Privacy Policy

Introduction

Financeit Canada Inc. ("Financeit") is committed to keeping personal information accurate, confidential, secure and private. The Financeit Privacy Code is an embodiment of this commitment.

Following are the ten Principles that guide Financeit’s privacy practices. Click on any of the Principles below or scroll down to get more details.

The Scope Of This Privacy Code

This Privacy Code describes the principles Financeit will use to protect the privacy of personal information in its possession or control.
This Privacy Code does not apply to information about business customers who carry on business as corporations, partnerships or in other forms of association. Financeit does, however, protect the confidentiality of such information in accordance with the law and Financeit's own policies. This Privacy Code does apply to personal information of individual owners of sole proprietorships.

Changes To This Privacy Code

In order to ensure that this Privacy Code is kept up to date, we reserve the right to change this Privacy Code from time to time. Any changes will be effective 30 days following Financeit providing you with notice. Notice of changes to the Privacy Code may be distributed through Financeit e-statements, newsletters and/or posted on the Financeit website. If you access or choose to continue to be serviced by Financeit after the effective date of the change, you automatically accept the change.

Definition of Terms Used in this Privacy Code

Customer Service Representatives (CSR)

The client services representatives at Financeit to whom the public is encouraged to address their initial questions and concerns about any Financeit product or service. CSR’s may be reached by telephone at: 1.888.536.3025 or email at: service@financeit.io.

Financeit

"Financeit" is the operating name of Financeit of Canada.

Personal Information

Information about an identifiable individual, but does not include the name, title or business address or business telephone number of an employee of an organization for the purpose of communicating with the individual in relation to their work.

Privacy Office

The department at Financeit that is responsible for ensuring the protection of individuals' personal information. The Privacy Office may be contacted by mail at:

Privacy Office
Chief Privacy Officer
Financeit Canada Inc.
500 - 296 Richmond Street West
Toronto, Ontario, M5V 1X2

1-888-536-3025
service@financeit.io

The Ten Principles of Privacy in Summary

These ten principles of privacy are interrelated and must be read in conjunction with the accompanying commentary.

1. Financeit's Accountability

Financeit is accountable for all personal information in its possession or control, including any personal information transferred to third parties for processing. Financeit has established policies and procedures to comply with this Privacy Code, and has designated one or more persons accountable for compliance.

2. Identifying The Purposes Of Collecting Personal Information

Financeit will inform individuals of the purpose for which personal information will be used before or when they consent to its collection.

3. Obtaining Consent

Financeit will obtain consent before or when it collects, uses or discloses personal information about an individual.

An individual can provide consent to the collection, use and disclosure of personal information about them expressly, implicitly, or through an authorized representative. An individual can withdraw consent at any time, with certain exceptions.

Financeit will collect, use or disclose personal information without an individual's consent only in limited circumstances as permitted by law.

4. Limits For Collecting Personal Information

Financeit limits the amount and type of personal information it collects. Financeit will collect personal information only for the identified purposes or as otherwise permitted by law.

5. Limits For Using, Disclosing And Keeping Personal Information

Financeit will use or disclose personal information only for the reasons it was collected, unless an individual gives consent to use or disclose it for another reason. Under certain circumstances, Financeit may have a legal duty or right to disclose personal information without consent.

Financeit will keep personal information only as long as necessary for the identified purposes.

6. Keeping Personal Information Accurate

Financeit will keep the personal information in its possession or control accurate, complete, current and relevant, based on the most recent information available to Financeit.

Individuals may challenge the accuracy and completeness of personal information about them and have it amended as appropriate.

7. Safeguarding Personal Information

Financeit protects personal information with safeguards appropriate to the sensitivity of the information.

8. Making Information About Policies And Procedures Available

Financeit will be open about the procedures used to manage personal information. Individuals will have access to information about these procedures through this Privacy Code, by contacting our CSR’s or by contacting the Privacy Office. The information will be available in a format that is easy to understand.

9. Providing Access To Personal Information

When an individual requests it, when possible, Financeit will advise the individual what personal information Financeit has in its possession or control about the individual, what it is being used for, and to whom it has been disclosed.

When an individual requests it, Financeit will give an individual access to personal information about them which is in the possession or control of Financeit. In certain situations, however, Financeit may not be able to give individuals access to all of their personal information.

10. Handling Complaints And Questions

Individuals may challenge Financeit's compliance with this Privacy Code. Complaints and inquiries should be directed to our CSR’s or sent to the Privacy Office.

Principle 1

Financeit's Accountability

Financeit is accountable for all personal information in its possession or control, including any personal information transferred to third parties for processing. Financeit has established procedures to comply with this Privacy Code, and has designated one or more persons to be accountable for compliance.

  1. Senior management of Financeit will have ultimate accountability for protecting personal information. Senior management has delegated the day-to-day management of procedures involving personal information protection to one or more persons.
  2. Financeit's Privacy Office is responsible for overall personal information protection and Financeit's compliance with this Privacy Code. In addition, CSR’s are able to respond to most inquiries about the protection of personal information.
  3. Financeit will allow the following categories of Financeit employees to access individuals' personal information in Financeit's control: Sales and Service Personnel; Finance Personnel; Security Personnel; Audit Personnel; IT Personnel; Operations Personnel; Legal and Compliance Personnel; Risk Management Personnel; and Credit and Lending Personnel.
  4. Financeit is also accountable for personal information that has been transferred to a third party for processing. Financeit's policies for safeguarding personal information transferred to third parties are set out in sections 7.4 and 7.5 of this Privacy Code.
  5. To practice the principles of this Privacy Code, Financeit:
    • has established procedures to protect the privacy of personal information;
    • has established procedures to receive and respond to questions and complaints;
    • gives the public access to this Privacy Code; and
    • has trained Financeit staff to understand and follow Financeit's privacy procedures.

Financeit also oversees compliance with this Privacy Code through regular audits and other compliance procedures.

Principle 2

Identifying The Purposes of Collecting Personal Information

Financeit will identify the purposes of collecting personal information, before or when consent is provided.

  1. Except as noted below, when an individual applies for a product or service,
    • Financeit will make the individual aware of the purposes for which Financeit is requesting the personal information.
    • If Financeit identifies other purposes for which the personal information may be used, Financeit will seek the individual's consent prior to starting these uses.
    • Financeit will explain that it is the individual's right to refuse permission for Financeit to use personal information for any such other purposes.
    • In some cases Financeit will not explain those purposes or obtain the individual's consent. (See section 3.4 and section 5.1 for details).
  2. Financeit will clearly identify the purposes for which it is collecting personal information in writing, verbally (either in person or over the telephone), or by any other means it communicates with individuals.
  3. Individuals can ask for information about the purposes for which Financeit collects personal information when they phone Financeit, or write to the Privacy Office.
  4. Unless additional purposes are identified to an individual before or at the time of collection, Financeit will collect personal information (which may include credit, employment and other financially related information) for the following purposes:
    • to help identify new clients
    • to set up and manage products and services that meet an individual's needs;
    • to offer products and services to meet those needs;
    • to provide ongoing service; and
    • to meet legal and regulatory requirements, such as requirements under the Income Tax Act and credit reporting requirements.
  5. Financeit takes care to explain purposes which are not as obvious as others. The purposes for collecting a name or address are obvious and do not need to be explained, but the purposes for collecting other information may not be as self-evident.

Financeit may collect, disclose and use personal information for some or all of the following purposes:

Principle 3

Obtaining Consent

Financeit will obtain consent before or when it collects, uses or discloses personal information about an individual. An individual can provide consent to the collection, use and disclosure of personal information about them expressly, implicitly or through an authorized representative.
Financeit will collect, use or disclose personal information without an individual's consent only in limited circumstances as permitted by law.
Subject to certain legal and contractual restrictions and reasonable notice, an individual can refuse or withdraw their consent to the collection, use or disclosure of personal information about them at any time.

  1. Financeit will obtain consent before or when it collects, uses or discloses personal information. Generally, Financeit will seek consent to use and disclose personal information at the same time it collects the information. In some circumstances, Financeit may identify a new purpose and seek consent to use and disclose personal information after it has been collected.
  2. Financeit will explain to individuals in plain language how personal information will be used or disclosed before they give their consent.
  3. Consent to the collection, use and disclosure of personal information can be expressed, implied, or given through an authorized representative of the individual.
    • Individuals can express consent verbally, such as when information is collected over the telephone, in writing, such as when completing and signing an application, or electronically, such as when applying through a computer.
    • Individuals can imply their consent, for example, by using an Financeit product or service. In such a case, Financeit may assume that the individual consents to the use of the personal information.
  4. Financeit may collect, use or disclose personal information without the individual's knowledge and consent only in limited circumstances as permitted by law. For example,
    • Financeit may collect, use and disclose personal information without the individual's knowledge or consent if it is clearly in the individual's best interests to do so and consent can not be sought in a timely manner. An example of such a circumstance is when an individual is seriously ill.
    • Financeit may collect, use and disclose personal information without individuals' knowledge or consent in certain circumstances where the information is publicly available. An example would be the name, address and phone number of a subscriber to a telephone directory that is available to the public where the subscriber can refuse to have their personal information appear in the telephone directory.
    • Financeit may collect, use and disclose personal information without the individuals' knowledge or consent in accordance with law or upon the lawful request of a government institution or part of a government institution. An example would be when a government institution lawfully requests the information for the enforcement of any law of Canada, a province or a foreign jurisdiction.
  5. Subject to certain legal or contractual restrictions and reasonable notice, an individual may refuse or withdraw consent at any time.
    • Financeit will inform individuals of the consequences of refusing or withdrawing consent when individuals seek to do so. Refusing or withdrawing consent for Financeit to collect, use or disclose personal information could mean that Financeit cannot provide the individual with a product, service or information of value to the individual.
    • For example, if an individual does not allow Financeit to obtain a credit history report, Financeit may not be able to lend money to the individual due to prudent lending practices, or other regulations.
    • Financeit, however, will not unreasonably withhold products, services or information from individuals who refuse to give consent or who withdraw consent.
    • Financeit is required by law to collect certain types of personal information in order to verify the identity of its clients. If an individual does not allow Financeit to collect and use this information, or if the client later attempts to withdraw their consent, Financeit may not be able to open an account or maintain the account on behalf of that client.
    • Withdrawal of consent is not permitted in relation to a credit product where Financeit must collect and report information after credit has been granted. This is to maintain the integrity of the credit system.
    • Financeit will not deny credit to an individual solely because the individual does not provide a SIN for this purpose.

Principle 4

Limits On The Collection Of Personal Information

Financeit limits the amount and type of personal information it collects. Financeit will collect personal information only for purposes it has already identified to the individual or as permitted by law. Financeit will collect personal information using procedures which are fair and lawful.

  1. Financeit will collect only the amount and type of information needed for the purposes documented by Financeit and identified to the individual.
  2. Financeit will collect personal information about an individual primarily from that individual. Except as permitted by law, Financeit will only collect personal information from external sources if individuals have consented to such collection.

Principle 5

Limits On Using, Disclosing And Keeping Personal Information

Financeit will use or disclose personal information only for the reasons it was collected, unless consent is given to use or disclose it for another reason.

Under certain exceptional circumstances, Financeit may have a legal duty or right to disclose personal information without the individual's knowledge or consent.

Financeit will keep personal information only as long as necessary for the identified purposes.

  1. Financeit may disclose personal information without consent when required or permitted by law. Examples of such disclosure include:
    • Subpoenas, search warrants and other court and government orders;
    • debt collection or demands from other parties who have a legal right to personal information; and
    • disclosure of personal information to a lawyer (or, in Quebec, a notary or an advocate) who represents Financeit.
  2. In any of the circumstances referred to in Principle 5.1, Financeit will protect the interests of its clients by making sure that:
    • orders or demands appear to comply with the laws under which they were issued, and
    • Financeit does not comply with casual requests for personal information from government or law enforcement authorities.
    • When permitted by law, Financeit may notify individuals that an order or demand has been received. Financeit may notify individuals by telephone, or by letter to the client's usual address.
  3. Financeit may want to use personal information in its possession or control to market products and services to individuals, either directly through Financeit or through its existing subsidiaries or affiliates or approved network of Independent Merchants. Financeit will obtain the individual's consent before using or disclosing personal information for this purpose.

    When an individual applies for a product or service and provides personal information, Financeit will advise the individual that his/her personal information may be used by Financeit to market other products and services to the individual.
  4. If personal information has been used to make a decision about an individual, Financeit will keep the personal information long enough for the individual to have access to it after the decision has been made.
  5. Personal information and non-personal information that an individual submits to Financeit may be transferred to, proceed on, and/or stored on, some of Financeit’s service vendors’ servers, which may be located outside of Canada.
    • In the event that a service vendor is located outside of Canada, the personal information on file may be processed and stored outside Canada, and foreign governments, courts of law enforcement or regulatory agencies may be able to obtain disclosure of this information.
    • In the event that a service vendor is located in the United States, the personal information on file may be processed and stored in the United States, and the United States governments, courts of law enforcement or regulatory agencies may be able to obtain disclosure of this information through the laws of the United States.
  6. Financeit will destroy, erase or make anonymous any personal information no longer needed for its identified purposes or for legal requirements

Principle 6

Keeping Personal Information Accurate

Financeit will keep the personal information in its possession or control accurate, complete, current and relevant, based on the most recent information available to Financeit.

Individuals may challenge the accuracy and completeness of personal information about them and have it amended as appropriate.

  1. Financeit will make reasonable efforts to minimize the possibility of using inaccurate, incomplete or outdated personal information to make a decision about the individual.
  2. Financeit will update personal information only if it is necessary for the purposes for which it was collected.
  3. Financeit will make reasonable efforts to keep personal information in its possession and control accurate and current if the information is used on an ongoing basis, unless limits on the need for accuracy are clearly set out by Financeit.
  4. Financeit will also rely on individuals to keep certain personal information relating to them accurate, complete and current. If an individual demonstrates to Financeit that personal information relating to them is inaccurate, incomplete, out of date or irrelevant, Financeit will revise or delete the personal information. If necessary, Financeit will disclose the revised personal information to any third parties to whom Financeit disclosed wrong or outdated information in order to permit them to revise their records.
  5. If Financeit does not agree to revise personal information as requested by the individual, the individual may challenge Financeit's decision. Financeit will make a record of this challenge, and, if necessary, disclose the challenge by the individual to any third parties to whom Financeit has disclosed the personal information.

Principle 7

Safeguarding Personal Information

Financeit will protect personal information with safeguards appropriate to the sensitivity of the information.

  1. Financeit will safeguard personal information in its possession or control from loss or theft and from unauthorized access, disclosure, duplication, use or modification.
  2. The safeguards employed by Financeit to protect personal information will vary depending on the sensitivity, amount, distribution, format and storage of the personal information. Financeit stores much of your information electronically. Recent paper records containing individuals' personal information are stored in files kept onsite at our Toronto head office or offsite though our secure data centre, and older records containing individuals' personal information may be stored at an offsite storage facility. Financeit will give the highest level of protection to the most sensitive personal information.
  3. Financeit will safeguard personal information in its possession or control through security measures. For example:
    • physical security, such as secure locks on filing cabinets and restricted access to offices;
    • organizational security, such as controlled entry in data centres and limited access to relevant information; and
    • electronic security, such as passwords, personal identification numbers and encryption.
  4. Financeit may disclose personal information to businesses such as credit bureaus, credit insurers and lenders with the individual's consent. Financeit relies on the added protection of credit reporting legislation to ensure that credit bureaus protect personal information which is disclosed to them.
  5. Financeit will use care when disposing of or destroying personal information in order to prevent unauthorized access to the information.

Principle 8

Making Information About Policies And Procedures Available To Individuals

Financeit will be open about the procedures used to manage personal information. Individuals will have access to information about these procedures through Financeit's Privacy Code, by contacting our CSR’s or by writing to the Privacy Office. The information will be available in a format that is easy to understand.

  1. Financeit will make this Privacy Code available to the public.
    • Copies of this Privacy Code will be provided to all new clients; and/or
    • An electronic version of this Privacy Code is available on Financeit's website at www.financeit.io/ca/en.
  2. Information about this Privacy Code will be available in a format that is easy to understand.
    • Financeit has produced a summary of this Privacy Code. The summary is available at the beginning of this document.
    • The contact information of the CSR’s and the Privacy Office are provided in the summary as in this Privacy Code, so individuals know where to address complaints and questions about Financeit's personal information policies and procedures.
  3. Financeit may make information about its procedures available in a variety of ways, depending on the nature of the services individuals are using and the sensitivity of the personal information.
    • Financeit may mail, or email information to its clients, establish a toll-free telephone service or provide on-line access.

Principle 9

Access To Personal Information

When an individual requests it, Financeit will advise what personal information Financeit has in its possession or control about the individual, what it is being used for and to whom it has been disclosed.

When an individual requests it, Financeit will give the individual access to personal information about them which is in the possession or control of Financeit. In certain exceptional situations Financeit may not be able to give individuals access to all of the personal information about them.

  1. An individual has the right to know, on request, what personal information about the individual Financeit has in its possession or control, a right to access that personal information and to know to which third parties Financeit has disclosed that information. Individuals may direct their requests by telephone to the CSR or, in writing, to the Privacy Office.
  2. Financeit has established procedures for responding to requests for access to personal information. Financeit will respond to requests within a reasonable period of time. Individuals must be specific about the personal information that may be in Financeit's possession or control. In the unlikely event that Financeit determines that there will be a cost to the individual in granting such access, Financeit shall inform the individual of the costs permitted by law prior to granting such access.
  3. Financeit will identify from whom it collected the personal information, to whom it has disclosed the personal information, and how and when the information was disclosed. Financeit will take this data from its records, and will provide it to the individual.
  4. In some cases, Financeit may not provide access to personal information that is in its possession or control. For example, this may occur when:
    • providing access to personal information would be likely to reveal personal information about a third party;
    • providing the personal information could result in a threat to the security of another individual;
    • disclosing the information would reveal confidential commercial information;
    • the personal information is protected by solicitor-client privilege;
    • the information is the result of arbitration or other formal dispute resolution process; or
    • the information has been collected for the purposes of a legal investigation.
  5. Financeit will not record in individual files when personal information was disclosed to third parties for routine purposes. For example:
    • regular updating of credit information to credit bureaus
    • indicating to third parties when cheques are returned for NSF (not sufficient funds)
  6. If Financeit denies the individual's request for access to personal information, Financeit will advise the individual of the reason for the refusal. The individual may then appeal Financeit's decision to the Privacy Commissioner of Canada.

Principle 10

Handling Individuals' Complaints And Questions

Individuals may challenge Financeit's compliance with this Privacy Code. Financeit has policies and procedures to receive, investigate, and respond to individuals' complaints and questions.

  1. Financeit has policies and procedures to receive, investigate, and respond to individuals' complaints and questions relating to privacy. Individuals are advised to direct their complaints and questions by telephone to the CSR or in writing to the Privacy Office.
  2. Financeit will investigate all complaints. If it finds a complaint justified, Financeit will attempt to resolve it. If necessary, Financeit will modify its policies and procedures to ensure that other individuals will not experience the same problem.
  3. If individuals are not satisfied with the way Financeit has responded to their complaint, they can contact the Privacy Commissioner of Canada.

Other Important Information

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