Privacy & Security

Privacy Policy

Our Commitment to You

Ukrainian Credit Union Limited (“UCU,” “we,” “our,” “us,” or the “Credit Union”) takes our commitment to privacy seriously. We take steps to protect the confidentiality and security of your personal information. The purpose of this Privacy Policy is to inform our members and other individuals (“you” or “your”) about how we collect, use, disclose, and protect your personal information. This Privacy Policy applies to our collection, use, and disclosure of personal information in Canada. This Privacy Policy does not apply to information about our employees or to information that is not personal information.

Your Obligations About Privacy

When using the Credit Union’s products or services, you are given access to certain systems in order to conduct transactions conveniently. Access to such products and services typically includes the use of personal identification numbers (PINs), personal access codes (PACs) or passwords, and other confidential passcodes or phrases (like, for example, Interac e-Transfer secret question and answer sets).

It is your responsibility to protect this information and prevent misuse. It is important to safeguard the personal information (including sensitive identity-related information) and banking information in your control, including account information, statements, unused cheques, PINs, PACs, and other codes.

Your responsibility includes safeguarding yourself from fraud and knowing or inadvertent disclosure of your information to unauthorized parties. This includes protecting yourself from phishing and other fraudulent conduct (like, for example, phishing and other scams) by third parties that could result in compromising your account, credentials, PINs, PACs, or codes. We will also never request sensitive information from you by email. If you receive a communication of that type, do not reply, and contact UCU directly (using the contact information located on our website or on the back of your debit card) for more information. Do not accept to contact us using the contact information included in suspected fraudulent communications because those attempting to commit fraud may also attempt to impersonate us.

Personal Information We Collect

We collect personal information in order to offer and provide financial products and services to you and to establish and serve you as our customer. We collect personal information from you, for example, when you use the Website (as defined in the website Legal Terms of Use available at ukrainiancu.com), on an application form, or through your ongoing interactions with us. We may also collect personal information from third parties, such as credit reporting agencies, financial institutions, references, employers, and other third-party sources (such as government registries and public records). Personal information we collect includes:

• Name.
• Contact information such as address, telephone number, email address and other contact information.
• Additional information for identity matching and credit check purposes, such as your occupation, name and contact information of your employer, assets, income, previous address, date of birth, social insurance number and other government issued identification.
• Information about your dealings with and through us, such as account information, transaction and payment history and records relating to any inquiries or complaints.
• Your contact list information (‘Contacts’), photos, and camera stored on your mobile device(s), if access to your Contacts, photos, or camera is enabled in the corresponding settings of your computer or mobile device.
• IP address and other device-related information such as the make and model of your device, its operating system, mobile device identification number (IMEI), MAC address, non-personal Device Identifier (AAID, IDFA), information about the screen size, date and time of your use, and geolocation information
• Other information we may collect with your consent or as permitted or required by law.

Use of Your Personal Information

We use personal information to provide requested financial products and services and to otherwise administer our business, including to:

• Verify your identity and the accuracy and completeness of information you provide to us.
• Assess your current and ongoing creditworthiness, financial situation and eligibility for products and services offer by us or our business partners.
• Evaluate and process your application.
• Open, administer and service your account(s) and provide and administer any requested products and services.
• Detect and prevent fraud and other illegal or unauthorized activities.
• Collect a debt or enforce an obligation owed to us.
• Provide you with information about special offers, contests, or community events.
• To meet legal, regulatory, self-regulatory, risk management, fraud prevention, and security requirements, including checking your identity against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies in Canada, the United States or in other countries.
• Manage and assess our risks, operations and relationship with you, and to analyze your needs and the effectiveness of our marketing or customer service efforts.
• Manage your Interac® e-Transfer Services Contacts on our mobile banking app.
• Obtain analytics about our products and services.

We may also use personal information for other purposes with your consent or as permitted or required by law.

Collection and Use of Social Insurance Numbers and Tax Identification Numbers

Provision of social insurance number (SIN) is optional for non-income generating products or services and mandatory for income-generating products or services. SIN, where provided, will be used for income tax reporting purposes (where applicable) and to identify you for credit matching purposes (if you have consented to such). Where a Tax Identification Number is used instead of a SIN, the same principles apply.

Monitoring Interactions

We may monitor and record telephone calls, chats, and email for quality assurance, training, and record-keeping purposes.

Use by Service Providers

UCU offers certain products and services through or with the assistance of service providers. We may transfer personal information to outside agents or service providers (including affiliates acting in this capacity) (“service providers”) that perform services on our behalf, for example card manufacturers, cheque providers, plan trustees, mailing services, billing providers, marketing agencies, information technology or data hosting or processing services or similar services, or otherwise collect, use, disclose, store, or process personal information on our behalf for the purposes described in this Privacy Policy. Some of these service providers may be located outside of Canada, including in the United States, and your personal information may be collected, used, disclosed, stored, and processed outside of Canada for the purposes described in this Privacy Policy. While your personal information is located outside Canada, it will be subject to applicable foreign legal requirements, which may include lawful requirements to disclose personal information to government or national security authorities in certain circumstances.

Your Consent

We collect, use and disclose personal information with your consent, except as permitted or required by applicable law. We may be required or permitted under statute or regulation to collect, use, or disclose personal information without your consent, including, for example, (a) to comply with a court order, applicable legal regulations, or a legally-permitted inquiry or demand by a government agency, or (b) to collect a debt owed to us.

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or otherwise at the time of collection.

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. However, if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide our products or services to you.

How We Protect and Safeguard Your Personal Information

The length of time your information is kept will vary depending on the product or service and the type of information we have. We keep your information for as long as we reasonably need it for customer service, legal or reasonable business purposes. For these reasons, we keep some of your information beyond the end of your relationship with us.

When your information is no longer required, we securely destroy such information within our control that has not been deidentified or anonymized.

We take reasonable steps to protect your personal information using physical, electronic, or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized persons who require access to your personal information in order to fulfil their job requirements will have access to your personal information.

Accessing or Correcting Your Personal Information

If you wish to request access or correction of your personal information in our custody or control, you may contact the UCU Contact Centre or write to:
Ukrainian Credit Union Limited
Attention: Privacy Officer
300-145 Evans Ave.
Toronto, Ontario M8Z 5X8
MemberPrivacy@ukrainiancu.com

Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.

Complaints to the Privacy Commissioner of Canada

You contact Privacy Commissioner of Canada any time if you have an enquiry or consumer complaint:

Privacy Commissioner of Canada, Investigations and Inquiries Branch
30 Victoria Street
Gatineau, Quebec, K1A 1H3

Changes to this Privacy Policy

This Privacy Policy may be revised from time to time. We will take reasonable steps to notify affected individuals of material changes to this Privacy Policy, including by posting the revised Privacy Policy on our website at ukrainiancu.com. You should check our website periodically to obtain a current copy of this Privacy Policy. Your continued provision of personal information or use of our services following any changes to this Privacy Policy constitutes your acceptance of any such changes.