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Aaron Acceptance Corporation - Policy Statement
At Aaron Acceptance, we understand that privacy is a critical issue for all our
clients. This policy outlines the principles Aaron Acceptance applies when
protecting clients' privacy. This policy outlines the principles and
commitments we make to you, our client, to protect the privacy of your personal
information.
This policy does not apply to the information collected, used or disclosed with
respect to corporate or commercial entities that are clients. However, Aaron
Acceptance exercises the same care and diligence in protecting the
confidentiality of this information.
Privacy Policies
1. Aaron Acceptance is accountable for the protection of clients' personal
information. While senior management is ultimately accountable for the
protection of personal information, the day-to-day monitoring for compliance
may be delegated to other staff.
2. Aaron Acceptance is committed to ensuring that the appropriate security
measures are employed in the transfer of sensitive information. However, when
using e-mail or wireless communication, Aaron Acceptance advises clients that
complete confidentiality and security are not assured.
3. Aaron Acceptance is not accountable for any damages suffered when a client
transmits personal information through e-mail or wireless communication or when
Aaron Acceptance transmits information at the request of the client.
4. Aaron Acceptance has developed policies and procedures to: protect personal
information; receive and respond to complaints and inquiries; train staff
regarding the policies and procedures; communicate the policies and procedures
to our clients.
5. Aaron Acceptance collects client personal information for the following
reasons only:
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To provide financial services;
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To understand their clients' financial needs;
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To facilitate the offering of third party complimentary products or services;
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To broker and administer loan agreements;
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To develop, manage and deliver products and services to clients;
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To develop and deliver marketing and promotional offers to clients;
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To determine client eligibility for different products and services;
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To ensure that clients receive a high standard of service;
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To meet regulatory requirements;
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To manage and transfer the assets and liabilities of Aaron Acceptance and those
assets under its administration; and
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To verify client's identity.
Aaron Acceptance will only collect personal information for the purposes
identified. Aaron Acceptance will use methods that are lawful and will not
collect information indiscriminately. Aaron Acceptance will not use personal
information for any additional purpose unless Aaron Acceptance seeks client
consent to do so.
6. Aaron Acceptance will obtain client consent to collect, use or disclose any
personal information except where detailed in this policy. Aaron Acceptance
will make reasonable efforts to ensure that clients understand how their
personal information will be used and disclosed.
7. A client's consent can be express, implied, or given through an authorized
representative such as a lawyer, agent or broker. Consent may be given orally,
in writing, or electronically. For example, depending on the sensitivity of the
information, consent can be expressed over the telephone when information is
being collected; electronically when submitting an agreement, application, or
other information; in writing when signing an agreement or application form.
Implied consent exists when Aaron Acceptance can reasonably infer consent based
upon the action or inaction of the client.
8. Aaron Acceptance, however, may collect, use or disclose personal information
without the client's knowledge or consent in exceptional circumstances:
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When such collection, use or disclosure is permitted or required by law
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When certain information is publicly available
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When we require legal advice from a lawyer
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When we need to collect a debt from a client
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When we need to deal with an anticipated breach of law
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When potential investors wish to ensure the quality and characteristics of an
investment.
9. Subject to contractual or legal arrangements, clients may withdraw or refuse
consent provided that Aaron Acceptance is given reasonable notice. Aaron
Acceptance may decline to deal with a client or person who will not consent to
the use of such information.
10. Aaron Acceptance may periodically use client personal information to conduct
client surveys in order to enhance our provision of services or products. If an
outside body is employed to conduct research on behalf of Aaron Acceptance, or
provide other services that require access to client information, Aaron
Acceptance will ensure that appropriate security undertakings, such as
confidentiality clauses in contractual arrangements, are employed to protect
the transfer and use of personal information.
11. Aaron Acceptance will retain client personal information only as long as
necessary or expected to be necessary for the identified purposes, or as
required by legislation.
12. Aaron Acceptance may disclose personal information related to a financial
asset of Aaron Acceptance along with transfer of the financial asset.
13. Aaron Acceptance will make reasonable efforts to ensure that client personal
information is as accurate. In some cases, Aaron Acceptance relies on its
clients to ensure that certain information, such as the client's address or
telephone number, is current, complete, and accurate.
14. Aaron Acceptance will not routinely update information unless it is
necessary to fulfill the purposes for which it was collected or if it is
required to maintain an active account.
15. Aaron Acceptance is committed to the safekeeping of client personal
information in order to prevent its loss, theft, unauthorized access,
disclosure, duplication, use, or modification, and will employ appropriate
security measures to protect the information. The measures may include, for
example, the physical security of offices and data, and electronic security
measures such as passwords and encryption where appropriate.
16. Aaron Acceptance will use appropriate security measures when disposing of
client personal information.
17. The development of Aaron Acceptance's policies and procedures for the
protection of personal information is an ongoing process. Changes in technology
necessitate that Aaron Acceptance continually develops, updates, and reviews
information protection guidelines and controls to ensure ongoing information
security.
18. Aaron Acceptance will make the following information available:
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The name, title and address of the person accountable for the policies and
procedures and to whom complaints or inquiries can be forwarded;
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A description of the type of personal information held by Aaron Acceptance,
including a general account of its use;
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A copy of any brochures or other information that explain the policies and
procedures; and
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An explanation of what personal information is made available to affiliated
companies or investors.
19. Clients have a right to access their personal information held by Aaron
Acceptance. Upon request, Aaron Acceptance will, within a reasonable time
period, tell the client what personal information it has, what it is being used
for, and to whom it has been disclosed if applicable and within the time period
for which records are available.
20. Clients may be asked to be specific about the information they would like to
access and to submit their request in writing to Aaron Acceptance.
21. Clients will be required to provide personal information to identify
themselves to enable Aaron Acceptance to provide an account of the existence,
use, and disclosure of personal information.
22. Aaron Acceptance will make the information available within 30 days, or
provide written notice of extension where additional time is required to
fulfill the request. When information is not provided within 30 days of the
request, Aaron Acceptance will, no later than 30 days after the date of the
request, send a notice of extension to the client, advising of the new time
limit, the reasons for extending the time limit and of the right of the client
to make a complaint regarding the extension.
23. If a request is refused, Aaron Acceptance will notify the client in writing,
documenting the reasons for refusal and resources for redress available to the
client.
24. The information will be made available at a cost that will vary with the
type and amount of information requested. Where the client will incur a cost,
Aaron Acceptance will inform the client of the cost and request further
direction from the client on whether or not Aaron Acceptance should proceed
with the request.
25. In certain situations, Aaron Acceptance may not be able to provide access to
any or all personal information about a client. In such cases, Aaron Acceptance
will explain the reasons it will not provide the requested information, and
identify resources for recourse available to the client. The reasons for not
providing information may include that it is unreasonably costly to provide,
information that would threaten the life or security of another individual,
information generated in a formal dispute resolution process, information that
contains references to other individuals, information that cannot be disclosed
for legal, security, or commercial proprietary reasons, and information that is
subject to solicitor-client or litigation privilege.
26. If the information is demonstrated to be inaccurate or incomplete, Aaron
Acceptance will amend the information as required. Where appropriate, Aaron
Acceptance will transmit the amended information to Third Parties having access
to the information in question.
27. Clients are to direct any complaints, concerns or questions regarding this
privacy policy in writing to the Compliance Officer. At any point in this
process the client may also write to the Privacy Commissioner.
28. Clients may withdraw consent at any time, subject to legal or contractual
restrictions, provided that reasonable notice of withdrawal of consent is given
to the Aaron Acceptance. On receipt of notice of withdrawal of consent, Aaron
Acceptance will inform the individual of the likely consequences of the
withdrawal of consent, which may include the inability of Aaron Acceptance to
provide certain products or services, if the information is necessary to
provide the products and services.
Contact Information
Aaron Acceptance Corporation, Attention Compliance Officer
Via email at info@oneplanloan.com
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