Effective date: September 29, 2026
Our Commitment to You
Clearwater Leasing Ltd. is committed to safeguarding your confidentiality, and protecting your personal information is our primary concern. This Privacy Policy describes our commitment to protecting your privacy and the personal information you disclose to us. If you do not agree with the use of personal information described in this Privacy Policy, please do not use this website and contact our office directly at 888-807-6166 or info@clearwaterleasing.ca.
The Collection and Use of Personal Information
To determine your creditworthiness, we may collect personal information directly from you, through your interactions with us, and from sources outside our organization, including government agencies and registries, law-enforcement authorities, public records, credit-reporting agencies, financial institutions, service providers, agents, organizations with which you have arrangements, and any other source with your consent or as permitted or required by law.
We may obtain information by telephone, in writing, electronically, or through your use of a product or service, or when you approach us to obtain information, make an inquiry, or apply for products or services. For legal entities such as businesses, partnerships, trusts, estates, or other organizations, we may collect information from each authorized person, partner, trustee, executor, owner, officer, director, guarantor, or representative, as appropriate.
We may collect identity and contact information, business and transaction information, financial and credit information, compliance and risk information, communications and service information, and website or technical information. This may include your name, title, address, email address, telephone number, date of birth, identification, business ownership, equipment and vendor details, requested amount, proposed lease terms, invoices, contracts, payment information, credit reports and scores, banking information, financial statements, tax information, assets, liabilities, income, and information about guarantors. We request a Social Insurance Number only when reasonably necessary and with appropriate consent.
We may use personal information for the following purposes:
- to establish, verify, and safeguard your identity;
- to service and improve the products and services you have with us;
- to assess your or your company’s eligibility, creditworthiness, affordability, fraud risk, and suitability for requested credit, leasing, or related services;
- to communicate with you about your inquiry, application, transaction, account, and other products or services that may be of interest to you;
- to match and submit transactions to lenders, funding partners, insurers, vendors, dealers, brokers, agents, referral partners, and other parties involved in arranging, approving, funding, administering, or servicing a transaction;
- to process transactions, maintain records, collect amounts owing, and manage our relationship with you;
- to meet anti-money-laundering, sanctions, tax, accounting, legal, regulatory, audit, and reporting obligations;
- to detect and prevent fraud and unauthorized or illegal activities;
- to operate, secure, troubleshoot, measure, and improve our website, services, and business processes; and
- to perform analytics and send marketing communications where permitted by law.
Consent and Your Choices
We obtain meaningful consent in a form appropriate to the sensitivity of the information and the circumstances. Consent may be express or implied where permitted by law. Certain collections, uses, or disclosures may occur without consent where authorized or required by law.
You may withdraw consent, subject to legal or contractual restrictions and reasonable notice. Withdrawal may limit our ability to provide a requested service, assess an application, or complete or administer a transaction. Credit applications and related forms may contain additional consents for credit reports, identity verification, lenders, funding partners, and other transaction parties. Those specific consents apply in addition to this Privacy Policy.
If you provide us with another person’s personal information, you are responsible for confirming that you have authority to provide it and that the person has received any notices and provided any consent required by law.
Automated Tools and Credit Decisions
We and our service providers or funding partners may use rules-based or automated tools to support identity verification, fraud screening, application processing, or credit assessment. A lender or funding partner may make its own independent credit decision under its own policies and privacy practices. Where required by law, you may ask our Privacy Officer for information about the use of automated decision systems in a decision affecting you and request that the decision be reviewed.
Sharing Your Personal Information
We do not sell or rent information about our customers. Your personal information is a vital part of our ongoing business relationship with you.
We disclose personal information only as permitted or required by law, including:
- to our employees, agents, service providers, lenders, funding partners, financial institutions, credit-reporting agencies, insurers, vendors, dealers, brokers, referral partners, and other entities that perform services for us or participate in a proposed or completed transaction;
- where the personal information forms part of an asset or business that we sell, assign, finance, reorganize, or otherwise transfer, subject to appropriate confidentiality and legal requirements;
- to protect and enforce the rights and property of Clearwater Leasing Ltd.;
- for credit assessment, identity verification, fraud prevention, security, and the reduction of fraud risk;
- to government, law-enforcement, regulatory, tax, court, or other authorities where permitted or required by law; or
- at your direction or with your consent.
We may use affiliates or other companies to provide services on our behalf, including data processing, hosting, data storage, account administration, document processing, electronic signatures, identity verification, communications, analytics, marketing, professional advice, and business administration. These companies receive only the personal information reasonably needed to perform their services and may use it only for those services or as otherwise permitted by law. We use contractual and other safeguards appropriate to the circumstances.
Processing Outside Your Province or Canada
Some of our service providers or transaction parties may process or store personal information in another province or outside Canada, including in the United States. Personal information may therefore be subject to the laws of those jurisdictions and may be accessible to courts, law-enforcement, national-security, or regulatory authorities in accordance with applicable law. Contact our Privacy Officer if you would like information about our use of service providers outside Canada.
Retaining Your Personal Information
We retain personal information only as long as reasonably necessary to fulfil the purposes for which it was collected and to meet legal, regulatory, tax, accounting, contractual, dispute-resolution, and legitimate business requirements. Retention periods vary depending on the product or service, the nature of the information, and the relationship.
A retention period may extend beyond the end of your relationship with us, but only for as long as reasonably necessary to manage issues that may arise later or to comply with applicable law, regulation, or guidance. When information is no longer required, we securely destroy, delete, or anonymize it, subject to permitted backup and archival practices.
Cookies, IP Addresses, Analytics, and Third-Party Services
Our website may collect Internet Protocol (IP) addresses and other technical information for system administration, security, fraud prevention, analytics, performance measurement, and to understand website use. We do not ordinarily link an IP address to personally identifiable information. However, we may use IP addresses and other technical information to identify website users where reasonably necessary to enforce our Terms of Use, comply with law, protect our services or website, or protect other users.
We use cookies and similar technologies to operate the website, remember preferences, understand traffic, measure performance, prevent abuse, and support advertising or marketing measurement. You can control cookies through your browser settings and, where available, our cookie controls. If you do not accept some cookies, your website experience may be diminished and some features may not function as intended.
Our website currently uses services that may include Google Analytics, Google Tag Manager, Google reCAPTCHA, and other analytics, advertising, or security technologies. These providers may collect or receive information from your browser or device and process it under their own privacy policies. Google reCAPTCHA helps protect our forms from spam and abuse and is subject to Google’s Privacy Policy and Terms of Service.
Safeguards and Security
Clearwater Leasing Ltd. uses administrative, technical, organizational, and physical safeguards appropriate to the sensitivity of the personal information. These safeguards are intended to reduce the risk of loss, theft, unauthorized access, disclosure, copying, use, modification, deletion, alteration, or destruction. Access to personal information is limited to employees and service providers with a business reason to know it. No method of transmission or storage is completely secure.
We assess suspected privacy and security incidents and take appropriate steps to contain, investigate, document, and remediate them. We will notify affected individuals and privacy regulators where required by applicable law.
Access, Correction, and Other Privacy Rights
Subject to applicable law, you may request access to personal information we hold about you, ask how it has been used or disclosed, and request correction of inaccurate or incomplete information. Depending on where you reside, you may also have rights relating to consent withdrawal, data portability, automated decisions, or complaints.
We may need to verify your identity before responding. Access may be limited where permitted or required by law, including where disclosure would reveal another person’s information, confidential commercial information, or information protected by legal privilege. If we cannot fulfil a request, we will explain the reason where required.
Marketing Communications
We send commercial electronic messages only as permitted by applicable law. You may unsubscribe using the link in an email or by contacting us. We may still send service, transaction, legal, or security communications that are not promotional.
Minors
Our commercial services and website are not intended for individuals under 18 years of age. We do not knowingly solicit or collect personal information from or about children under 18, and we do not knowingly market our products or services to children under 18.
Our Commitment Under Canadian Privacy Law
We are committed to meeting or exceeding the privacy standards established by Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial private-sector privacy laws. We follow the fair information principles reflected in PIPEDA to govern our collection, use, disclosure, safeguarding, retention, accuracy, openness, and handling of access requests and complaints.
Third-Party Websites
Our website may link to third-party websites or services. Their privacy practices are governed by their own policies, and Clearwater Leasing Ltd. is not responsible for their content or privacy practices.
Limitation of Liability
To the fullest extent permitted by applicable law, Clearwater Leasing Ltd., its directors, officers, employees, agents, and affiliates are not responsible or liable for indirect, incidental, consequential, special, exemplary, punitive, or other damages arising from or relating to this website, an inability to access this website, content on this website, or a third-party website linked from this website.
This limitation does not limit any rights or remedies that cannot lawfully be limited, including rights under applicable privacy legislation.
Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices, technology, or legal obligations. The current version will be posted on our website with its effective date. We will provide additional notice or obtain consent where required by law.
Privacy Officer and Complaints
The Privacy Officer for Clearwater Leasing Ltd. is responsible for administering this Privacy Policy and overseeing our privacy program. The Privacy Officer conducts ongoing privacy reviews, advises management on privacy matters, supports staff training, liaises with service partners so employees, contractors, and external agents understand their privacy obligations, responds to access and correction requests, handles questions and complaints, and administers our privacy dispute-resolution process.
Privacy Officer
Clearwater Leasing Ltd.
Mailing address: 23-845 Dakota Street, Suite 306
Winnipeg, Manitoba R2M 5M3
Email: info@clearwaterleasing.ca
Call/Text: 204-470-5447
Toll-free: 888-807-6166
We will investigate and respond to privacy concerns. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator.