Your Privacy Is Important to Us
Manawa Inc. (Manawa) and its family of companies including Manawa Networks, Manawa Procurement, Manawa Development, and Manawa Hosting. Manawa also includes any successors or subsidiaries of the above-listed companies are committed to protecting the privacy and security of your personal information obtained by reason of your doing business with us.
Our Privacy Charter explains the types of customer personal information we collect, how it is used and the steps we take to ensure your personal information is handled appropriately.
Each member of the Manawa family of companies collects information necessary to do business with you. For more specific details on what information each company may collect and how we use it, we refer you to the Frequently Asked Questions (FAQs) section.
The Privacy Charter is our commitment to you. It is our organization wide policy on how all companies in the Manawa family protect your personal information.
Policy on Privacy of Customer Personal Information
Manawa is committed to protecting the privacy and security of your personal information obtained by reason of your customer relationship with Manawa. The Manawa Privacy Charter (“Privacy Charter”) explains the types of customer personal information we collect, how it is used, and the steps we take to ensure your personal information is handled appropriately.
Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and corresponding provincial privacy acts. Our Privacy Charter may be amended from time to time. A copy of the most current version of our Privacy Charter may be obtained online at www.manawa.net under Privacy and Security or you can request a copy from us (See Contact Information, below). We encourage you to review the current Privacy Charter from time to time. A list of frequently asked privacy questions (FAQ) is also available to provide you with examples and instances of how your personal information may be collected, used and disclosed.
Who is Manawa?
For purposes of this Privacy Charter, “Manawa” means Manawa Inc. and its family of companies including Manawa Networks, Manawa Procurement, Manawa Development, and Manawa Hosting. Manawa also includes any successors or subsidiaries of the above-listed companies.
What is personal information?
Personal information is information about an identifiable individual. Personal information includes such things as your name, address, age, income, date of birth, gender, financial information and credit records, as well as your opinions, preferences and purchase patterns.
1. We are accountable to you
Manawa is responsible for all personal information under its control, including any personal information that is transferred to third parties for processing, storage or other purposes. To achieve this objective, Manawa has developed and implemented this Privacy Charter.
2. Why we collect your personal information
Manawa identifies the purpose for which your personal information is collected. We do this before or at the time the information is actually being collected. We collect, use and disclose your personal information in order to:
- process your application for a product or provide a service;
- better understand your product and services needs and to offer relevant information, products, services and rewards to meet those needs;
- determine your interest and eligibility for, and where appropriate provide you with, products, services and loyalty rewards;
- administer the delivery of products, services and loyalty rewards to you;
- track and analyze your purchases, other transactions, shopping patterns, account activity, and payment history for marketing analysis purposes or making promotional offers to you;
- conduct surveys and analysis for research, statistical and product development purposes (information will be anonymized to the extent possible);
- verify your identity and protect against error and fraud;
- assess and update your credit-worthiness on an ongoing basis;
- process, service, analyze and audit your relationship with us, including collecting any money you owe us;
- support promotions and contest administration;
- perform tests to implement or modify systems;
- comply with legal and regulatory requirements; and
- achieve other purposes as may, from time to time, be permitted by law.
By providing your information to Manawa, you consent to Manawa using your personal information for the purposes outlined above.
3. We obtain your consent to collect, use or disclose your personal information
Manawa obtains your consent to collect, use or disclose your personal information, except as permitted by law. The method of obtaining consent depends on the circumstances and the sensitivity of the information. Consent may be oral or written, express or implied. Your express consent (verbal, written or electronic agreement) is obtained to collect, use or disclose sensitive personal information. Implied consent is obtained in circumstances where a customer relationship already exists, express consent has previously been given, or the purpose of using the personal information is reasonably apparent to you.
You can change your consent preferences at any time by contacting Manawa’s Customer Relationship Contact Centre (see Contact Information, below).
Benefits you receive through consent
Manawa is a growing network of interrelated businesses offering a unique mix of products and services. We want to give you exceptional customer service and additional value which is facilitated by sharing your information within Manawa and across our various businesses. This sharing enables us to notify current and new customers of products, services, rewards and special offers they might enjoy. We may also provide your personal information to other companies designated by Manawa so that they can notify you directly of products, services, rewards and special offers that may be of interest to you. These notices may be given to you by postal mail, e-mail, facsimile, telephone, text message, automatic dialing-announcing device or other form of telecommunication using the contact information that you provide to us.
“Opting-out” or withdrawing your consent
If you decide that you do not want to receive marketing offers for products and services, you may always withdraw or refuse your consent at any time by calling us toll-free at 1-866-996-2629. Your request will be promptly processed but may not be in time to remove you from promotions already in progress. Please note that even if you have opted out of receiving marketing communications, we may still contact you for purposes of administering your account.
If you decide to withdraw or refuse your consent, our ability to communicate with you will be diminished. For example, we will generally not be able to tell you about price discounts, rewards, customized balance transfer offers, contests, or other products and services that may be of value to you.
4. We limit collection of your personal information
Manawa collects only the information required to provide products and services to you. If the personal information we require is collected for a reason other than as outlined in this Privacy Charter, your consent will be obtained before or at the time the information is collected. Manawa will collect personal information only by clear, fair and lawful means.
5. We limit use, disclosure and retention of your personal information
Manawa uses and discloses your personal information only for the purposes for which it was collected, except with your consent or as required by law.
We assure you that we do not sell or rent personal information. We only provide your personal information within Manawa and across our various businesses, with current or future Partners, and with third party service providers for the administration of certain promotional activities, and to ensure your needs are.
We may transfer your personal information to entities outside Manawa, such as our vendors, suppliers and agents who assist us in serving you (“Service Provider”). When your personal information is transferred to a Service Provider, we require them to protect the information in a manner that is consistent with this Privacy Charter. Our Service Providers may be located outside of Canada and may be required to disclose your personal information under the laws of their jurisdiction. You may contact us for information about our policies and practices regarding Service Providers to whom we have transferred your personal information and their locations (see Contact Information, below).
Manawa retains your personal information only as long as it is required for our business relationship or as required by law. In the unlikely event that Manawa, any of its affiliated companies, brands or substantially all of any of their assets are acquired by an unrelated third party, your personal information may be one of the transferred assets. By providing your personal information to us, you agree that we may disclose your personal information, on a confidential basis, to any prospective transferee and its professional advisors for the purposes of their due diligence investigations, the completion of any such transaction and the continued operation of the acquired business.
6. We keep your personal information accurate
We want to keep your personal information up to date, accurate and relevant for its intended use. We rely on you to let us know if your address, telephone number or other information changes, so that we may provide you with the best possible service.
7. How we protect your personal information
The security of your personal information is important to us. We will protect your personal information with appropriate safeguards and security measures. All of our Service Providers are required under their contracts with us to maintain your confidentiality and may not use your information for any unauthorized purpose. When we are required by law to provide information, we take reasonable steps to verify the lawful authority for the collection and we disclose only the information that is legally required. We review our procedures and security measures regularly to ensure that they are properly administered and remain effective and appropriate for the sensitivity of the information.
8. We are open about our privacy and security policy
We are committed to providing you with understandable and easily available information about our policies and practices related to management of your personal information.
9. You can access your personal information stored by us
You have the right to request access to your personal information we have on record in order to ensure it is accurate. If there are discrepancies, your information can be updated as appropriate. To access your personal information, a request must be submitted in writing to us (see Contact Information below). We will respond to your request for access or information in a reasonable time. There may be times when we are unable to fulfill your request – for example, if providing access to your personal information would reveal confidential commercial or proprietary information or personal information about someone else (and we are unable to separate your data), or if we are prohibited by law from disclosing the information.
10. We respond to your questions, concerns and complaints about privacy
Manawa responds in a reasonable time to your questions, concerns and complaints about the privacy of your personal information and our privacy policies and procedures. We will investigate and respond to any concern you have regarding the handling of your personal information. In most cases, an issue can be resolved simply by telling us about it and discussing any issues.
Our privacy statement provides a quick reference to the key privacy points of the Privacy Charter. It also provides you information on your choices and important contact information.
This statement highlights how Manawa and its family of companies collects, uses and discloses your personal information. Manawa means Manawa Inc. and its family of companies including Manawa Networks, Manawa Procurement, Manawa Development, and Manawa Hosting. Manawa also includes any successors or subsidiaries of the above-listed companies. Manawa is committed to protecting and caring for your personal information that we obtain through your customer relationship with us.
Personal Information Collected
Personal Information includes your name, address, email address, date of birth, income, financial information and credit records, as well as your opinions, preferences and purchase patterns.
We obtain information directly from you from your application for a product or purchase of a service. We also obtain information through your interactions with us, such as surveys, websites activities, call monitoring and contests.
We may obtain information with your consent from third parties, such as your credit history which is obtained from credit bureaus.
Your personal information is only used or disclosed for the purpose for which it was collected.
We assure you that we do not sell or rent personal information. We only transfer your personal information within Manawa and to current or future Partners in the Loyalty Program to ensure your needs are met.
We use your personal information in order to process your application for a product, service or loyalty program and administer delivery of products, services and loyalty rewards. We also use your information to better understand your product and service needs and to offer relevant information, products, services and rewards to meet those needs. Your purchases and other transactions, shopping patterns, account activity and payment history is tracked and analyzed for marketing purposes and for making promotional offers to you. For a full list of why we collect your personal information, see our Privacy Charter.
We may transfer your Personal Information to third party service providers who assist us in serving you, such as vendors, suppliers and agents; however, we require them to protect your information in a manner consistent with our Privacy Charter. Our service providers may be located outside of Canada and may be required to disclose personal information under the laws of their jurisdiction.
We may share information about you as permitted or required by law, for example with credit bureaus, regulators and law enforcement agencies.
You may access your personal information that we have on record in order to ensure it is accurate by submitting a written request to us. If you decide that you do not want your personal information used or shared for marketing products and services to you, you may opt out of receiving promotional offers and contests at any time by calling us toll-free at 1-866-846-5841.
How to Reach Us
- By calling our Customer Relationship Contact Centre at 1-866-996-2629
- By e-mail at firstname.lastname@example.org
- By mail at 301-801 York Mills Road, Toronto, ON M3B 1X7 – Re: Privacy Inquiries
If your questions, concerns and complaints have not been resolved to your satisfaction or if you have further questions, you can contact Manawa’s Chief Privacy Officer by mail at: Chief Privacy Officer c/o Manawa, 301-801 York Mills Road, Toronto, ON M3B 1X7 or by email at email@example.com
Our FAQs provide answers to important questions you may have regarding your information and your privacy. The FAQ provide additional detail on what information is collected by each company. The information may vary according to company. If there are further questions you would like answered, feel free to contact us anytime. Customers should access the Privacy Charter, Privacy Statement and Privacy FAQ from this page. They should appear in this order.
Manawa knows that our customers trust us with their personal information and we intend to continually earn that trust by treating your personal information with care. Manawa has a Privacy Charter which explains how we collect, use and disclose the personal information of our customers. The Privacy Charter and these frequently asked questions are available on our website, www.manawa.net under Privacy and Security or on request.
Who is Manawa?
Manawa is Manawa Inc. and its family of companies including Manawa Networks, Manawa Procurement, Manawa Development, and Manawa Hosting. Manawa also includes any successors or subsidiaries of the above-listed companies.
What is “personal information”?
Personal information means information about an identifiable individual. Personal information includes such things as name, address, age, income, date of birth, financial information and credit records, as well as your opinions, preferences and purchase patterns.
Why do we need your personal information?
We need your personal information in order to do business with you. Following are some examples of the personal information that our IT Services, Hosting, Development, and eCommerce Services businesses need and why.
Most of the information collected about you is very basic information that we need to complete a purchase, provide you with a refund or exchange or process and keep track of transactions and report back to you. Examples of information that may be collected to complete an in-person purchase or refund may include things such as your name, address, telephone number, and a description of the item requested or purchased.
Generally, we request your address and phone number only if the item you purchased will be sent to you at a later date, or if you are receiving a refund.
You may visit one of Manawa’s websites just to browse, or you may actually make an online purchase. If you make a purchase, we collect personal information such as your name, address, e-mail address, phone number, and credit card information. Website Terms and Conditions are available on each Manawa website.
Banks and financial institutions require certain information in order to open credit related accounts and deposit accounts. For example, name, address and date of birth are required to identify you and process your application; information about your background (for example, occupation) and financial circumstances like assets, income, other financial commitments, to determine if you are eligible for products and services; credit reports and other information to assess and update your credit worthiness; transactional and payment patterns to identify credit risk, fraud risk, and suspicious activities and to fulfill regulatory obligations such as anti-money laundering and anti-terrorist financing regulations.
Depending on the financial product, some information is required by law. For example, your name, address, date of birth, employment information and details of government issued documents like a passport are required under anti-money laundering and anti-terrorist financing regulations and your social insurance number (SIN) is required for reporting purposes under the Income Tax Act.
We may collect and use personal information in an aggregated form about our customers to improve our services, to study trends, for statistical analysis, to develop products and programs, for marketing purposes and/or for industry reporting purposes. Aggregated information does not identify any individual customer. We may share such aggregated information with members of the Manawa family of companies, our partners, our agents, service providers that we employ and advertisers.
When do we ask for your Social Insurance Number (SIN)?
When you apply for financial products we may ask for your SIN, however, providing your SIN is optional. Your SIN is used by credit bureaus/consumer reporting agencies to distinguish you from others with a similar name and your SIN provides us with more accurate credit bureau/consumer reporting agency information. If you apply for a credit related product or service and if you choose not to provide your SIN, the approval of your application and/or your credit limit may be affected. We do not treat you differently because you choose not to disclose your SIN for these other purposes. If you do provide it to us, it makes the exchange of information with credit bureaus/consumer reporting agencies more timely and accurate.
When do we need a credit bureau report?
If you are applying for a credit-related product or service, we need a credit bureau report on you to determine your credit-worthiness and the appropriateness of granting you credit and we will continue to obtain credit reports, from time to time, to update your credit-worthiness in order to administer the credit facility or loan. The credit/consumer reporting system relies on the accuracy and completeness of the information provided to credit bureaus/consumer reporting agencies. As such, during the term of a credit facility or loan, we need to collect, use, or share your personal information with the credit bureaus/consumer reporting agencies to support and maintain the integrity of the credit/consumer reporting system. However, if an account is closed voluntarily with no balance remaining on the account, we will stop providing the related account information to the credit bureaus.
How do we obtain your consent to use your personal information?
We obtain your consent in different ways depending on the circumstances and the sensitivity of the information. Consent may be oral or written, express or implied. Your express consent (verbal, written or electronic agreement) will be obtained to collect, use or disclose sensitive personal information such as your personal financial information. We will use implied consent to collect, use or disclose your personal information in circumstances where a customer relationship already exists, express consent has previously been given, or the purpose of using the personal information is reasonably apparent to you.
In certain circumstances, the law permits or requires that we collect, use or share your personal information without your consent. For example, we may collect, use or share your personal information to investigate a breach of an agreement or a law, or in response to a search warrant; to realize on security pledged for a loan, or to investigate or deter fraud.
What information do we need from you?
In order to provide you with products or services, administer your account and provide you with exceptional customer service, there is certain personal information that our companies need from you.
Sometimes you may voluntarily provide information to Manawa. This occurs when you fill out Manawa’s Customer Satisfaction Survey. The goal of this program is to gauge customer feedback via both an Internet and telephone survey. The survey will ask customers a variety of questions regarding their most recent experience and will help ensure that we consistently deliver an excellent customer experience. Manawa uses that information to respond to your query, and to keep track of customer feedback, which enables us to continuously improve.
Manawa may collect your email address, name, address, city, province, country, postal code, gender, household income and age range in order to provide you with advance notice of upcoming promotions and exclusive offers, or news of on-line events, information on products and services and notices of contests.
We need your name, address, and email address to provide to our financing partners if you request a leasing option.
Our financing partners use third parties including credit bureaus/consumer reporting agencies for these purposes and we need your consent to do this. If you do not provide us with your consent, we cannot act on your behalf when requesting financing from one of our partners.
Why do we record our calls?
Your customer experience is important to us which is why we train our customer service representatives on an ongoing basis. It is important for us to understand how our representatives are handling your questions and concerns. As such, if you have a telephone conversation with our representatives, we may monitor the call for training and quality control purposes. Please be aware, certain calls will be recorded for record keeping purposes. For example, your call will be recorded when you apply for a product or service, or authorize us to activate or enrol you in a product or service by phone.
What are “cookies”?
Cookies are small text files that contain a unique identifier which is placed on your computer. When you visit a website, the website saves the file with a matching identifier. When you revisit the site days or weeks later, the site can recognize you by matching the cookie on your computer with the matching identifier in its database. For more information on “Cookies”, visit our website terms and conditions.
Why do we share your information?
We need to transfer your personal information in order to provide you with the products and services you have requested. The following are examples of why our family of companies need to share your information.
We may need to share your personal information with the following entities: credit bureaus/consumer reporting agencies, data storage providers, insurers, data and payment processors, credit card printers, cheque printers, claims processors, collection agencies, statement producers, mailing houses (i.e., to mail your statement; to provide any necessary legal communications), third party call centres and account administrators, companies that solicit and collect applications for the financing, other companies that provide and service products and services, software developers specializing in data analysis, and fraud detection; regulatory compliance service providers, and other businesses within the Manawa family of companies that provide administrative services.
We may share personal information with the following types of companies for the purposes of promoting and selling products and services that may be of interest to you: mailing houses and letter generators, sales and marketing agencies, organizations that provide and service these offerings, and other businesses within the Manawa family of companies.
We do not necessarily share your personal information with each and every type of company listed above. The personal information we share with other companies will naturally depend on the products and services you are receiving.
In an ongoing effort to protect our customers and ourselves from fraud, we have employees assigned to various teams for fraud strategy protection. Designated employees may collect, use, and exchange personal information with other financial institutions and other entities permitted by law, such as investigative bodies, if we have confirmed a case of fraud and/or need to investigate potential cases of fraud. We also share information with the credit bureaus/consumer reporting agencies so that they can update their respective fraud databases. Examples of information shared for these purposes include confirmed fraudulent addresses, phone numbers and social insurance numbers, and other pertinent information.
How can you opt-out of receiving marketing?
You may decide that you do not want your personal information used or shared for marketing purposes. If this is the case, you may always withdraw or refuse your consent at any time by calling us toll-free at 1-866-996-2629. We will process your request as soon as possible but it may not be in time to remove you from promotions already in progress. Please remember that even if you have opted out of receiving marketing communications, we may still contact you for non-marketing purposes such as fraud, collections, account maintenance and transactional purposes.
How can you review and/or obtain copies of the personal information we have about you?
Once we receive your written request, our goal is to respond to your request within thirty (30) days of receipt. If, for some reason, we are unable to respond to your request within this time frame, we will contact you directly and explain the reason for delay.
There may be times where the law permits us to refuse your request to access your personal information. For example, if providing access to your personal information would reveal confidential commercial or proprietary information or personal information about someone else (and we are unable to separate your data), we may be unable to fulfill your request.
If we refuse access to your personal information, we will contact you directly. If you wish, you may then choose to file a complaint with the Privacy Commissioner of Canada.
You can request access to your personal information stored by us. Your request must be submitted in writing to:
301-801 York Mills Road, Toronto, ON M3B 1X7
Re: Privacy Inquiries
How can you ask further questions?
If you have further questions or concerns regarding our privacy policies or procedures, or if you would like to review, verify or amend your personal information, please do not hesitate to contact us.
We may be reached toll-free at 1-866-996-2629. Alternatively, you may write to us at:
301-801 York Mills Road, Toronto, ON M3B 1X7
Re: Privacy Inquiries
If your questions, concerns and complaints have not been resolved to your satisfaction or if you have further questions, you can contact: Manawa’s Chief Privacy Officer by mail at Chief Privacy Officer c/o Manawa, 301-801 York Mills Road, Toronto, ON M3B 1X7or by email at firstname.lastname@example.org.