Privacy Policy

What Personal Information do we collect?

We collect and use several types of information from and about you to better provide products and services to you. Depending on the product or service you have with us, this may include: 

• Personal Information (such as your name, address, contact information, date of birth, occupation and any other type of identification including your driver’s license);
• Financial and bank information including your credit score and information about your assets,  liabilities, income and expenses; 
• Tax information (including Social Insurance Number (SIN)); 
• Employment information; and  
• Information about your transactions with us and our interactions with you (including call recordings). 

We also collect technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our website, and usage details as well as non-personal details about your online interactions, including the Uniform Resource Locators (URLs), clickstream to, through and from our website (including date and time), products you viewed or searched, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, email response and interactions, and any phone number used to call our customer service number.

Collection of Social Insurance Number (SIN) for Identity Verification (optional) 

Depending on the product or service you have with us, we may also request (with your consent) your SIN to verify your identity through an established credit reporting agency. This will apply for all accounts, with the exception of registered accounts (i.e., RSP, RESP), which do not require the use of a SIN for identity verification. However, if we do request that you provide us with your SIN for a reason other than for income tax reporting purposes, providing us with your SIN is optional and you can refuse our request for this information.

Biometric Information

While we do not collect, use, access, disclose, or retain any biometric data, our apps may be supported by third parties such as Apple. Through the use of third party technology, users may enable technology which use biometrics for authentication. When such technology is enabled, we will be notified if the authentication is successful but will not have access to any of the data associated with the authentication.

The Personal Information we have about you may be collected directly from you (or anyone authorized by you to act on your behalf under a power of attorney or other legal authority), and from sources within or outside of our organization (depending on the product or service you have with us) including from:

• our interactions with you (including telephone and video calls); 
• your mortgage broker, real estate agent or broker, or insurance broker (where applicable); 
• government bodies, agencies, and registries; 
• regulatory bodies;
• law enforcement authorities;
• public records;
• professional advisors such as accountants or lawyers; 
• third party service providers (including financial data aggregators); 
• other financial or lending institutions;
• credit reporting agencies including Equifax Canada Inc. and Trans Union of Canada, Inc.;
• our affiliates, partners, and related entities; and 
• organizations with whom you have arrangements or any other source we deem appropriate.

Call Recordings

We may record telephone or video calls made or received by our agents and employees for quality assurance and security purposes. If you do not want your call to be recorded, please notify the agent on the call. We keep recordings of calls only for as long as permitted by law.

The Personal Information collected is used to ensure we can provide products and services to you and fulfill our obligations to you.

Other reasons why we collect your Personal Information include to: 

• verify your identity and determine your eligibility for products, services or coverage for which you are applying for;
• administer your account and product and services you may have with us (including the administration of claims); 
• contact and communicate with you (including responding to any inquiries you may make);
• evaluate and process your application, accounts, transactions, and reports;
• provide you with ongoing service and information related to the products, accounts and services you hold with us;
• analyze your needs to help us serve you better and personalize your experience with us and our affiliates; 
• help understand your needs in the development of new products and services by us or our affiliates;
• for marketing purposes including disclosing other products and services that may be of interest to you (including those of affiliates and select third parties), to determine your eligibility and for you to participate in any contest, survey, or promotion, or to contact you by telephone, fax, text message, or other electronic means; 
• help protect you and us against fraud and error. This includes for purposes of preventing, detecting, or suppressing financial abuse, fraud, criminal activity and to protect our assets and interests. It may include any investigation (internal or external) into potentially illegal or suspicious activity, or to manage, defend or settle any potential or actual loss in connection with the activity. We may not only collect your Personal Information for such purposes, but also use and disclose the information to any person or organization,fraud prevention agency, regulatory or government body, operator of any database or registry used to check information provided against existing information, or other financial/lending institutions;  
• help manage and assess our risks, operations and relationship with you;
• help us collect a debt or enforce an obligation owed by you; 
• comply with applicable laws and requirements of regulators, including self-regulatory organizations; 
• help us manage our risks including risk of default; 
• help us assess your eligibility to renew your current products and services with us or our affiliates; and 
• help us assess your eligibility for other products and services offered by us or our affiliates. 

For credit/mortgage products

For any credit products such as mortgages, lines of credit, overdraft protection, loans, or credit cards, we will exchange Personal Information and reports about you with credit reporting agencies (including creditor and default insurance providers) and other lenders at the time of the application and throughout your relationship with us to review and verify your creditworthiness, establish credit and hold limits, help us collect a debt or enforce an obligation owed to us by you, and/or manage and assess our risks. Once you have such a credit product with us and for a reasonable period of time afterwards, we may from time to time disclose your Personal Information to other lenders and credit reporting agencies requesting such information, which helps establish your credit history and supports the credit granting and processing functions in general. We may obtain Information and reports about you from a credit reporting agency such as Equifax Canada Inc. and Trans Union of Canada, Inc.

Using Your SIN for non-tax purposes

With your consent, and where SIN has been collected, we may also use your Social Insurance Number (SIN) as a unique identifier, in situation(s) where it is necessary to keep your personal information separate from that of other customers or individuals with similar names, for internal matching of your personal records against records received from authorized third parties, and to help maintain the accuracy of your personal information. You can withdraw your consent for the non-tax use of SIN at anytime by contacting privacy@communitytrust.com and putting “Withdraw Non-Tax Use of SIN” in the subject line or in the body of the message. 

Personal Information will not be used, disclosed, or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In order to provide you with the best products and services, we may need to share your Personal Information with other parties who are under an obligation to protect the confidentiality of that information. The shared information will be limited to such information which is necessary to facilitate the arrangement.

Your Personal Information may be disclosed:

• in accordance with any applicable consent obtained from you;
• as part of a business transaction that we are considering or involved in (including the purchase of a business or the sale of part of all of our business); 
• to respond to a court order, search warrant, or any other valid demand or request 
• to satisfy any applicable legal or regulatory requirement (including to a self-regulatory organization of which we are a member of);  
• to suppliers, service providers, agents or other organizations that perform services for you, for us or on our behalf;
• to your mortgage broker, real estate agent or broker,  or creditor/default insurance provider; 
• to our investors for purposes of credit risk management and to meet our contractual obligations to them; 
• to any authorized individual with legal authority including Power of Attorney;  
• for study or research purposes, or for the production of statistics;
• to help us collect a debt or enforce an obligation owed to us by you; and
• where otherwise permitted by law.

Disclosures Between Provinces and Outside of Canada

Note that the suppliers, service providers, and other organizations we may use could be located outside of your province of residence and Canada and as such, your Personal Information may be collected, accessed, used, disclosed, and stored outside of your province and outside of Canada. In such cases, your Personal Information may be accessible or disclosed to or accessed by law enforcement, regulators, or authorities in the jurisdiction(s) where the Personal Information is being accessed, used, disclosed or stored.  

Disclosures to Affiliates (Questrade Group of Companies)

We may also share your Personal Information internally, including with affiliates, for the following purposes:

• to manage your relationship with us and our affiliates;
• to better understand the products and services you have with us or our affiliates; 
• to provide you with improved customer experience including maintaining consistent information about you;
• to manage and assess our risks; and
• to comply with all applicable legal and regulatory requirements for us and our affiliates.  

Certain regulators may require access to Personal Information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by regulated persons.  

Disclosing Your SIN

Your SIN may be shared with third parties for income tax reporting purposes, as required by law. In addition, depending on the product or service you have with us, we may be required by law to verify the identity of all clients, account beneficiaries, and trading authorization holders. 

Accessing and Correcting your Personal Information 

Depending on the product or service you have with us, you may be able to access your Personal Information online directly through your Questrade Group of Companies account. In addition, upon written request, we will provide you with details regarding your Personal Information including what information we have about you, and how it has been used and disclosed. Subject to certain exceptions permitted by law, we will provide you with access to the information.

You have the right to request the correction of your Personal Information. It is your sole responsibility to ensure that your Personal Information is accurate and up to date. If you identify any inaccuracy in your Personal Information, or you need to make a change to that information, please contact us immediately so that we may promptly update our records.

If you wish to access, correct, or withdraw consent to the use of your Personal Information you can:

• Log on to your Questrade Group of Companies account (where available); 
• Call 1 (800) 268-1576; 
• Email privacy@communitytrust.com; or 
• Mail

Community Trust Company
2350 Matheson Boulevard East
Mississauga, Ontario, L4W 5G9
Canada

Consent to Communications with Community Trust

By providing Community Trust with your contact information (email, phone number, address), you are consenting to the Questrade Group of Companies collecting, using, accessing, disclosing and storing your Personal Information for communication purposes including responding to any inquiries you make, helping Community Trust better understand your needs, and advising you of other products and services that may be of interest to you (including those of select third parties and affiliates).

Please note that while Community Trust clients may withdraw consent from obtaining promotional communications, this withdrawal will not apply to all communications. There are certain communications that all Community Trust clients must receive (such as those regarding account-related information). Non Community Trust clients may withdraw consent from all communications at any time. 

Opting out of Commercial Electronic Messages

If you consent to and receive commercial electronic messages from Community Trust and you no longer wish to receive them, you can click on the “unsubscribe” link at the bottom of the message and follow the prompts on your screen.  You can also contact unsubscribe@communitytrust.com. 

Some emails may not include a ‘unsubscribe’ link because the email contains account-related information that all clients must receive:

• If you receive an email in error after you have unsubscribed, please forward it to unsubscribe@communitytrust.com and your request will be processed immediately.
• You can change, update and opt-out of mobile alerts (for example, order, custom or smart alerts), through the User Preference pages in IQ Edge or IQ Web Trading (where applicable; depending on the product/service you have with us).

Note: a non-Community Trust client can withdraw consent from all communications at any time. Community Trust clients cannot unsubscribe from receiving communications that we are obligated to provide such as account-related information. All clients can unsubscribe from promotional communications at any time.

Our website contains links to other sites that we do not own or operate. Community Trust is not responsible for the privacy policy and privacy practices of any other websites.

If you store your financial or authentication information (such as investment account numbers and login information) with online or web-enabled personal finance sites or data aggregators, your security may be at a greater risk.

Updates to Our Privacy Policy

We will post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email using the email address specified in your account or place information banners on our website. We will include the date the Privacy Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our website and this Privacy Policy specifically to check for any changes.

Contact Us

If you have any questions or concerns about this policy or privacy and confidentiality matters, please contact our Chief Privacy Officer at:

Community Trust Company
2350 Matheson Boulevard East
Mississauga, Ontario, L4W 5G9
Canada
Toll free: 1 (800) 268-1576
Email: privacy@communitytrust.com
Attention: Rebecca Ma, Chief Privacy Officer and Executive Counsel

Contact the Office of the Privacy Commissioner of Canada

If, after contacting Questrade, you feel your Personal Information concerns have not been adequately addressed, you may contact the Office of the Privacy Commissioner of Canada at:

30 Victoria Street
Gatineau, Quebec  K1A 1H3
Toll-free: 1 (800) 282-1376
Phone: 1 (819) 994-5444
TTY: 1 (819) 994-6591
Online: https://www.priv.gc.ca/en/report-a-concern/