1. Online Privacy Policy
2. Our guiding Policy principles
3. Identifying the purpose of personal information
4. Obtaining your consent
5. Use of cookies
6. Limiting collection, use, and disclosure of personal information
7. Providing access and accuracy
8. Responding to your privacy concern

1. Online privacy policy
The Business Development Bank of Canada, with its virtual branch BDC Connex, (collectively "BDC") is Canada's small business bank and may be involved in special initiatives (e.g. E-Spirit Aboriginal Youth Business Plan Competition). BDC plays a leadership role in delivering financial, investment and consulting services to Canadian small business, with a particular focus on the technology and export sectors of the economy.

Technology is changing the way we do business, increasing the circulation and exchange of information; therefore it has become essential to establish clear rules in the management of Personal Information that recognizes individuals' right to privacy.

BDC is aware of your legitimate concerns about privacy and is fully committed to maintaining the integrity, confidentiality, security, and accuracy of your Personal Information. To this end, we will continuously deploy all reasonable physical, technological, and administrative measures to protect your privacy in accordance with applicable privacy legislation and best industry practices.

We thought it would be useful to provide you with our Online Privacy Policy (the "Policy"). The Policy helps you understand the guiding principles applied by BDC to the collection, use, disclosure, retention, and disposal of and access to Personal Information on this site. Because privacy concerns and legal and business requirements evolve continually, BDC may have to change its Policy at any time without advance notice and therefore you are invited to review it regularly. Access to and use of this site are also governed by BDC's site terms and conditions for access to and use of site which contain provisions concerning privacy and other issues that you should review.

If you have any questions concerning BDC's Policy, please feel free to contact us by email.

2. Our guiding privacy principles
Our Policy rests on the following 7 key privacy principles:

1. Identifying the purposes of Personal Information
   BDC will identify and inform you of the purposes for which the Personal Information is being collected.
2. Obtaining your Consent
   BDC will obtain your Consent before or when it collects, uses, or discloses Personal Information, and will give effect to your withdrawal of consent.
3. Limiting collection, use, and disclosure of personal information
   BDC will not, without your Consent, collect, use, or disclose Personal Information except for the purposes identified or for a use consistent with those purposes.
4. Safeguarding personal information
   BDC will implement appropriate physical, technological, and administrative measures to safeguard your Personal Information.
5. Providing access and accuracy
   BDC will respect your right of access to your Personal Information and take all reasonable steps to ensure the Personal Information used is accurate and complete for the purposes identified.
6. Responding to your privacy concerns.
   BDC will respond to your questions and investigate diligently any complaints with respect to your Personal Information.
7. Complying with applicable privacy legislation.
   Your and BDC's rights and obligations regarding privacy are governed by applicable privacy legislation in Canada. The application and interpretation of this Policy and of our guiding privacy principles are subject to and will comply with such legislation, including the requirements, procedures, exemptions, and exclusions contained therein.

For purposes of this Policy, "Personal Information" means any information about an identifiable individual within the meaning of section 3 of the Privacy Act. Personal Information includes, without limitation, information relating to identity (including the name or other identifier assigned by BDC to an individual), nationality, age, gender, address, passwords, telephone number, e-mail addresses, marital status, education, employment and health history, assets, liabilities, payment records, income and information relating to financial transactions as well as certain personal opinions or views of an individual.

3. Identifying the purposes of personal information
The nature and scope of the Personal Information we need depends to a great extent on which products or services are of interest to you. BDC will collect Personal Information only in relation to its operating programs or activities for business purposes, and will take special care to explain these purposes clearly. Below, we provide concrete examples of Personal Information associated with these purposes and explain why such information is necessary:

• To identify you
  Personal Information such as your name, telephone number, personal address, date of birth, gender, and password helps us to identify and contact you, and to prevent impersonation.
• To determine your eligibility for products, solutions or services you request and their suitability
  Personal Information such as information relating to assets, liabilities, financial transactions, income, education, employment, etc. is needed to evaluate your creditworthiness, assess your eligibility, and to make decisions in the context of any loan application or credit facility.
• To offer products, solutions and services that meet your needs
  The BDC Consulting Group draws on almost 30 years of experience to deliver custom-made services, with the objective of providing innovative and responsive consulting solutions to growth-oriented, knowledge-based, and exporting companies. Personal Information about you, your projects, needs and finances such as name, address, e-mail, telephone number, passwords, etc., enables our specialists to respond to your requests for such services and to assess, plan, and implement integrated management solutions at every stage of your business's development.
• To advise on our products, solutions and services
  BDC will try to satisfy your request for advice on various matters and direct you towards appropriate products, solutions and services whenever possible. Personal information ensures the advice we give you is better suited to your financial profile. It allows us to recommend features and tools such as our ratio calculators and online benchmarking tools, designed to provide automated feedback on business opportunities based on your input.
• To provide ongoing services
  Personal Information about you and your business allows us to communicate with you and respond adequately and promptly to your enquiries about applications, accounts, or other on-line services.
• To recognize your achievements
  BDC's Young Entrepreneur Awards and other competitions are held annually across Canada in recognition of entrepreneurship. To select and contact the winners for these prestigious awards, the judges require certain Personal and financial Information concerning, for instance, your financial statements, your business plans, and your community involvement.
• To protect you and us against errors and fraud
  All your activities are electronically logged, so that BDC can review them in case of any suspicious activity. BDC uses software to monitor site traffic and to detect unauthorized attempts to upload, change information, or otherwise cause damage. The software receives and records the Internet Protocol (IP) addresses of the computers that have visited this site, including the date and time of visits, the pages that were viewed and downloaded, and the identifier attributed to any registered user who accesses restricted areas on this site. The software also captures information regarding the type of browser and operating system. BDC does not attempt to link the IP addresses and the identifiers with the identity of users visiting this site unless there is an attempt to damage the site.
• To promote our products, solutions and services to you
  When you complete any on-line BDC subscription or registration form and indicate that you wish your name to be added to BDC's mailing list, BDC will, from time to time, use your e-mail or regular mailing address to send you information on BDC's products, solutions and services, changing trends, business opportunities, or other topics of current interest. In order to do so, BDC may also collect the information that you provided on the subscription or registration form, such as your name and name of your company (if applicable), your address, telephone and fax numbers, and your language of preference.
• To comply with legal, security, processing, and regulatory requirements
  In situations where BDC may credit you with interest income, your social insurance number is required to comply with current tax laws.

4. Obtaining your consent
Your Consent can be expressed or implied ("Consent"). It can be expressed orally, in writing, or electronically when, for example, you authorize us to check your employment, to obtain a credit report, or to exchange Personal Information with credit bureaus or other financial institutions in the context of an application for financing, a loan, or credit facility. Your Consent can be implied through your action or inaction. For instance, when you file an application, we conclude that you have Consented to the collection, use, and disclosure of the Personal Information it contains for the intended purposes. The same conclusion may be drawn when you use one of our products, solutions or services or fail to respond to our offer to remove your Personal Information from a mailing list. Your Consent can also be given by your authorized representative, for instance, if he or she is providing Personal Information and is seeking financing on-line from BDC Connex on your behalf.

BDC will make all reasonable efforts to ensure you understand the purposes for collecting Personal Information, and to obtain your Consent in a timely manner, given the nature and sensitivity of the information. Your Personal Information will be viewed by BDC employees or representatives for the purpose of their work or for which it was given.

In some circumstances, BDC will have to collect, use, or disclose Personal Information without your Consent for legal, security, or processing reasons, or when it is impossible to obtain your Consent in cases contemplated by applicable privacy legislation. Examples of such circumstances include compliance with applicable laws or court orders, the protection of the public interest, BDC's rights, fraud detection and prevention, the use of an outside company to process Personal Information, the use of Personal Information emanating from a third party, and the collection of overdue accounts. Wherever possible, BDC will require third parties to conform to appropriate privacy standards and allow us to audit their compliance.

You can withdraw your Consent at any time, provided BDC is given reasonable notice and there are no legal or contractual requirements preventing this i.e. BDC will comply with your request to be removed from their mailing list.

5. Use of cookies
A cookie is a small text file containing certain pieces of information that a web site server creates and puts on your computer. BDC uses cookies to enable us to better serve you when you visit our site. We have 2 common types of cookies, "session cookies" and "persistent cookies".

Session cookies actively store information only for the length of time you are connected to the site. BDC's session cookies are created at the start of navigation or by completing our online registration or request for information forms. The information you supply on these forms and the related session cookie are destroyed once you close your web browser or once there has been a period of 60 minutes of inactivity at the BDC's site.

Persistent cookies are written or stored on your hard drive until the expiry date. BDC's persistent cookies are used, for example, to retain information that you provided so that the BDC Web site can be personalized accordingly, or to determine if a certain user has previously completed one of our surveys, so that they will not be surveyed again.

BDC undertakes to ask your authorization before using any persistent cookies on the Site and to explain the purpose for which they are used.

The cookies used by the BDC are designed so they do not reveal any personal information on their own.

By accessing our site, you consent to the use of cookies and agree to have your browser set to accept cookies. If you want to access our site but don't agree to receive cookies, you can do so by modifying the preferences of your browser. However, note that by not accepting cookies, you may not be able to use all the features of our site.

6. Limiting collection, use, and disclosure of personal information
BDC will generally collect Personal Information about you directly from you. With your Consent, BDC may obtain Personal Information from third parties, including through credit checks, other lenders, or credit bureaus. We may also contact your employer or other personal references to verify information you have provided for identified purposes.

BDC will limit the type and scope of Personal Information it collects for use and disclosure according to the identified purposes. Except as outlined above, BDC will not disclose your Personal Information to anyone outside BDC without your Consent. BDC will exchange Personal Information with reputable reference sources and clearinghouse services for purposes of credit reporting, verification, and risk management. BDC will act in a fair and lawful manner with respect to your Personal Information.

BDC is subject to various legal and business requirements in dealing with document retention, including electronic documents such as e-mails. BDC will retain the Personal Information only for such periods of time as may be prescribed by applicable laws and regulations, as deemed necessary for the identified purposes, or to ensure you have a reasonable opportunity to obtain access. In accordance with legal requirements and applicable guidelines, BDC will destroy, erase, render anonymous, or otherwise dispose of Personal Information after such period of time.

7. Providing access and accuracy
Subject to legal requirements provided by the Privacy Act or the Access to Information Act, BDC will respect your right of access to your Personal Information by informing you of its procedures and requirements for responding to your request for access. BDC will act diligently to give you access, at minimal or no cost wherever possible. In certain exceptional circumstances, BDC may not be able to give you access to your Personal Information. For example, some Personal Information banks may contain references to other persons or to BDC's proprietary information, or be covered by solicitor-client privilege.

You can challenge the accuracy of your Personal Information and request corrections if you believe there are errors or omissions. You may also require in certain circumstances an annotation be attached to your Personal Information reflecting any correction requested but not made, or that such annotation or correction be notified to certain individuals.

BDC will take all reasonable steps to ensure Personal Information used on an ongoing basis is as accurate, up-to-date, and complete for the purposes in which it was collected; BDC will rely on you to inform it of any required corrections.

8. Responding to your privacy concerns
For questions or comments regarding this Policy, for additional information about the management of Personal Information at BDC, or to consult or modify your Personal Information, contact us by email, by phone at 1 877 BDC-BANX (232-2269), or by mail to Business Development Bank of Canada, 5 Place Ville Marie, suite 400 Montréal (Québec) H3B 5E7.

To file a privacy complaint concerning the collection, use, disclosure, retention, and disposal of or access to Personal Information, please contact our Ombudsman by email. Should we fail to resolve the complaint to your satisfaction, you or your authorized representative may contact the Office of the Privacy Commissioner of Canada.