Last updated: March 4th, 2018
- “Cookies” are small text files offered to a user's computer by web servers in order to keep track of the user's browser as a website is navigated.
- “Personal Information” means any information about an identifiable individual.
- “Principals” means individuals that own and/or are involved in the management of a business.
- “Us”, “we”, “our” and “Certn” means Certn Holdings, Inc.
- “Website” means the website operated by Certn and located at https://certn.co.
Certn is an information and data analytics company with the goal of offering the highest quality alternative to the current consumer credit-related products and services. Today, we serve the business community by providing consumer and business risk, fraud and identity management information, as well as analytics tools to help our clients make decisions.
An overview of our business
We facilitate business-consumer interactions by providing consumer credit, social and behavioural profiles to our clients, which include banks, credit-card companies, finance companies, landlords, property managers and other institutions (the “Clients”). By their nature, our services must include some personal information about our Clients’ potential or existing customers (the “Applicants”). Accordingly, we regularly collect, use and disclose personal credit, social and behavioural information of consenting Applicants. Credit grantors, credit bureaus and other institutions provide Certn with factual information about how the consenting Applicants pay their bills and other debts. Credit reporting agencies, such as Equifax, compile and assemble this information, along with public record information, into a "File" for each Applicant. In return, credit grantors and authorized institutions, pursuant to the applicable federal, state and/or provincial consumer reporting legislation, are able to obtain credit reports about Applicants.
We facilitate commercial transactions by providing credit, social and behavioural profiles to our Clients. Our services will contain credit information about potential or existing Applicants including businesses, as applicable. In some instances, credit information about businesses may also contain certain personal information as provided in a business credit report about the Principals of the business, such as name, address, phone number and percentage ownership in the business. Similarly, credit information about individual Applicants may also contain information about the individual’s related businesses and/or affiliations.
Our collection practices for potential or existing Applicants
We primarily collect Applicant Personal Information from the following sources:
- Reports about Applicants that are provided to us by credit reporting agencies, bureaus, grantors or other institutions
- Collection agencies;
- The internet, and public social media profiles that individual authors have made publicly available;
- Directly from Applicants in response to any dealings we have with the Applicant including the Certn questionnaire; and
- Public records, federal, state and/or provincial government offices, public registries, and other sources permitted by law.
If you call us, we may record and retain the recording to ensure the accuracy of our discussions and for quality control and record keeping purposes.
Information we collect
What is included in our reports
Certn’s reports may contain the following information:
- Identifying information: Applicant name, previous name(s), date of birth, Social Insurance Number (including temporary and/or previous Social Insurance Numbers), current and previous addresses and telephone numbers, and current and previous employers;
- Credit history: Record of payment history on current and previous bills/debt obligations, including payments on loans, credit cards, lines of credit and mortgages owing to organizations such as retail stores, banks, finance companies and telecommunications companies;
- Public records: Information that may affect creditworthiness, such as judgments, bankruptcies, consumer proposals and registered items;
- Inquiries: A list of credit grantors and other parties authorized by the consumer and/or by law that have received all or part of a Applicant’s credit information. Also lists organizations that have received a service from Certn where consumer credit information was used but not necessarily disclosed, such as authentication;
- Collections: Information about collection matters. This segment may include information about outstanding collections on business accounts if you are personally liable for the debt. It may also include information about outstanding family maintenance support obligations, if permitted by law;
- Banking: Information about bank accounts that were closed by an institution for reasons such as empty envelope deposit, NSF cheques or uncollected overdraft charges;
- Remarks: All remarks that have been added to your file, such as a fraud alert or a consumer statement;
- Behavioural profiles: Results from the psychometric test questions that may be asked in a Certn questionnaire; and
- Social profiles: Results from a scan of the internet and public social media profiles for information containing content published by you, about you or on your behalf.
Information we do not collect
Certn reports do not contain:
- Medical histories;
- Information about purchases paid in full with cash or cheques;
- Race, creed, colour, ancestry, religion, ethnicity, sexual preference, family status or political affiliations.
Our use and disclosure of your Personal Information
We limit our use of Personal Information to those purposes which have been disclosed to the Applicant by us or our Clients and for which appropriate consents have been obtained, or for purposes which are otherwise permitted by law. In connection with our services, we do not have direct relationships with the Applicants. Accordingly, Clients to inform their Applicants of the purposes for which they are providing Personal Information to Certn, or accessing Personal Information from Certn, and to obtain appropriate consent at the time the information is collected from the Applicant and/or prior to its use or disclosure by Certn. We also require our Clients to limit the use of Personal Information obtained from Certn to purposes that are permitted by law.
Certn uses and discloses Personal Information in the following circumstances:
- To provide our consumer credit reporting services, business credit reporting services, and other related services to our Clients;
- To provide authentication, ID verification and/or credit services to Clients purchasing your credit file;
- To manage, administer, collect or otherwise enforce accounts;
- To assist in the investigation of a contravention of a law and/or fraudulent activities;
- To fulfill our obligations under consumer reporting and privacy legislation (such as, a request to initiate an investigation); and
- To act in respect of an emergency that threatens the life, health or security of an individual or for other purposes as permitted or required by law.
In addition, we may provide anonymous information (i.e., information that does not identify Applicants or, where applicable, its Principals) in the form of aggregate or demographic data to our Clients or service providers. We may also generate and use anonymous information to develop, enhance or validate our products, processes or services. Personal Information will necessarily be used to generate anonymous information and, when required, to research, validate and test the use of anonymous information in such processes, products, services and enhancements.
We collect, use and disclose personal information when the Applicant is aware of the purposes for which the information will be used or disclosed, and has given his or her consent to such use or disclosure, except where collection, use or disclosure of personal information without consent is permitted or required by law.
In most cases, Applicants will not provide such consent directly to Certn, but to our Clients. We require our Clients to obtain consent prior to providing Certn with personal information, and prior to accessing the personal information contained in our credit files.
We have appointed a Privacy Officer to oversee our compliance with the privacy principles established by the federal Personal Information Protection and Electronic Documents Act, and with provincial privacy and credit reporting legislation. However, protecting Personal Information does not begin and end there: we are committed to fostering a sense of responsibility amongst our employees for protecting the privacy and accuracy of Personal Information while it is in our care.
Likewise, our Clients have obligations to Applicants when accessing Personal Information from us or providing Personal Information to us. We have processes in place to encourage our Clients to comply with applicable law and obtain the necessary consents. Such processes include entering into binding agreements with our Clients and conducting random audits of our Clients’ internal procedures; however, the responsibility for the Clients’ compliance ultimately rests with them.
Retention of your Personal Information
Certn retains your Personal Information in our information database for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws.
Please contact our Consumer Relations Centre using the contact information below. Our Consumer Relations Centre is staffed by trained personnel who can assist with your inquiries. You may also direct your inquiry or request directly to our Privacy Officer. We may require that you put any request for access or correction in writing.
Consumers can also contact us through our:
- Website: https://certn.co
- Email: email@example.com
- Telephone: +1 (844) 822-3786, Mon-Fri 8am-8pm (EST)
When a Client bases its decision to deny a benefit or to increase a charge to the Applicant, in part on information received from Certn, the Client has an obligation to inform the Applicant Customer that it obtained information from us and our Partners at Equifax. In this situation, Clients must provide individuals who are declined with Certn’s and Equifax’s contact information so that the individual can verify the content of their Certn Report and Credit File and, if necessary, request from Certn, the credit bureau or one of our Certified Data Providers that information be amended or deleted. Certn does not play a role in the decision to deny or advance an Application, the Applicant should deal directly with the Client for more information on the denial of their Application.
If Certn is satisfied on reasonable grounds that a request made should be implemented, Certn will (a)correct the personal information as soon as reasonably possible, and (b)send the corrected personal information to each organization to which the personal information was disclosed by Certn during the year before the date the correction was made.
If no correction is made, Certn will create a note in our database with the correction that was requested but not made.
Certn requires, that when an Client is notified of a correction of personal information, the Client must correct the personal information under its control.
Access to your Personal Information
You are entitled to receive your Personal Information from Certn at no charge upon written request. We also encourage all consumers to request and review their Equifax credit report on a regular basis. By doing this, you can ensure that your report contains information that accurately reflects your credit history. You have the right to dispute any discrepancies by immediately notifying us, or Equifax in writing and we will investigate to ensure the items reported are factual. Where a piece of information, outside of the Credit file (Equifax Report), cannot be verified by the reporting source, Certn will remove it from your Certn files.
You also have a right to access the other personal information belonging to you that is under our control subject to any legal restrictions or rights of refusal. Such a request for access must be made in writing stating the details of the personal information you are requesting to Certn’s Chief Privacy Officer at Chief Privacy Officer, Certn (Canada) Inc. 1017 Fort St., Victoria BC V8V 3K5. To ensure we disclosure information to you only, with your request please include photocopies (front and back) of two (2) pieces of government issued photo id so that we may verify your identity.
Certn's Website makes use of "per-session" Cookies. Unlike "persistent" Cookies, which are stored on a user's hard drive and can last indefinitely, per-session Cookies are stored only in a browser's temporary memory and are deleted when the browser is shut down.
When users visit our Website, our web server offers the user's browser a per-session Cookie. As the Website is navigated, this Cookie is read back to our web server, allowing us to generate an anonymous "click trail" profile of the visit. From the aggregated information about visits, Certn learns how visitors interact with its Website, how the Website design and content can be improved, and how visitors' experiences can be improved.
Certn does not link, share or associate the contents of the per-session Cookie with any other information in a way that would enable the identification of visitors to our Website. Nor do we track or link together multiple visits by any single user over time. Our per-session Cookies cannot be "read" by any other web servers, so users cannot be tracked or profiled using Certn's Cookies if they visit multiple sites on the Internet. Some browsers can be set to reject all Cookies. If a user chooses to modify a browser in this manner, some pages of our Website may not function properly.
IP addresses and server logs
Unique Internet Protocol (IP) addresses are assigned to all internet users by their Internet Service Providers (ISPs). IP addresses do not directly identify internet users; however, through an ISP, an IP address may be linked to a particular user.
During a visit to a website, certain information about a user's traffic patterns, linked with the user's IP address, is passively and automatically collected in the normal course of establishing and maintaining a website connection. This information is logged by the web server of the website that is visited.
The following information is logged by Certn's web servers during visits to our Website: IP addresses, type of operating system, time and duration of visit, web pages visited and browser type. We do not link server log information to any other information in a way that would enable the identification of visitors to our Website. Server log information is analyzed by us in order to improve our Website and to customize the Website for users. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on our Website. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
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