At Merit, we are committed to providing our customers with exceptional service. Because our business requires the collection, use and disclosure of some personal information about our customers, protecting their personal information is one of our highest priorities.
We will inform our customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
Personal Information –means information about an identifiable individual. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.
Privacy Officer – means the individual designated responsibility for ensuring that Merit complies with this policy and applicable law.
Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect customer information that is necessary to fulfill our business purposes including:
- To verify identity;
- To identify customer preferences;
- To understand the needs of our customers;
- To open and manage an account;
- To deliver requested products and services
- To ensure a high standard of service to our customers;
- To meet regulatory requirements;
2.1 We will obtain customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, in writing, electronically, or through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used and the customer does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide or continue to provide a service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers can withhold or withdraw their consent for Merit to use their personal information in certain ways. A customer's decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer in making the decision.
2.5 We may collect, use or disclose personal information without the customer's knowledge or consent when the collection, use or disclosure of personal information is permitted or required by law;
Using and Disclosing Personal Information
3.1 We will only use or disclose customer personal information where necessary to fulfill the purposes identified or reasonably implied at the time of collection
3.2 We will not use or disclose customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer lists or personal information to other parties unless we have consent to do so.
Retaining Personal Information
4.1 If we use customer personal information to make a decision that directly affects the customer, we will retain that personal information for at least one year so that the customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer personal information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization.
5.2 Customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required. If the correction is not made, we will note the customers' correction request in the file.
Securing Personal Information
6.1 We are committed to ensuring the security of customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 We will take reasonable and appropriate measures to secure customers' personal information, including: use of electronic network passwords and security measures, maintaining paper records in secure areas or in locked files, contractually requiring service providers to establish and maintain reasonable security practices.
6.3 We will use appropriate security measures when destroying customer's personal
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Providing Customers Access to Personal Information
7.1 Customers have a right to access their personal information, subject to limited
exceptions as are provided for by law.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.
7.3 Upon request, we will also tell customers how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer of the cost and request further direction from the customer on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the customer in writing, providing the reasons for refusal and the recourse available to the customer.
Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Merit's compliance with this policy and our obligations under the law.
8.2 Customers should direct any complaints, concerns or questions regarding Policy Payments' compliance in writing to Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer may also contact the appropriate government privacy official.