Privacy Policy

This Privacy Policy (this “Policy“) is effective as of December 1, 2021.

In this statement, the words “Lendhub”, “we”, “our”, the “Company”, and “Business” refer to Lendhub and shall include all parent, predecessor, successor and affiliated or related companies of Lendhub. The words “you” and “your” refer to our customers, prospective customers, Dealers or prospective Dealers, and anyone who visits our website, engages with our services and otherwise provides personal information to Lendhub.

The phrases “information” and “personal information” mean any factual or subjective information about an identifiable individual, but does not include business contact information used solely for the purpose of communicating or facilitating a communication with an individual in relation to their employment, business, or profession. Examples of personal information include (but are not limited to): age, name, ID numbers, income, ethnic origin, credit records, loan records, and existence of a dispute with a merchant.

Introduction

Thank you for visiting Lendhub’s website. Your privacy is important to us. This Policy explains our information practices and the choices you can make about the way your information is collected and used. If you have any questions, do not hesitate to contact us using the information set out in Section 11 entitled “Customer inquiries & CPO contact”.

What information we collect

Lendhub collects the Personal Information we need for the purposes stated in this Policy and as otherwise permitted or required by law. We may collect the following types of Personal Information about you:

Identification and contact details, such as name, date of birth, marital status, contact information (e.g. address, telephone number, and email address), passport (optional), driver’s license, Social Insurance Number (optional), immigration forms, permanent residency forms, certificate of Indian status, Canadian Institute for the Blind ID card, other governmental identification information, and information relating to dependents;
Employment information such as your employer name, employment references, employment history, occupation, work permits, job title, and current and past income;
Financial information such as your bank name, account and transit numbers, credit history, sources of wealth, assets, liabilities, transaction history, financial relationships, information related to insurance policies including coverage and claim information, personal references; and
Information about your past interactions with us and our affiliates.

Why we collect and use your information

We may use your information for the following reasons:

To assess and verify your eligibility (including creditworthiness) for our products and/or services;
If eligible, to provide you with our products and services, and to improve our quality of service and minimize any disruption to the products and services that we may offer you;
To satisfy any contractual arrangements we may have with you;
To confirm your identity;
To directly or indirectly communicate with you about our products and services and related offerings (to opt out of this, please see section 9 below for details);
To promote or market our services and those of our affiliates (to opt out of this, please see section 9 below for details);
To make referrals to affiliates and non-affiliated organizations for other services we reasonably believe you may be interested in (to opt out of this, please see section 9 below for details);
To provide your information to third-party service providers and to applicable credit reporting agencies, credit bureaus, automobile or other asset insurer or aggregator in connection with products or services that you have requested;
To process your information with your consent;
To manage our risks and operations;
To protect you from unauthorized access or identity theft;
To conduct credit and insurance investigations;
To create anonymous, aggregated and de-identified information that may be used for business purposes;
To establish, exercise or defend legal claims or proceedings;
To comply with our legal, regulatory, audit, risk assessment, processing, and security obligations under applicable laws;
To comply with “know your customer” obligations based on applicable anti-money laundering and anti-terrorism requirements, customer due diligence, or other similar laws or regulations;
To aid in the detection, prevention or suppression of fraudulent or criminal activity; and
For other purposes required or permitted by applicable laws and regulations.

Meaningful consent

We believe in meaningful consent. Providing us with your information is always your choice; however, withholding consent may in some instances mean that we cannot provide you with the services or products you are requesting. In some cases, we may assume consent when you provide your information directly to us and we use that personal information to purposes reasonably connected to what you’ve asked us to do (for example, when you request a product or service we provide, or when completing a transaction). Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to our use, collection and disclosure of your personal information in accordance with this Policy.

You can always retract your consent. If you retract your consent, we will respect your choice, subject to our right to continue to use your information to fulfil our contracts with you, collect debts, or otherwise as permitted or required by applicable laws and regulations.

In some limited situations, we may collect and use your information without your consent as permitted or required by law. For example, we may be legally required or permitted to disclose information for our protection (such as collection and fraud prevention) or the protection of other’s rights and interests without consent, and otherwise to comply with law, regulations or regulatory authority.

How we collect your information

Most of the information is collected when you engage with us and our products and services. For example, we collect information when you:

Submit an application for our products, including supporting documentation;
Communicate with us, whether verbally or in writing;
Use our website, software, or other applications (through cookies, which are files that reside on your computer and contain information about your browsing history);
Engage with us through social media such as posting a review, making a comment, or otherwise submitting personal information on a public forum such as our social media accounts or other public forums found on our website or other applications;
Open and operate an account with us;
Call our customer service lines or email our customer service department;
In the course of providing our services, we may also collect financial and other information about you from third parties, including:
- - Credit reporting agencies;
  - Third-party verification services; and
  - Merchants from whom you have purchased goods or services and in respect of which you have applied for credit from us.
If you provide information about a third party or authorize a third party to do so, we will assume you have taken proper measures to obtain informed consent.

How we use your information

We may use your information for the purposes stated above in Section 3, or the purposes communicated to you at the time of collection or in your agreement(s) with us or as otherwise permitted or required by law. In specific cases, we may use your information to:

Verify your identity and authenticate you when you contact us;
Communicate with you through various channels including telephone, mail, email, web applications, or mobile applications;
Provide you with the products and services you’ve requested;
Assess your financial situation in order to determine your eligibility for the products and services we offer;
Send you information (with your consent) about other products and services that we offer, and related products and services that third parties may offer;
Conduct statistical analytics and predictive models for legitimate business purposes;
Marketing and advertising, including offering you promotional materials or other tailored content based on your interests;
Manage our risks and operations; and
Meet our regulatory and legal requirements.

When we share your information

We will not share personal information for any purposes other than the purposes listed in this Policy unless it is authorized by you or is otherwise permitted or required by law. Examples of when we may share personal information include sharing to:

Our parent, predecessor, successor and affiliated or related companies, contractors, and third-party service providers for the purposes of assessing creditworthiness and administering and granting our credit services;
Our business partners, for the purpose of offering you related products and services that may benefit you;
Our administrative and technical support providers for the purpose of servicing your account, including cloud storage providers or data analytics providers.
Our funding partners, for the purpose of providing information related to the credit services granted to you by us;
Third-party marketing and data processing agencies, for the purpose of engaging in marketing services and promotional activities, whether by email or otherwise (to opt out of this, please see section 9 below for details); and
Debt collection agencies and related entities, for the purposes of pursuing collection accounts owed to us.

If you believe a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.

The following are additional circumstances in which we may share your information with third parties. These include:

(a) Legal requirements

Subject to applicable law, we may disclose information if required or permitted to by law or regulation or in the good faith believe that such action is necessary to:

Comply with a legal obligation or in response to a request from public authorities or regulatory bodies to which we are subject;
- Protect and defend our rights or property;
  - Detect, prevent or report to law enforcement agencies fraud or other illegal activity;
  - Verify identity or conduct required due diligence;
  - Act in urgent circumstances to protect the personal safety of our workers/employees, our clients, or the public;
  - Protect against any legal liability; or
  - As permitted or required by law.

(b) Business transfers

From time to time we may sell, buy, restructure or reorganize our business or assets. In the event of any actual or proposed sale, merger, reorganization, restructuring, dissolution or any similar event involving our business or assets, personal information may be shared with the relevant entity or may be part of the transferred assets.

(c) Third-party programs

We may from time to time enter into contracts with third parties for programs that provide products and services to our clients

Safeguarding your information

It is important to us that your information is protected. We take the following steps to ensure that your information is safe, complete and accurate:

Physical measures, such as locked filing cabinets and restricted access to physical records;
Organizational measures, such as security clearances and limiting access on a need-to-know basis; and
Technological measures, such as securing information by means of data permissioning, passwords and encryption.

Despite all of the foregoing security measures, online storage and communicating online is never one hundred percent secured. We encourage all individuals to provide only the information they are comfortable with providing a third-party, to keep watch for communications that are suspicious, and to report any suspicious activity to us as soon as possible. We as a community can help keep us all safer.

(a) Accuracy

We make every reasonable effort to keep your personal information as accurate, complete and up-to-date as necessary. If desired, you may verify the accuracy and completeness of your personal information in our records. Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third-party, we will communicate relevant changes to the third-party where appropriate.

(b) Employee and third-party access

Your information can only be accessed by employees who have a valid business reason to do so. Our service providers and contractors are also contractually required to maintain the strict information security standards set out in this policy.

(c) Retention policy

We only retain information for as long as necessary for the purposes outlined in this Policy and as otherwise permitted by applicable laws and subject to record-keeping requirements imposed by applicable laws, regulations and business practices.

Opting Out

You may withdraw your consent for our use and collection of your personal information at any time, however this may limit our ability to provide services or administer our scholarship to you, if applicable.

To withdraw consent, please contact us at the contact information set out at the end of this Policy. Any withdrawal of consent will apply thereafter and not to information handling practice that have been previously undertaken based on prior consent.

You may opt-out of use of cookies through your browser settings. You can opt-out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page or the Network Advertising Initiative’s Opt-Out page

Your right to access your information

You may always access personal information we hold about you by submitting a written request to us via the contact information provided at the Section 11 entitled “Customer inquiries & CPO contact”. To enable us to obtain your information in a timely manner, you may be required to provide sufficient information to allow us to identify and authenticate you in order to provide the information you are requesting.

Please note that there may be instances where access to your information may be restricted as permitted or required by law. We will advise you of the reasons for restricting access, subject to any applicable laws or regulations.

Customer inquiries & CPO contact

Any inquiries relating to this Policy should be directed to our Privacy Officer at the following address:

Lendhub

Attention: Privacy Officer

625 – 1881 Steeles Ave West,

North York, ON

M3H 5Y4

Canada

[email protected]

https://lend-hub.ca

Modifications to this Policy

This Policy may be modified from time to time due to changes in legal or regulatory requirements or for other reasons. We reserve the right to make such changes and any changes will be posted on our website. Changes to this Policy will be binding after such changes have been introduced. We may assume that you have provided your consent from your continued patronage of our products or services.

Governing law

This Policy and any disputes arising from it shall be interpreted in accordance with the laws of the Province of Ontario and all applicable federal laws of Canada.

Sharing and Disclosing To Other jurisdictions

Our business relationships may result in your information being stored outside of Ontario and outside of Canada. For example, personal information may be disclosed to service providers, affiliated entities, or regulatory bodies or other third parties located in other jurisdictions. You acknowledge and agree that your personal information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement agencies in other jurisdictions.