Business POS Canada Privacy Policy

1. 1. Who Are We?
2. 2. How We May Contact You As Part Of Your Application
3. 3. How You Contact Us
4. 4. How We Keep You Informed
5. 5. Obtaining Your Personal Data/Information
6. 6. Customer Communication
7. 7. What Personal Information Do We Collect?
8. 8. How Do We Use Your Personal Information?
9. 9. Who Do We Share Your Personal Information With?
10. 10. Who Might Our Panel of Electronic Point of Sale Digital System Provider and Brokers Share Your Personal Information with?
11. 11. What Cookies Do We Use?
12. 12. How Secure Is Our Site and What Steps Do We Take To Keep Your Personal Information Safe?
13. 13. Your Right To Opt Out of Future Contact From Us And Our Trusted Third Parties
14. 14. Your Right to be Forgotten / Erasure of Your Personal Information
15. 15. How to make a complaint

1. Who Are We?

Commercial Experts Canada is a trading name of TFLI (US) INC Limited, Registered Office; 5805 Blue Lagoon Drive, Suite 200. Miami, Florida. 33126. TFLI (US) INC is registered in United States of America (Company number P20000059850).

pos-commercialexperts.ca are aware how important your privacy is, based on this we have implemented measures which will ensure any personal information that is obtained from you by visiting our website will be processed and maintained in line with accepted principles of good information handling and in accordance with the Canada's Federal Personal Information Protection and Electronic Documents Act (PIPEDA) formerly referred to as Bill C-6. Contained within this statement and set out below are details of the type of information that we at Commercial Experts may hold about you our customer, also how we obtain and process any information we may have and importantly how we protect your privacy.

This privacy policy is only applicable to us and personal information which may be collected and obtained by us. pos-commercialexperts.ca may choose to amend the content of this privacy policy on occasion. If this occurs then we will update the policy and the revised policy will be posted on this website.

2. How We May Contact You As Part Of Your Application

We, and our panel of electronic point of sale digital system provider and brokers will keep you informed with the progress of your application. Unless you state otherwise you may be contacted via telephone, email, SMS and automated message. (See further section on 'How we keep you informed')

3. How You Contact Us

If you are required to telephone us using the specified telephone numbers on our website under the Contact or advertising/marketing correspondence then your call may be recorded for training, quality and regulatory purposes. We pride ourselves in complete customer care and this gives us the opportunity to continuously improve and monitor our customer experience.

4. How We Keep You Informed

We may want to make contact with you at some point in order to keep you informed regarding offers on products or services which we think you may find of interest; this contact will be made via email and SMS. Third parties may also wish to contact you from the information we have shared with them, any information that is shared to third parties is completely trusted for the purpose it is specified for, third parties may also use the same means of contact stated above.

Whilst the electronic point of sale digital system provider and brokers will make contact with you to confirm whether your application has been successful, they will to have their own privacy policy and recommend you refer to them, upon making your application, you will be requested to agree to their use of your information.

5. Obtaining Your Personal Data/Information

1. You are free to access and browse our websitepos-commercialexperts.ca at your convenience and do not have to provide any personal information/data, however I would like to refer you to the 'Cookies' section set out within this privacy policy.
2. The personal information/data that we would normally collect from you is as follows: Business Name, ZIP Code, Name, Email Address, Cell Number, IP Address

If you apply with us and have a question about our services, or alternatively choose to send an email to compliance@tfli.us we may also collect the above personal information/data in this instance in order for us to respond to your enquiry.

6. Customer Communication

Unless the customer states otherwise we will contact the customer via means of telephone, SMS and email to provide information and alerts relating to our services and our associate companies. We may also receive personal information/data from third parties, which enables us to offer Identified potential customers products, and services who have expressed interest in our products and services. Any information/data obtained from third parties is checked in regards to accuracy and we will endeavour to check your information with you on occasion.

Ensuring your personal details & or preferences are kept up to date.

It is your responsibility to ensure that any information we have on record for you is kept up to date and correct. If you do require any of your information to be updated then please contact us as soon as possible so we can ensure it is corrected.

If you require your preferences to be updated then please contact our Compliance Manager as soon as possible (details set out below within 'Contact' page).

7. What Personal Information Do We Collect?

We collect personal information about you when you give this to us when applying for a product online. This might be, for example, to obtain quotes for electronic point of sale digital systems. In the course of providing the Services to you, we may also store information about how you use our Sites, for example, the pages viewed, the website from which you came to visit our Sites, changes you make to information you supply to us, details of the quotes you request and your applications, together with details of your financial information, for example, bank account or employer details.

In order to provide you with a quote we will need to collect personal information. By proceeding with obtaining a quote you give your explicit consent to such information being processed by us and our third-party providers such as electronic point of sale digital system provider and brokers, 

We will store the information you provide and may use it to pre-populate fields on the Sites and to make it easier for you to use the Sites when making return visits.

We may monitor or record your Calls, Emails, SMS or other communications but we will do so in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training (e.g. where you call our compliance or customer service department), to prevent unauthorised use of our telecommunication systems and Sites, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime.

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law.

8. How Do We Use Your Personal Information?

We may use your personal information:

1. to enable you to access and use the Services;
2. to personalise and improve aspects of our Services;
3. for research, such as analysing market trends and customer demographics;
4. to communicate with you, including some or all of the following:
5. to process an application between you and a third party such as the electronic point of sale digital system provider and brokers
6. to track sales, which may involve us sharing data with your product provider relating to the product(s) you have purchased. Your product provider may also send us information they hold relating to the product(s) you have purchased for this purpose;
7. to match our data with data from other sources - we may validate and analyse your information and, in some cases, match it against information that has been collected by a third party to ensure that the information we hold about you is as accurate, consistent and as well-organised as possible. As well as ensuring that any marketing material that we send you is appropriate to your needs, this process also ensures that our Services continue to be as personalised and focused as possible;
8. to circulate our customer survey review which are available to customers once an application has been completed;
9. to enable you to share our content with others, e.g. by using any 'Email a friend' or 'Share this' functionality on our Sites.
10. to potentially pass on your data to third parties for marketing purposes as per section 9 where you have consented to do so.

Keeping you informed about the Services: You agree that we and, with your consent, other trusted third parties will be entitled to contact you (depending on your contact preferences) via email, post, telephone, SMS, or by other electronic means such as via social and digital media, in relation to products, services and other offers that may interest you.

Whenever you provide us with personal information, where necessary we will seek your consent and/or we will give you an opportunity to tell us you do not consent to the use and sharing of your information for marketing purposes. Unless you tell us otherwise, you are consenting to such use.

9. Who Do We Share Your Personal Information With?

When you complete an application, you consent to us disclosing your personal information to the following parties:

1. pos-commercialexperts.ca and TFLI (US) INC: (i) to communicate with you, including sending you information about products and services which may be of interest to you; (ii) to speed up form filling, or to personalise, or improve your experience on its website, mobile applications or other similar devices, channels or applications; or (iii) in accordance with its privacy policy.
2. Electronic point of sale digital system provider as detailed below. You can view details to how they will process your data within their privacy policies.
3. Trusted third parties / partners but only where you have opted in to allow us to do so and they are detailed below.  They will contact you with regards to the electronic point of sale digital system quote that we believe could be of benefit to you. You can opt out at any time from receiving these communications.
4. Regulatory/governing bodies, for the purposes of compliance monitoring;
5. Google, Linkedin, Facebook to enhance targeting / exclusions from advertising.
6. Under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn't outweighed by the effects it will have on the relevant individuals. Your data may also be used in a similar manner to aid debt recovery and to prevent fraud by helping to identify you (for instance when you are applying for new products.

Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account:

1. if required or permitted to do so by law;
2. if required to do so by any court, the Competition and Markets Authority or any other applicable regulatory, compliance, Federal or law enforcement agency;
3. if necessary, in connection with legal proceedings or potential legal proceedings; and/or
4. in connection with the sale or potential sale of all or part of our business.
5. TFLI (US) INC collect your data and will share it for commercial gain with third parties. These organisations will have a relationship with you or it may be used where they have a lawful reason, which may include these organisation's own legitimate interest. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.

If we reasonably believe false or inaccurate information has been provided and fraud is suspected, details may be passed to fraud prevention agencies to prevent fraud and money laundering.

You have the right to object to this processing at any time by contacting us at compliance@tfli.us

10. Who Might Our Panel of Electronic Point of Sale Digital System Provider and Brokers Share Your Personal Information with?

Some of our providers will use your personal information to assess your circumstances (including information about any third party who is named on the application) and verify the information that you have provided before providing a quote to you. Some providers may carry out checks with fraud prevention and credit reference agencies. Some providers may carry out checks against data they already hold on you, (or is held by the company whose brand they administer the product for, or members of their group of companies) such as data from existing products, account data, data from previous product transactions, accounts you may hold with them or loyalty scheme data to share with our panel of electronic point of sale digital system provider and brokers. If providers carry out these searches, a record of the search will appear on your credit report. Some providers may also check public and private higher education sources to obtain information about your educational background.

This information exchange allows providers to verify the information that is provided during the quote process (including information about any third party who is named on the policy), and also helps to detect fraudulent applications. These checks are not unique to users of our Services - they may also be carried out if you obtain quotes from other sources.

If you decide to enter into a contract, the information you have provided to us, together with any further information requested by, and supplied by you or us to the third-party provider, will be held by the provider for the purposes set out in that provider's privacy policy. Therefore, you are strongly advised to read your chosen provider's privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the agreement. We have no responsibility for the uses to which a provider puts your personal information.

11. What Cookies Do We Use?

Cookies and Web Beacons

This section sets out our use of Cookies when you use our sites. Please read it carefully as it explains how we and third parties may make use of your data collected by such Cookies. If you wish to understand how we make use of your data, more generally please refer to section 8.

We use a single first party cookie, named 'PHPSESSID'. This cookie is vital for the operation of the website, as it allows us to track different page loads to yourself, which allows the form and application process to work.

To find out more about accepting or refusing cookies please visit www.allaboutcookies.org.

We also use Google Analytics to collect non-personally identifiable information, in aggregate form, to understand website/page visit volumes in terms of source, geography, browser, etc.

Google Analytics employs a software technology called web beacons, that help us better manage content on our site by informing us what content is effective. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users or responses to emails. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons cannot be disabled in same manner as cookies may. We do not tie the information gathered by web beacons to our customers' personally identifiable information.

Cookies used by Google Analytics:

Google Analytics is a simple, easy-to-use tool that helps website owners measure how users interact with website content. As a user navigates between web pages, Google Analytics provides website owners JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to "remember" what a user has done on previous pages / interactions with the website.

Important: Read the Google Analytics privacy document for more details about the data collected by Google Analytics.

Google Analytics supports three JavaScript libraries (tags) for measuring website usage: gtag.js, analytics.js, and ga.js. The following sections describe how each use cookies.

FACEBOOK (VISITOR ACTION PIXEL)

We use the "visitor action pixels" from Facebook Inc (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook")) on our website.

This allows user behaviour to be tracked after they have been redirected to the provider's website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook's Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.

Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

Privacy Policy for the use of Instagram

On our websites functions of the service Instagram are embedded. These functions are offered by the Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged in to your Instagram account, you can link contents of our websites to your Instagram profile by clicking the Instagram button. By this, Instagram will associate the visit of our websites with your user account. We would like to point out that we, as providers of these websites, do not obtain knowledge about the contents of transmitted data as well as their use by Instagram.

For further information, please review the Privacy Policy of Instagram: http://instagram.com/about/legal/privacy/

TWITTER CONVERSION TRACKING

On our website, we use the Conversion Tracking Service of Twitter Inc. (1355 Market Street #900, San Francisco, California 94103, "Twitter"). Twitter stores a cookie on the user's computer to enable an analysis of the use of our online products and services. Twitter Conversion Tracking tracks the actions of users after they have viewed ads or interacted with ads on Twitter. Twitter's Conversion Tracking allows you to assign conversions such as link clicks, retweets or "like" data.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you wish to object to tracking, you can do so using the Digital Advertising Alliance tool at optout.aboutads.info.

Twitter is certified under the Privacy Shield Agreement and thus guarantees its compliance with European data protection legislation: (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active)

Cookie settings

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that by disallowing cookies some functionality on the site may be restricted.

12. How Secure Is Our Site and What Steps Do We Take To Keep Your Personal Information Safe?

Our Sites are "Let's Encrypt Secure Websites" and keeping information about you secure is very important to us. However, no data transmission over the internet can be guaranteed to be totally secure. Sensitive information, for example, your card details, is encrypted to minimise the risk of interception during transit.

We do our best to keep the information you disclose to us secure. However, we can't guarantee or warrant the security of any information which you send to us, and you do so at your own risk. By using our Sites you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

Where will your personal data be held?

Your personal data may be held within the European Economic Area (EEA) or outside the EEA. If any personal data is transferred or stored outside of the EEA, we check whether the EU Commission has determined that it will afforded the same level of protection as it would within the EEA (this is called an adequacy decision). If it will not, we will ensure any such transfer is subject to appropriate safeguards (for example by putting appropriate contractual provisions in place with relevant third parties to provide us with reassurance about the security of your personal data) or is otherwise permitted (for example with your express consent to transfer) in accordance with the provisions of the Canada's Federal Personal Information Protection and Electronic Documents Act (PIPEDA) and GDPR.

13. Your Right To Opt Out of Future Contact From Us And Our Trusted Third Parties

You can opt out of future contact from Commercial Experts at any time. All of our marketing messages provide an opt out link - please allow up to 48 hours for us to process your opt out request. Alternatively, you can email compliance@tfli.us where your details will be removed from any future marketing campaigns.

If you are receiving contact from third parties you will need to contact them directly and request them to remove your details.

14. Your Right to be Forgotten / Erasure of Your Personal Information

All individuals have the right to request the deletion or removal of personal data (the right to be forgotten) under the following circumstances:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
• When the individual withdraws consent.
• When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
• The personal data was unlawfully processed.
• The personal data has to be erased in order to comply with a legal obligation.
• The personal data is processed in relation to the offer of information society services to a child.

There are some circumstances where the right "to be forgotten" does not apply i.e., where we need to comply with a legal obligation.

If you wish to request your "right to be forgotten" please email: compliance@tfli.us

Our marketing partners will also be informed of your request where you have stipulated to do so.

15. How to make a complaint

Commercial Experts always aim to be fair and honest in everything we do, so if you have a complaint about any aspect of our service, we're keen to resolve it as quickly as possible. You can contact us as follows:

By Email: complaints@tfli.us

We will acknowledge receipt of the complaint within 3 working days and we hope to provide a final response within 4 weeks. We will write to you again within 4 weeks if we are unable to provide a final response within that time period. In any event we will respond to your complaint in full within 8 weeks.