Privacy - PayBright: E-Commerce and Point-of-Sale Financing

PayBright (“PayBright”, “we”, “us” or “our”) takes steps to ensure it meets privacy principles and requirements with respect to Personal Information under applicable Canadian privacy legislation. The purpose of this statement is to inform our customers and other individuals we deal with (“you” and “your”) how we collect, use, disclose, and protect your Personal Information. “Personal Information” is information that is identifiable as pertaining to an individual, as more particularly described under applicable privacy legislation. This policy applies to our collection, use, and disclosure of Personal Information in Canada.

Our Principles of Privacy Protection

Principle 1: Establishing Accountability

PayBright is responsible for maintaining and protecting the customer information under its control.

Principle 2: Identifying the Purpose of Collecting Information

We will identify the purposes for which customer information is collected before or at the time the information is collected.

Principle 3: Obtaining Consent

We will require the knowledge and consent of the customer for the collection, use or disclosure of customer information except where required or permitted by law.

Principle 4: Limiting Collection of Personal Information

Customer information collected must be limited to those details necessary for the purposes identified by PayBright. Information must be collected by fair and lawful means.

Principle 5: Limiting Use, Disclosure and Retention of Personal Information

We may only use or disclose customer information for the purpose for which it was collected unless the customer has otherwise consented, or when it is required or permitted by law. We will only retain customer information for the period of time required to fulfill the purpose for which it was collected.

Principle 6: Keeping Information Accurate

We will maintain customer information in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

Principle 7: Protecting Customer Information

Customer information must be protected by security safeguards that are appropriate to the sensitivity level of the information.

Principle 8: Maintaining Openness of Policies and Practices

PayBright will make information available to customers concerning the policies and practices that apply to the management of their information.

Principle 9: Providing Customer Access to Personal Information

Upon request, a customer shall be informed of the existence, use and disclosure of their information, and shall be given access to it. Customers may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.

Principle 10: Handling Customer Complaints and Questions

Customers may direct any questions or enquiries with respect to the privacy principles outlined above or about our practices by contacting our Privacy Officer.

Personal Information We Collect

We, and our agents and representatives, collect certain types of Personal Information such as:

Personal Information may be collected through our online application, tablet or mobile applications, over the telephone, or by other means.

Your Consent

Use of Your Personal Information

We generally use your Personal Information to:

Disclosure of Your Personal Information

Merchants: In the course of completing a loan application and obtaining financial services from us, some of your Personal Information will be disclosed to the merchant(s) from whom you are purchasing services or products in connection with your transaction with us. This information may include, without limitation, your contact information and your available credit with us.

Service Providers: We may transfer Personal Information to outside agents or service providers (for example, credit bureaus, billing service providers, collection agents, or marketing agencies), in which case we will use contractual or other reasonable means to ensure that your Personal Information is protected and not used or disclosed for any purposes other than as directed by us. We may also from time to time cooperate with suppliers, service providers and partners for the purposes of providing you with additional services or products or for advising us on matters such as market research and data processing. Such parties will be given only the information required necessary to perform their services and are required to adhere to our privacy standards.

Financing Sources/Sale of Business: Your Personal Information may be used by us and disclosed to parties connected with the contemplated or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of our business or assets, including for the purpose of permitting such parties to determine whether to proceed or continue with such transaction, to fulfill reporting, inspection, or audit requirements or obligations to such parties. In the event that all or part of our business or assets to which your Personal Information relates is sold, assigned, or otherwise disposed of, your Personal Information will be used and disclosed by such parties for substantially the same purposes as described in this policy.

Legal/Compliance: We may otherwise disclose Personal Information as necessary to meet legal, regulatory, insurance, audit, and security requirements, or as permitted or required by law.

Security and Storage

Access to your information is provided to our employees and other parties only on a need-to-know basis. We protect your Personal Information using physical, electronic, or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized employees and agents of PayBright who require access to your Personal Information in order to fulfill their job requirements will have access to your Personal Information.

Your information may be stored by us and other parties in electronic or physical files. Electronic files are stored on servers which may be located outside of Canada, including in the United States. In the event that such information is located outside of Canada, foreign governments, courts of law enforcement or regulatory agencies may be able to obtain disclosure of this information.

Our Website and the Internet

Visiting our website: We operate the website www.paybright.com which provides information about your accounts, and allows you to request further information, to request customer support, or to make other inquiries. Personal Information provided by you online is used to respond to your inquiries and fulfill your requests. Personal Information that you voluntarily provide in response to our online questionnaires and surveys is used to help us learn more about your interests and preferences, and may be used to send you periodic information about our products and services (if you have chosen that option). Our internet servers may passively and automatically collect certain information about website visitors’ traffic patterns, which may be linked to their Internet Protocol (IP) addresses (which are unique Internet “addresses” assigned to all Internet users by their Internet Service Providers). Server logs may record statistical information, such as visitors’ IP addresses, type of operating systems, time and duration of visit, and pages requested, and identify categories of visitors by items such as domains and browser types. These statistics are only collected and used on an aggregate basis.

Cookies and other features: Our site makes use of cookies. Cookies are small text files offered to your computer by servers in order to keep track of your browser as you navigate the website. Cookies may be stored on your hard drive, or in temporary (cache) memory, in which case they are deleted when you shut down your browser or turn off your computer. We may use cookies to store preferences, record session information such as language preferences, develop aggregate information about website visitors’ preferences and interests, record past activity at a site in order to provide better service when you return to our site, or customize webpage content based on your browser type or other information you provide. Unless a visitor specifically provides their identity to us (e.g., by providing information through an online form or sending us correspondence from the website), cookie information is anonymous and we will not know who the individual visitors are. Information gathered from cookies is only used on an aggregate basis. You can disable cookies using your Internet browser’s settings. Please consult your browser’s help function for information on how to disable cookies. Note: if you disable cookies, certain features of our website may not function properly. Our website may also use a technology called “tracer tags” or “web beacons”. This technology allows us to understand which pages you visit on our website. These tracer tags are used to help us optimize and tailor our website for you and other future visitors to our website.

Interest-based advertising: We may use third parties (such as Remarketing with Google Analytics) to serve our advertisements on our Website and other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our website and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant to you, both on and off our website. You can opt-out of interest-based ads from Google by visiting http://www.google.com/settings/ads. To find out more about the collection and use of information by third parties for behavioural advertising purposes, or if you would like to opt-out of certain third-party cookies and make selections about what online advertisement you choose to receive, you can visit the Digital Advertising Alliance of Canada website.

Third-Party Links: Our website may contain links to other websites that are provided as a convenience only, and which may have different privacy policies and practices than PayBright and, accordingly, we have no responsibility for such third-party websites, and individuals are advised to review the privacy policies of any third-party websites they visit.

Telephone Communications

Your telephone conversations with our authorized employees and representatives may be monitored and/or recorded for quality control, internal training and recordkeeping purposes. We and our affiliates and third parties with whom we share your personal information in accordance with this Privacy Statement may contact you by telephone using the telephone number information you have provided to us.

Access, Correction, and Contacting Us

We may establish and maintain a file of your Personal Information for the purposes described above, and which will be accessible at our Corporate Office in Toronto, Ontario. If you wish to request access or correction of your Personal Information in our custody or control, or if you wish to make inquiries or complaints or have other concerns about our Personal Information practices, you may contact our Privacy Officer by calling 1-877-276-2780 or emailing us at info@paybright.com, Attention: Privacy Officer. Your right to access or correct your Personal Information is subject to applicable legal restrictions.

Policy Changes

We may revise our privacy policy and this privacy statement from time to time. If we materially change our privacy practices, we will take reasonable measures to notify affected individuals of these changes in advance. If our Personal Information practices change at some time in the future, we will post the policy changes on our website to notify you of these changes and provide you with the ability to opt out of any new nonessential uses or disclosures of Personal Information. If you are concerned about how your Personal Information is used, you should check our website periodically or contact us as described above to obtain a current copy of this policy. This privacy statement was last updated December 1, 2016.