Last updated April 10, 2023
“Personal Information” is information that identifies you or could be combined by the Company or the Company’s services providers or affiliates with other information to identify you.
TYPES OF PERSONAL INFORMATION COLLECTED
The Company offer users with a business user account and connections to lenders through a centralized platform, simplifying your application process. The Personal Information the Company collects about you will depend on the manner in which you access or use the Web Services or any content on or through the Web Services (including whether you create an account and whether you fill and submit an application) and may include information you provide directly (e.g. through a form or email that is sent to us) and information that is collected by us (e.g. through observation of your web-browsing behaviour):
• Business details, including your business name, constating documents, address, trade name, type of business, industry, URL, date of incorporation/formation, business start date, business model, type of business, industry, revenue and credit score;
• Details about the ownership of your business, including your owner’s (or owners’) name (s), title(s), date(s) of birth, ownership %, address(es), SIN/SSN(s), phone number(s), email(s) and credit bureau/monitoring/rating information, including credit score(s) and account details;
• Financial information, including the amount of funds you are requesting, intended use of funds, timing of funding requirements, and any additional information reasonably requested to complete your account or application(s);
• Account formation information, including a login name, email, and a password, and other information related to your business user account that we may require from time to time (the information you provide when creating a business user account is collectively called your “Account Details”). When creating a business user account, you agree to provide correct, current, and complete Account Details, and to promptly update your Account Details if any information changes – for example, if you change your email address; and
• Information about the devices you use to connect to and interact with the Website and Web Services;
Collectively, your “Provided Information”
The Web Services (including any content provided on or through the Web Services) are not directed to any person who is not the legal age of majority under applicable law. The Company will not knowingly collect Personal Information from any person who is not the legal age of majority under applicable law.
METHODS FOR COLLECTING PERSONAL INFORMATION
How Information is Directly Provided to the Company by You
Personal Information the Company collects from you on or through the Web Services and as a result of your access to or use of the Web Services or any content accessed on or through the Web Services may include Personal Information you provide the Company directly, for example by:
Any User Generated Content that is published or displayed by you on the Website is posted on and transmitted to others at your own risk. Although we limit access to certain pages and/or you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Generated Content. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Generated Content.
How Information is Collected by the Company Through Technological Means
We may collect some information, including Personal Information, automatically, including when the Company uses your Provided Information, scans your government-issued ID, connects to your bank accounts or to credit bureau/monitoring/rating accounts using your Provided Information, including during the account creation process. We may maintain or associate your Provided Information with Personal Information we collect in other ways, that you provide to us, or that we receive from third-parties. We may use this Personal Information in the manner set out below under the section entitled “Using and Disclosing Personal Information”.
This information also helps the Company improve the Web Services and the content available on or through the Web Services and otherwise improve the services of the Company by:
USING AND DISCLOSING PERSONAL INFORMATION
Use of Personal Information by the Company
The Company collects Personal Information to provide you with a secure, smooth, efficient, and customized experience through or on the Web Services or any content on the Web Services. The Company may use your Personal Information to:
The Company may combine all the Personal Information the Company collects, including yours, in order to analyze and understand aggregate trends.
The Company may also transfer your Personal Information to third-parties that assist the Company with the use of Personal Information described in “Use of Personal Information by the Company”, above, such as data centers, or email service providers. Some third-parties may be located outside of Canada and may accordingly be subject to laws that are different from those in Canada.
In compliance with applicable privacy laws, some aggregated and/or de-identified information may be transferred to a third party without your further consent to facilitate a potential introduction.
The Company requires that all third-parties that the Company uses to deliver its Web Services that receive any Personal Information from the Company, except for Exported Information, use the same standards as the Company in using, maintaining, disclosing, and protecting Personal Information.
The Company may also share aggregated, non-personally identifiable information publicly to show trends about the general use of the Web Services, or any content, services, or products provided on or through the Web Services.
Other Disclosures of Personal Information
The Company may transfer information about you, including Personal Information, in connection with a merger or sale (including any transfers made as part of an insolvency of bankruptcy proceedings) involving all or part of the Company’s business or as part of a corporate reorganization or stock sale or other changes in corporate control.
ACCESS AND CORRECTION
The Company will provide you with access to your Personal Information in accordance with applicable privacy legislation, and may decline to provide you access to your Personal Information on the basis that such Personal Information is:
Where the Company is unable to provide you with access to your Personal Information, reasons will be provided, subject to any legal or regulatory restriction.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
The Company strives to provide you with choices regarding the Personal Information you provide to us. The Company has created mechanisms to provide you with the following control over your information:
1. You may decline to complete any applications, surveys or forms during your use of the Web Services.
2. You may provide or decline to provide your consent to any Company request for information.
The security of your Personal Information is important to the Company. The Company protects your Personal Information by maintaining physical, organizational, and technological safeguards (including, in some cases, private key encryption) against unauthorized access, unauthorized disclosure, theft, or misuse appropriate to the sensitivity of such Personal Information. Personal Information collected by the Company may only be accessed by persons within the Company who require access to provide you with access to, use of, or content, services, or products provided on or through the Web Services. The Personal Information the Company collects is maintained within databases located in Canada.
The safety and security of your information also depends on you. Where the Company has given you (or where you have chosen) a password and/or private encryption key for access to certain parts of our Web Services, you are responsible for keeping this password and/or private encryption key confidential. The Company asks you not to share your password and/or private encryption key with anyone.
Although the Company takes precautions against breaches of or unauthorized access to your Personal Information, no company can fully eliminate the risks of such breaches or unauthorized access and no website is completely secure. The Company cannot guarantee that unauthorized access, hacking, data loss, or breaches of the Company’s security systems will never occur. Accordingly, you should not transmit Personal Information to the Company by any means if you consider that Personal Information to be sensitive.
Except as otherwise permitted or required by applicable law or regulation, the Company retains Personal Information that it collects only as long as necessary for the purposes for which such Personal Information was collected. The Company reserves the right to use anonymous and de-identified information, including anonymized or otherwise de-identified Personal Information, for any legitimate business purpose without further notice to you and without your Consent.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
If applicable to you, this means the Company’s collection, use and disclosure of Personal Information shall be in accordance with the CCPA, and, among other things:
• You have the right to have the Company delete the Personal Information the Company has collected from you by emailing us at firstname.lastname@example.org.
• You may opt out of the sale of your Personal Information by emailing us at email@example.com.
• You have rights under the CCPA to ask the Company for records of Personal Information collected (including how), how Personal Information was used (including reasons), and how Personal Information was shared (including with whom) by the Company in the past 12 months by emailing us at firstname.lastname@example.org.
• The Company shall not discriminate against you for exercising any of your rights under the CCPA.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
Boundless Privacy Officer
27 Bathurst Street, Unit 218W
Toronto, Ontario, Canada