Lendful Financial Ltd and its affiliates (“Company”, “we” or “us”) are committed to protecting your privacy and safeguarding your personal information. This Privacy Statement describes how we may collect, use and disclose your personal information. This Privacy Statement applies to any personal information we collect or receive about you, from any source. This Privacy Statement may be updated by Company giving reasonable notice of the revised terms (including by e-mail or by posting on our websites), and it may be supplemented or modified by your consent and/or agreements entered into with Company from time to time.
Personal information we may collect
“Personal information” in this Privacy Statement means information about an identifiable individual, as further defined in Canadian privacy laws. Examples of personal information that we may collect, use and disclose include your contact information (name, address, phone number, email address), your billing information (credit card number or banking information), purchase history, and other information that you may provide to us (such as date of birth and social insurance number which may be needed in connection with the purchase and fulfilment of certain of our products and services). Personal information does not include your name, business title, business address, and business telephone number in your capacity as an employee of an organization.
Collecting and Using Your Personal Information
When you open your account, and during the course of your relationship, we may collect personal and financial information from you including: your legal name, residential address, email address, phone number, date of birth, S.I.N, occupation, employment income, credit bureau information, banking information (name of your banking institution, transit and account numbers, account balance and transaction history), a photo of a government document issued to you, and a photo of your face that will be used to verify your identity, determine your credit responsibility and to evaluate and respond to your request for loan financing. Most of the information we collect is received directly from you and, with your consent, from third parties outside Lendful including from credit reporting agencies, other lenders, financial institutions, past and current employers, creditors and tenants, your spouse or persons authorized to act on your behalf under power of attorney, service providers, agents and other organizations with whom you or we conduct business, government agencies and public registries. You further authorize and consent to those third parties providing us with such personal and financial information. The decision to provide us with your personal information always rests with you. We may however, be limited in our ability to provide you with loan approval, if you decline to provide us with information essential to complete the credit approval process. We limit the collection of personal information to what we require in order manage our relationship with you including to: verify your identity and personal financial background; evaluate and process your application; determine your eligibility for products and services; communicate with you; deliver products and services to you that may benefit you; conduct research and generate statistics related to our business, products and services; for business purposes including data analytics, audits, developing, enhancing, improving or modifying our products and services; to help manage and assess our operations and risks; to protect you and us against error, risk, fraud and criminal activity; and to comply with applicable laws and regulatory requirements.
With respect to identity and income verification, we may do this as follows:
· We may obtain your credit file information from credit bureaus using your date of birth to ensure an accurate match between your personal information and your credit bureau information.
· We may retrieve, through one of our service providers, your bank account information (name of your banking institution, transit and account numbers, account balance and transaction history) to verify your income and identity.
· We may ask you to take a photo of: (1) your government issued identification that contains picture of your face; and (2) yourself (i.e., a “selfie”).
Our service provider will compare the biometric attributes of the face on your government identification document against the selfie that you submit, along with authenticating the other attributes of your government identification document, to verify your identity. Please note that our service providers do not keep this information after they have performed the identification exercise and have reported the results to us.
If you wish to be informed about what personal information we hold about you or if you want it to be removed from our systems, please contact us at privacyo[email protected] or refer to the “Protecting your Personal Information” section above.
Please note that if you seek to withdraw consent to our collecting and processing information that we must process to provide our services, we may not be able to provide those services to you. For example, you cannot withdraw consent to ongoing collection, use and disclosure of personal information needed in connection with administering a loan product you have purchased. Similarly, you cannot withdraw consent for us to collect, use or disclose information we need to carry out regulatory purposes.
Disclosing your Personal Information
We will not disclose, trade, rent or sell or otherwise transfer personal information for purposes other than those as set out herein, except with your consent or as required or permitted by privacy laws. We may share your personal information with our employees, potential lenders, mortgage insurers, debt collection agencies, as applicable; third party product and service providers retained by us to assist in providing you with services or to perform certain specialized services to assist us in our business including cloud-based service providers required for data processing, storage and to help manage your relationship with us. We take steps to ensure that any such service provider will provide a level of protection to your personal information comparable to that provided by us. Some service providers may be located outside of Canada where personal information may be subject to disclosure to governments, law enforcement and others pursuant to the laws of those jurisdictions. Where required by law, we may disclose personal information in response to a legally valid demand, enquiry, proceeding or other order. As we continue to grow, we may disclose your personal information in connection with a merger or sale involving all or part of our business or as part of a corporate reorganization.
Use and Disclosure of Non-Personal Information
Non-personal information is any information, other than personal information, that does not reveal your identity or directly relates to you as a person. Non-personal information may also include personal information we have de-identified or aggregated to the point where it no longer identifies a particular individual. At times, Lendful may make certain de-identified or aggregated non-personal information available to strategic partners and service providers that work with Lendful, to provide or support our or their products and services or that help Lendful or its strategic partners and service providers to conduct data analysis and develop and improve products and services. We reserve the right to use and share any such non-personal information with service providers for any lawful purpose. If we ever combine non-personal information with any personal information, we will obtain your consent and treat it as personal information.
Safeguarding your Personal Information
We protect personal information in our possession and control from loss, theft, alteration and misuse through physical, technical and organizational safeguards. Although we take precautions to protect your personal information from loss, theft, alteration or misuse, no system or security measure is completely secure. Any transmission of your personal data is at your own risk and we expect that you will use appropriate measures to protect your personal information as well.
All loans are subject to credit approval. Interest rate are indicative of individual qualifications and will vary upon your credit score, loan purpose and document verification. Interest rates and/or loan terms, when shown (or quote via form submissions) are not an approval or offer of credit.
Company may collect, use or disclose your personal information for secondary marketing purposes, such as sending you our newsletter or informing you about valuable offers and information that may be of interest to you. In most cases, we will obtain your express consent. In certain circumstances, consent may be assumed where we provide you with a readily exercisable means of telling us that you do not want your personal information used for such purposes (an ‘opt out’) and you do not exercise that option. In addition to any ‘unsubscribe’ or equivalent mechanism that may accompany our communications to you, you may withdraw or vary your consent regarding such marketing, at any time, by giving reasonable notice by telephone at 1.877.996.2233 or by contacting Lendful Customer Support by email or mail as indicated below (including your name and contact information).
Accuracy of your information
We use reasonable efforts to ensure that your personal information is as accurate, complete and up-to-date as necessary for the purposes for which such information was collected. However, you are responsible for advising us of any change in your contact information or other information necessary for us perform our obligations to you.
Retaining and safeguarding personal information
We retain personal information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. Typically, we will retain information only so long as necessary for Company and you to perform their obligations to one another, to comply with our obligations under applicable law, or for Company’s business or legal purposes. We have implemented physical, organizational, contractual and technological security measures to help protect your personal information from loss or theft, and unauthorized access, disclosure, copying, use or modification.
Cookies and website usage information
From time to time, we collect certain usage information from our servers that relates to the use of our websites, including but not limited to Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the website, the files visited, the time spent in each file, and the time and date of each visit. We use this information to improve our website, for example by enhancing pages or features that are visited frequently, and on occasion we may share this information with our affiliates or other third party companies to provide them with an indication of the amount of interest in our website for advertising purposes and to help us plan for technical improvements.
Accessing to your personal information
You may contact our Customer Support Manager in writing by email or mail to access to your personal information or to request modification or correction of inaccuracies in your personal information. To confirm your identity, we may ask you to provide additional personal information such as your name and contact information and the contract number of any contract you have with Company for the supply of a product or service. We will attempt to respond to your written request within thirty (30) days. We will advise you in writing if we cannot meet your request or access within this time limit.
You may contact our Privacy Officer in writing with any complaints you may have regarding your personal information. Within a reasonable time upon receiving the written complaint, we will conduct an investigation, respond to the complaint and take any measures that may be appropriate to address the complaint.
Our Privacy Officer is accountable for our compliance with this privacy statement and applicable privacy law. All comments, questions, concerns or complaints regarding your personal information should be forwarded to our Privacy Officer as follows: (a) in writing at Privacy Officer, Lendful Financial Ltd. 1400-888 Dunsmuir Street, Vancouver BC, V6C 3K4, (b) by telephone at 1-877.996.2233; or (c) by email at [email protected].