personal information we hold about you, you may visit or submit a written request to your branch or office where you do business. Basic personal information such as your name, address, age, account numbers etc. can be verified on the spot, at no charge.

If you wish to review more extensive information, such as payment or investment records or credit history, you will be asked to provide details regarding the nature and possible location (branch, office, account etc.) of the information you wish to check. The information will be obtained from the records to which you have directed your request and will normally be provided within 30 days of your request. There may be a charge for retrieving this information, in which case you will be notified in advance, and if you like, you may withdraw your request. You may also challenge the reasonableness of the charge. If you have a sensory disability, on request, we will give you access to your personal information in an alternative format if available. If it is necessary and if we can reasonably do so, we will convert the information into an alternative format.

Please note that there may be instances where access may be restricted as permitted or required by law. Examples may include information that is subject to legal privilege, information containing confidential commercial information and information relating to a third-party. If applicable, we will advise you of the reasons for restricting access subject to any legal or regulatory limitations.

7.3 Your Consent And Your Choices

 

Subject to applicable law, from time to time the HCB may offer you products or services, including special promotions, which may be of interest to you. This consent is optional and you can decide to withdraw it at any time. However, this will not limit the information provided to you through discussions with a HCB representative or through general HCB marketing or servicing channels (e.g., posters in branches and electronic messages on our website), or information we send you that is related to your existing products and services or is permitted or required by law.

Subject to legal, business or contractual requirements, you can withdraw your consent to our collection, use or sharing of information at any time upon giving us reasonable notice. However, withdrawing your consent may limit or prevent us from providing you with, or being able to continue to provide you with, specific products or services. For example, if you choose not to provide us with your SIN, we will not be able to provide you with any product where the collection of SIN is required under applicable law (e.g., a registered product like an RRSP).

In certain circumstances your consent cannot be withdrawn. For example, you may not withdraw your consent where our collection, use or sharing is permitted or required by law, is required to ensure we have correct and up to date information about you (e.g., current address), or is necessary to manage our business including the sharing of information when we assign our rights to others for business transactions.

During the term of the loan or credit facility, you may not withdraw your consent to our ongoing collection, use or disclosure of your personal information in connection with the loan or other credit arrangement you have with us or have guaranteed. In order to maintain the integrity of the credit reporting system, we may periodically update your information with credit bureaus as long as you have a credit product, or service with us, and for a reasonable period of time afterwards. Your consent to the exchange of information cannot be withdrawn during this time.

8. International Data Transfers

 

Data transfer to legal entities in countries outside of Canada takes place so long as:

• It is necessary for the purpose of carrying out your orders (e.g. payment and securities orders)
• It is required by law (e.g. reporting obligations under financial regulation), or
• If you have given your consent

These data transfers are secured through corresponding guarantees of the recipients to ensure an appropriate level of data protection.

8.1 Data Retention

 

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. Addressing Any Privacy Concerns

 

If you have any complaints, questions or concerns about this privacy policy or our privacy practices, please let us know right away. If you choose to send us an e-mail, do not include sensitive information (e.g., card or account numbers).

The following process applies to HCB banking clients:

Step 1: Talk To Us

 

In most cases, a complaint, question or concern is resolved simply by talking to us about it. You should be able to get swift results by talking to an HCB representative where you do business. You can speak with us in-branch or by calling toll free: +1 855 82 HABIB (+1 855 82 42242).

Step 2: Call The HCB Office

 

If your complaint, question or concern is not resolved to your satisfaction, you may contact:

The Chief Privacy Officer
Habib Canadian Bank

Phone: +1 (905)  276 5300

Fax: +1 905 276 5400

Toll free: +1 (855) 82 HABIB (+1 (855) 824 2242)

Write to: 6450 Kitimat Rd, Mississauga, ON L5N 2B8

Be sure to include your name and contact information where you prefer to be reached, the nature of your complaint, question or concern, details relevant to the matter and with whom you have already discussed the issue.

Step 3: The Office of the Privacy Commissioner (OPC)

 

If your complaint, question or concern has still not been resolved to your satisfaction, you should contact the Office of the Privacy Commissioner (OPC).

Office of the Privacy Commissioner of Canada (OPC)
30 Victoria Street 
Gatineau, Quebec K1A 1H3

Phone (Toll-free): +1 (800) 282 1376

Phone: +1 (819) 994 5444

TTY: 819-994-6591

 

9. Updates to this Privacy Notice

 

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, in accordance with the significance of the changes we make.

This Privacy Notice was last updated in December 2023