PRIVACY POLICY

Last updated on February 28, 2017.

Overview

FlexFi Inc. (“FlexFi”, “we”, “us” or “our”) is committed to protecting the privacy of personal information of identifiable individuals who visit our website (the “Site”) and use our services (the “Services”). As used herein, “you” or “your” means anyone who accesses and/or uses the Site or Services.

Amendments to this Privacy Policy will be posted to the Site and will be effective when posted.  Your continued access to and use of the Site and Services following the posting of any amendment to this Privacy Policy shall constitute your acceptance of such amendment.

Consent and Information Collection and Use

As a user of our Site and Services, you may provide personal information to apply for a loan (“Loan Application”), for us to communicate with you, and for other purposes set out in this Privacy Policy.

In connection with a Loan Application for which you wish to be considered, you may provide us with your (1) name; (2) contact information (mailing address, telephone number, fax number, email address, etc.); (3) birthdate; (4) social insurance number; (5) current and past employment history (occupation, name of current and past employers, names and contacts of references, etc.); (6) education history; (7) financial situation (assets, liabilities, income, etc.); (8) number of dependants; (9) banking information (bank statements, account transaction history, etc.); and (10) contacts of reference.

We may collect personal information about you through your interactions with our representatives, from your employers, financial institutions and other third-party sources. We may also collect personal information from credit bureaus in order to verify your creditworthiness, from your contacts of reference to verify your identity and/or from skip tracing service providers to locate your whereabouts or serve you with documents.

By providing personal information to us, you voluntarily consent to the collection, use and disclosure of such personal information as specified in this Privacy Policy.  Without limiting the foregoing, we may on occasion ask you to consent when we collect, use, or disclose your personal information in specific circumstances.  Sometimes your consent will be implied through your conduct with us if the purpose of the collection, use or disclosure is obvious and you voluntarily provide the information.

We may use your personal information for the following purposes (this is not an exhaustive list):

  • verify your identity and other information provided by you with credit bureaus, financial institutions and other third parties;
  • administer and process your Loan Application;
  • evaluate and determine your eligibility for certain products and services offered by FlexFi or our network;
  • locate your whereabouts or serve you with documents;
  • collect a debt owed to FlexFi and/or its service providers;
  • communicate with you, including, without limitation, for the purpose of providing you with information about the Site, the Services and your Loan Application, or informing you of changes or additions to the Site, the Services and your Loan Application or of the availability of any other services we provide;
  • provide the Site and Services to you;
  • improve the quality of the Site and our business through polls, surveys and other similar feedback gathering activities conducted by FlexFi and/or third parties;
  • create, manage and control your account information, and to verify access rights to the Site;
  • assess service levels, monitor traffic patterns and gauge popularity of different features and service options of the Site;
  • enforce this Privacy Policy or our Terms of Use;
  • protect against fraud or error, and to respond to claims of any violation of our rights or those of any third parties;
  • respond to your requests for customer service;
  • protect the rights, property or personal safety of you, us, our users and the public; and
  • comply with applicable laws or as authorized by applicable laws.

We may occasionally communicate with you regarding our business, services and news. You have the option to not receive this information.  We provide an opt-out function within all email communications of this nature, or will cease to communicate with you for this purpose if you contact us and tell us not to communicate this information to you.  The only kind of these communications that you may not “opt-out” of are those required to process your Loan Application.

Disclosure and Third Party Suppliers

We will only share your personal information with third parties in accordance with your instructions or as necessary to provide you with a specific service or otherwise in accordance with applicable privacy legislation.  For instance, from time to time we may disclose or allow access to your personal information to credit bureaus, credit reporting agencies, skip tracing service providers and financial institutions. In addition, we provide your personal information to our third party communication service providers to communicate with you, including, without limitation, for the purposes of administering your outstanding loans with FlexFi.

We may transfer (or otherwise make available) your personal information to third parties who provide services on our behalf. For example, we may use service providers to host our website and store information on our behalf.  Your personal information may be maintained and processed by third party service providers in the United States or other jurisdictions and may be accessed by the courts, law enforcement and national security authorities as required under the laws of those jurisdictions.

As a general rule, we do not and will not sell and rent your personal information without first receiving your permission or as permitted in this Privacy Policy.

Age of Consent

We do not knowingly provide access to or use of the Site and Services to, and will not knowingly collect the personal information from anyone under the age of consent.

Rights to Your Information

You have the right to access your personal information that you provide to us at any time by contacting us.

Aggregated Data

We may use your personal information to generate Aggregated Data for internal use and for sharing with others on a selective basis.  “Aggregated Data” means records which have been stripped of information potentially identifying users, and which have been manipulated or combined to provide generalized, anonymous information.  Your identity and personal information will be kept anonymous in the Aggregated Data.

Links

The Site may contain links to other sites and we are not responsible for the privacy practices or the content of such sites.  We encourage you to read the privacy policy of linked sites.  Their privacy policies and practices may differ from our policies and practices.

Cookies and Log Files

We use cookies and log files to track user information.  Cookies are small amounts of data that are transferred to your web browser by a web server and are stored on your computer’s hard drive.  We use cookies to track which page variant a visitor has seen, to track if a visitor has clicked on a page variant, to monitor traffic patterns and to gauge popularity of service options.  We will use this information to deliver relevant content and services to you.

Change of Ownership or Business Transition

In the event of a change of ownership or other business transition, such as a merger, acquisition or sale of our assets, your information may be transferred in accordance with applicable privacy laws.

Security

We will strive to prevent unauthorized access to your personal information, however, no data transmission over the Internet, by wireless device or over the air is guaranteed to be 100% secure.  We will continue to enhance security procedures as new technologies and procedures become available.

Please remember that you control what personal information you provide while using the Site or Services. Ultimately, you are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of the Site. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them.

Contact Us

If you have any queries about the disclosure of your personal information or if you otherwise have any questions or suggestions regarding our Privacy Policy or wish to make a complaint, you may contact FlexFi by email at info@flexfi.ca or by mail at 1411 West Broadway, Vancouver, British Columbia V6H 1H6.