Last modified: May 13, 2021
Do Finance Inc. (“Company” or “We”) respect your privacy and are committed to protecting it by complying with this policy.
This policy describes:
· How we collect, use, disclose, and protect the personal information of our customers and website users (“you”).
· Describes the types of information we may collect from you or that you may provide when you visit the website at www.dofinance.ca (our “Website”).
· Our practices for collecting, using, maintaining, protecting, and disclosing that information.
We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
This policy applies to information we collect, use, or disclose about you:
· On this Website (including through your loan application and any related forms).
· In email, text, and other electronic messages between you and this Website.
· Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
· When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
This policy DOES NOT apply to information that:
· We collect offline or through any other means, including on any other Company or third-party websites.
· You provide to or is collected by any third party, through any application or content (including advertising) that may link to or be accessible from or on the Website.
INFORMATION WE COLLECT ABOUT YOU
We collect and use several types of information from and about you, including:
· Personal information, that we can reasonably use to directly or indirectly identify you (e.g. your full name, date of birth, address, email address, Internet protocol (IP) address used to connect your computer to
the Internet, and user name or other similar identifier) (“personal information”).
Please note that we provide an opportunity for any user to unsubscribe or opt-out of contact for marketing and/or other purposes on an ongoing.
Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
· Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
· Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
· Direct interactions with you when you provide it to us, for example, by filling in forms (including online loan application(s) on our Website) or corresponding with us by phone, email, or otherwise.
· Credit Reports, for purposes of obtaining and disclosing information from relevant institutions such as banks, lenders, governmental authorities, credit agencies or other persons.
· Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
· Third parties in financial technology sectors or publicly available sources, for example, our business partners specializing in secured banking verification, automatic payment gateways and credit bureaus and/or your chosen provider.
INFORMATION YOU PROVIDE TO US
The information we collect directly from you on or through our Website and third-party affiliates may include:
· Information that you provide by filling in forms on our Website, including without limitation the information you provide by filling out loan application form(s), i.e. your full name, previous name (e.g. if changed by marriage or otherwise), date of birth, marital status, driver’s license information, home address, mailing address, email address, home and mobile telephone number, fax number, employment status and income, type of income, net monthly income, next pay date, frequency of payment, information regarding any existing loans (e.g. name of borrower, reason for loan, and outstanding amount of loan), details regarding spousal or child support payments, details regarding having ever been declared bankrupt, insolvent, or undoing bankruptcy proceedings, banking information for purposes of obtaining pre-authorized payments, banking transactions for the purposes of underwriting loan applications, payment histories on existing and previously active trades, information concerning the relevant clinics and/or providers of elective medical or cosmetic procedures (e.g. name and contact information of clinic or provider, type of procedure and cost of procedure), and social insurance number.
· Information provided at the time of registering to use our Website, subscribing to our service, posting material and/or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
· Records and copies of your correspondence (including email addresses), if you contact us.
· Your responses to surveys that we might ask you to complete for research purposes.
· Your search queries on the Website.
You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”)
. Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/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 Contributions. Therefore, we cannot and do not guarantee that unauthorized
persons will not view your User Contributions.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
· Details of your visits to our Website, including [traffic data, location data, logs,] and other communication data and the resources that you access and use on the Website.
· Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical information that includes personal information and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
· Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
· Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
· To present our Website and its contents to you.
· To provide you with information, products, or services that you request from us.
· To determine and underwrite your eligibility for any of our loan offers.
· To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
· To provide you with notices about your account, including expiration and renewal notices.
· To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection (e.g. working with collection agencies to collect loans we’ve advanced) or to comply with legal requirements.
· To notify you about changes to our Website or any products or services we offer or provide though it.
· To improve our Website, products or services, marketing, or customer relationships and experiences.
· To allow you to participate in interactive features, social media, or similar features on our Website.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
· To coordinate payment for procedures performed by clinics and/or providers of elective medical or cosmetic procedures, as required and with your consent.
· To obtain credit reports from institutions such as banks, institutional lenders, governmental authorities, credit agencies and/or other persons, as required and with your consent.
· To register security in connection with the loan, if applicable and with your consent.
· To our subsidiaries and affiliates.
· In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Do Finance Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Do Finance Inc.’s about our customers and users is among the assets transferred.
· Without restricting the generality of any of the foregoing, to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
· To fulfill the purpose for which you provide it.
· For any other purpose disclosed by us when you provide the information.
· With your consent.
We may also disclose your personal information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Do Finance Inc. , our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.
By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
· Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form where we collect your information. You can also opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to firstname.lastname@example.org.
· Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to email@example.com If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
· Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by [OPT-OUT METHOD]. For this opt-out mechanism to function, you must have your browser set to accept browser cookies.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada [link]. You can also access these websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
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.
SITE VISITORS UNDER THE AGE OF 18
Our Website is not intended for visitors under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from anyone under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a user under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a user under 13, please contact us at firstname.lastname@example.org.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
You can review and change your personal information by logging into the Website and visiting your account profile page.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at email@example.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
· Information protected by solicitor-client privilege.
· Information that is part of a formal dispute resolution process.
· Information that is about another individual that would reveal their personal information or confidential commercial information.
· Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact our department at firstname.lastname@example.org.
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at email@example.com. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
DO FINANCE INC.
Suite 200 – 99 Yorkville Ave.
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.