Plus Credit Ltd. (“PlusCredit,” “we,” “us,” or “our”) is dedicated to upholding the privacy and security of your personal information. Plus Credit Ltd, including its subsidiaries and affiliates (collectively, the “PlusCredit Ltd”), referred to in this Privacy Policy as “PlusCredit”, “we”, “us” or “our”, has developed this Privacy Policy (this “Policy”) in accordance with applicable privacy legislation.
This Privacy Policy explains how we collect, use, disclose, retain, and manage your Personal Information, as defined below, in connection with your access and use of our Products and Services. This includes information collected by us through websites, emails, or telephone calls and when providing Products or Services.
1.Personal Information
In this Privacy Policy, “Personal Information” means information about an identifiable individual, such as an individual’s name and email address, or any information that applicable law classifies as personal.
This Policy applies to Personal Information of Plus Credit’s members or other individuals. To the extent permitted by law, this Policy does not apply, nor include:
– information that is publicly available in a telephone directory
– business contact information that enables an individual to be contacted at a place of business
– information that is anonymous, or is no longer identifiable to a specific person
– aggregated information
– personal information of our employees, candidates
– any information that is not qualified as personal
2. Your Consent
By providing us with your Personal Information, and/or by applying for or obtaining a Product or Service from us, you consent to the collection, use, disclosure and retention of that information by us in accordance with this Privacy Policy and as otherwise permitted by applicable law.
You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to us, by emailing our Privacy Officer using the contact information noted below. If you do not provide us with certain Personal Information then you might not be able to proceed with your intended interactions or transactions with us or otherwise receive the full benefit of our Products and Services.
If we want to use your Personal Information for any purpose that was not disclosed to you at the time you provided your initial consent, we will seek out your consent at the time of this new purpose. If you do not agree with any term in this Privacy Policy, do not provide us with any of your Personal Information or use our Website, Products or Services.
3. Information We Collect
We collect Information for the purposes of managing and administering the operations of our product(s) and service(s). We may collect Information directly from you or from third parties, with your consent, or as permitted or required by law. This collection is necessary in order to perform the contract entered into when you use our product(s) and service(s) on our websites.
Mandatory Information is necessary for the operations of our product(s) and service(s). The possible consequences of a failure to provide Mandatory Information may include, but are not limited to, disruption or delay in the delivery of our product(s) and service(s).
Information we collect includes, but is not limited to:
– Name, address, email address, telephone number, mobile phone number and other contact particulars;
– Bank account information, including bank account, transit and institution numbers;
– Credit history and financial and identity information from consumer and credit reporting agencies, or financial institutions or businesses that you currently have, or have had, financial dealings with;
– Information relating to credit risk assessments completed by a third party;
– Information related to verifying your identity in accordance with our regulatory requirements and in order to prevent fraud; in certain situations, this includes the use of facial recognition technology in the form of a “selfie” photograph and collecting images of valid and current government-issued photo identification; this information is held by our provider for a limited period of time, however Plus Credit may retain this information for a period of time commensurate with our anti-money laundering and anti-terrorist financing regulatory requirements.
– Income information, including the name and contact information of your employer or other sources of income;
– Information you provided to us in connection with your use of the product(s) and service(s) from Plus Credit
– Name and contact information of personal references, and trusted contact, should you choose to provide one;
– Banking information collected from your physical or online bank statements;
– Information relating to ongoing interactions with Plus Credit, including payment history, current and historical loan amounts or balances, inquiries or complaints, and similar information;
– Social Insurance Number, date of birth, and other personal identifiers (if you choose to provide them to us). If you give us your Social Insurance Number, we may use it to identify you with consumer reporting agencies and other parties, and we may keep it in our records with your other information, even after your account is closed;
– Contact and credit information from other providers of financial products and services where you have agreed to the sharing of your Information with entities like Plus Credit;
– Information we collect automatically when you visit our website (see “Cookies and Similar Technologies” below);
– Information we collect from public sources and third parties in order to locate you where a debt is owed to us and we are unable to contact you using the information we have on file;
– Any Information that you choose to communicate to us about you via support channels; and
– Other Information collected with your consent or as permitted or required by law.
You must carefully review any agreements you have entered into with your financial institution to confirm whether you are permitted to provide us with your Banking Information, and whether your use of the Bank Verification System may result in any negative consequences for you. We are not liable for any breach of contract or any other liabilities that may result from your use of the Bank Verification System and your disclosure of your Banking Information to us.
(a) General
We use your Personal Information for purposes relating to or arising from your relationship and transactions with us and as otherwise set out in this Privacy Policy or permitted by applicable law, including to:
– administer your relationship with us, including to offer and provide you products from us and PlusCredit Companies and provide services relating to any existing products you hold with us and PlusCredit Companies and correspond with you regarding those matters;
– facilitate your interactions and transactions with us, including to process your applications, requests, orders and payments, and to do so via telephone, mail, email, text (SMS) message or other means;
– assess your application and eligibility for any of our Products and Services;
– verify your identity for authentication and security purposes;
– provide any Product(s) and Service(s) to you;
– process and respond to your inquiries, requests and other communications;
– provide you with information (including by email and other electronic messages) regarding us and our – Product(s) and Service(s) and related product(s) and service(s) offered by other businesses, to the extent permitted by applicable law;
-administer and facilitate your participation in contests and promotions related to PlusCredit;
– maintain, protect and improve our Products and Services and to develop new products and services;
inform you of any changes to our Products and Services;
– identify you on third-party platforms you already use (such as Facebook, Instagram, and Twitter) and serve you ads through their marketing platforms;
– comply with our legal and regulatory obligations;
– protect and enforce our legal rights, interests and remedies or to protect our business, operations and customers or other persons from fraud, and other unauthorized or illegal activities; and
assist Plus Credit Companies to collect, use, disclose and retain your Personal Information in accordance with this Privacy Policy.
(b) Disclosure by Plus Credit
We may share your Personal Information with Plus Credit Companies, and we may develop, maintain and share a confidential profile for you for use by each Plus Credit Company to provide information, products and services to you, to facilitate your dealings with each Plus Credit Company and as otherwise set out in this Privacy Policy. We may also share your Personal Information with our partners for the purposes of providing you with the Products and Services and any related matters pursuant to this Privacy Policy.
(c) Interest-Based Advertising
We may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by third party vendors (such as Google and Facebook) to display advertisements on third party websites and social media sites visited by users of our Website. Advertising vendors (such as Google and Facebook) use technologies, including but not limited to, cookies, pixels, and tokens– unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses our Website – to display ads based on the computer’s past access to our Website. You can opt-out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page. We may also use advertising services provided by third party vendors, whereby we may share general information about preferred customer profiles with such third party vendors, to obtain specific types of customers. Such preferred customer profiles would be created through the aggregation of data from previous customers we obtained through the advertising services of such third party vendors.
(a) General
We disclose your Personal Information for purposes relating to or arising from your relationship and transactions with us and as otherwise set out in this Privacy Policy or permitted by applicable law.
(b) Specific Consents
We may disclose your Personal Information in accordance with express or implied consents that you give during your interactions and transactions with us.
(c) Referred Transactions
If we refer you to an independent business (e.g. a lender) for a proposed transaction (e.g. a vehicle loan), then we may disclose your Personal Information (including your credit score that you provided to us, Bank Account information, and related information) to the independent business to facilitate the proposed transaction. We have no responsibility or liability for, the use, disclosure or retention of your Personal Information by the independent business, and the use, disclosure and retention of the disclosed information by the independent business is not subject to this Privacy Policy.
(d) Suppliers and Service Providers
We may disclose your Personal Information to our suppliers and service providers (including fraud prevention services and payment processors) to assist us in the provision of information, Products and Services to you, to assist us in using your Personal Information as set out in this Privacy Policy and as otherwise permitted by applicable law.
(e) Law Enforcement/Legal Disclosures
We may disclose your Personal Information as required or authorized by applicable law, including to comply with a subpoena, warrant court or arbitral order or litigation disclosure obligation. We may disclose your Personal Information to law enforcement agencies or other independent organizations if we reasonably believe the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if we reasonably believe the disclosure is necessary or appropriate to protect and enforce our legal rights, interests and remedies or to protect the rights, interests, business, operations or our customers or other persons (including to detect and prevent fraud and other illegal activities, enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of our Products or Services).
We have no responsibility or liability for, the use, disclosure or retention of your Personal Information by the agencies, independent organizations or other persons to whom we disclose the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy. We may disclose your Personal Information that we have in our records even if your profile with us has been closed, to comply with our regulatory and legal requirements. This may include disclosures for tax, anti-money laundering, and sanctions screening purposes. We may relay this information to our financial institution partners, relevant third parties and relevant government or regulatory agencies, as permitted or required by law.
(f) Business Transactions
We may disclose your Personal Information in connection with a proposed or actual business transaction in which we are involved (such as a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of our business or assets), but we will require the information recipient agree to protect the privacy of your Personal Information in a manner that is consistent with this Privacy Policy and applicable law.
We and Plus Credit Ltd, and our and their service providers may process, store and use your Personal Information at facilities in various countries, including Canada, the United States of America and one or more countries in Europe, Asia, or South America. The Personal Information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your Personal Information without notice.
By providing your Personal Information to us, you consent to the transfer and access of your Personal Information to facilities located in other countries and the processing and storage of your Personal Information at those facilities
Information is retained only for as long as reasonably necessary for the purposes referenced in this Privacy Policy and to comply with our legal obligations or enforce or protect our legal rights, or a longer period required or permitted by applicable law.
We will delete or dispose of your Personal Information when we are no longer reasonably required to retain the information for the purposes referenced in this Privacy Policy.
We take all useful precautions to preserve the security, integrity and confidentiality of your Information and in particular, to prevent them from being distorted, damaged or accessed by unauthorized third parties.
To ensure safety of your Personal Information, we use measures such as:
– The use of the latest Transport Layer Security (TLS) protocols for encryption to protect customer information, passwords, and data against unauthorized access
– Continued compliance efforts for cybersecurity regulations
– The use of many third party tools to confirm the identity of people applying for any of our product(s) and service(s)
– Third party vendors thoroughly vetted for their security practices
– AWS secure data centers to help protect data in our care
– Multiple zones and layers on firewalls to protect our internal and external networks
We may transfer Information to outside agents or service providers (including our affiliates acting in this capacity) that perform services on our behalf, for example, mailing, call center, billing, collections, skip-tracing, marketing, analytics, information technology and/or data hosting or processing services or similar services, or otherwise to collect, use, disclose, store or process Information on our behalf for the purposes described in this Policy.
Some of these service providers may be located outside of Canada, including in the United States, and as a result, your Information may be processed and stored on servers outside of Canada for the purposes described in this Policy. Contractual clauses and other measures we may take to protect your Information while processed, stored or handled by these service providers are subject to applicable Canadian and foreign legal requirements, including lawful requirements to disclose personal information to government and national security authorities in certain circumstances.
We ensure our employees and partners handle your Information with care at all times and we require them to maintain their obligations of confidentiality even after the end of their contract with us.
Our Website and correspondence (including emails and messages) may include advertisements for products and services (e.g. vehicle sales, personal loans and credit cards) offered by independent businesses (that may have a financial relationship with us) or links to websites operated by independent businesses (e.g. car dealers, lenders and credit card providers). We have no responsibility or liability for, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your Personal Information.
This Privacy Policy does not directly apply to the collection, use, disclosure and retention of your Personal Information by those websites, online services and independent businesses. We recommend reviewing the privacy statement or privacy policy associated with any linked website prior to visiting the site or providing any Information.
We use “cookies”, a technology that installs a small amount of information on a website user’s computer, to permit our website to recognize future visits using that computer and to avoid having to register your contact information at each visit. Cookies enhance the convenience and use of our website.
When you visit our website, we may collect and use your internet protocol address to help diagnose problems with our server and to administer the website, to identify users and their activities on the website, and to gather broad demographic information. We may also collect web page choices, browser type, operating system, and time you spend on the site, to help us improve your experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of our website and your ability to access certain features of our website or engage in transactions through our website.
For example, the information provided through cookies is used to recognize you as a previous user of our website, to track your activity on our website, to respond to your needs, and to otherwise facilitate your experience on our website. Plus Credit also uses web cookies and pixel tags to track user behaviour on our websites and to compile reports regarding user demographics, website traffic patterns, and website purchases. We may then provide these reports to advertisers and others.
Within our applications, we may also use analytic tools and automated tracking technology or methods. We use these tools to analyze and enhance the user experience. Plus Credit may use third-party advertising networks to display advertising on our websites or other websites. These advertising networks use cookies or similar technologies to track your navigation habits on our websites and third-party websites in order to serve you advertising that is customized to your inferred interests and preferences.
For example, a cookie may be placed on your computer when you visit a Plus Credit website, which is recognized and used by third-party advertising networks to serve you with an advertisement from PlusCredit when you visit other websites within their advertising network. As described above, you may be able to set your browser to decline cookies. If you decline cookies you may still receive online advertising. However, it may be less personalized. Some advertising networks participate in industry programs that include web pages to visit to opt-out. For example: http://youradchoices.ca/choices.
(a) Accuracy
We rely on you to ensure that the Personal Information you provide to us is as accurate, complete and up to date as necessary for the purposes for which we use the Personal Information. You will promptly notify us of any changes to your Personal Information using the procedures made available for that purpose by us or by contacting our customer service.
(b) Access
You may reasonably request access to your Personal Information collected by us and information about our use, disclosure and retention of that Personal Information by submitting a written request to our Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your Personal Information in our control and you will be entitled to verify the accuracy and completeness of your Personal Information and to have it revised as appropriate. You may be required to pay a reasonable fee for access to your Personal Information.
(c) Deletion
You may request we delete your Personal Information in our possession by submitting a written request to our Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, we will delete your Personal Information upon such request.
We will take appropriate steps to verify the identity of anyone requesting changes to, access to or deletion of your Personal Information. We may decline to process a request to change or access Personal Information that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.
(d) Correction
If you find any errors in your Information, please notify us as soon as possible and we will correct them.
12.Your Consent
Plus Credit collects, uses and discloses your Information with your consent, or as permitted or required by law. By providing us with your Information, we will assume that you consent to our collection, use and disclosure of such Information for the purposes identified or described in this Policy, if applicable, or otherwise at the time of collection.
We may be required or permitted under statute or regulation to collect, use or disclose Information without your consent, for example, to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
You may withdraw your consent to our collection, use and disclosure of your Information at any time, subject to contractual and legal restrictions and reasonable notice. We will let you know the consequences of refusing or withdrawing consent. Note that if you withdraw your consent to certain uses of your Information, we may no longer be able to provide certain of our products or services.
If you choose to close your account, we will delete your Information as soon as authorized under applicable financial information legislation.
No method of transmission over the Internet, or method of electronic storage, is 100% secure. We take reasonable measures to protect personal information in our care. You are responsible for the security of any device you use to access your account(s). Your account(s) will be protected with appropriate security measures, which may include passwords, tokens, biometric information, and other measures (“Access Controls”).
On an ongoing basis, we assess the risks associated with the collection, use and disclosure of personal information and we update our privacy and security practices as necessary. Should an unforeseen event occur, such as a data breach or harm caused by bad actors, we have procedures in place to identify, assess and minimize any further risks and determine if there is a real risk of significant harm to individuals.
However, security risks cannot be entirely eliminated and we cannot guarantee that your Personal Information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy.
We create and collect non-personal information (information that is not about an identifiable individual), including information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. We may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with Personal Information, then we will treat the combined non- personal information as Personal Information for the purposes of this Privacy Policy for as long as the non- personal information is combined with Personal Information.
(a) Disclaimers, Liability Exclusions/Limitations and Disputes:
The agreements (including any subscription agreement or terms of service or use) that you accept when you apply, register for, order or use our Products or Services contain important provisions, including provisions disclaiming, limiting or excluding our liability and other persons (including PlusCredit Ltd Companies and service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or our collection, use, disclosure and retention of your Personal Information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.
(b) Changes to this Policy:
We may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on our Website. Our collection, use, disclosure and retention of your Personal Information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with us after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your Personal Information as set out in the changed Privacy Policy. Please visit this Website regularly for updates to this Privacy Policy.
(c) English Language:
You and PlusCredit have each expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language. Les parties conviennent et exigent expressement que cette Politique de Confidentialité et tous les documents qui s’y rapportent soient rédigés en anglais.
(d) Contacting Our Privacy Officer:
Our Privacy Officer is responsible for our employees being trained in our privacy policies and for ensuring we fulfill our privacy commitments.
If you have any comments or questions about this Privacy Policy or how we deal with your Personal Information, please contact our Privacy Officer by mail or email at:
Plus Credit Ltd – Privacy Officer
Calgary, Alberta, Canada
and by email: legal@PlusCredit.ca
