Privacy Policy

Finloc 2000 Inc. (the “Company” or “we”) values its clients, respects their privacy and recognizes that it must maintain and use their personal information responsibly. We have created this privacy policy to demonstrate our firm commitment to your privacy and security and to advise you about how we collect, use and disclose your personal information in connection with our services (the “Services”). This privacy policy applies to all users of our website, including our web portal and associated interfaces and features (collectively, the “Website”). This privacy policy also provides you with information regarding your ability to “opt‑out” of providing certain personal information that you do not wish to provide and to access, correct, request the deletion, or withdraw consent to the communication or use of personal information already collected.

You are responsible for ensuring that your access to the Website and material available on or through it is legal in each jurisdiction in or through which you access or view the Website or such material.

The terms “Company,” “we”, “us”, and “our” used in this privacy policy refer, collectively, to the Company and its affiliates, divisions, successors and assigns and their respective employees, mandataries and agents (collectively, the “Company Affiliates”).

Due to the global nature of our Website, our data processing practices may vary among the jurisdictions in which we operate in order to comply with applicable legal requirements. Please note that certain rights, requirements and disclosures in this Privacy Policy may be subject to exemption or otherwise may not apply to you based, for example, on applicable law or regulations. If you reside in a relevant geographic location, please see the section relating to that geographic location for more information.

   1.  WHAT INFORMATION IS COLLECTED BY THE COMPANY?

Any time you use our Website or introduce any information, content or other materials through the Website or otherwise provide personal information to the Company (including via mail or e‑mail in regular correspondence), it may be collected, used and disclosed by the Company for various purposes as described herein.

Information collected when you use our Website:

• Device Information: Every time you visit or use the Website, the following information may be automatically obtained and compiled: your internet protocol (IP) address and the domain name registry information associated with that IP address; identification of your internet browser, operating system and/or hardware you are using; the date and time of your visit; the name and address (URL) of the web page you viewed immediately prior to accessing the Website; your entire query (if any) that was entered into a search engine which led you to the Website; any other “click stream” data; and other similar information. This information may be stored in our log files. Occasionally, if your browser is not configured to prevent disclosure of such information, the following information may also be revealed to us: your name and e‑mail address.
• Usage Information: We may collect the complete record of your actions on the Website, including without limitation access dates and times, app features or pages viewed, the time spent on each page, the information sent or received and the names of all files uploaded or downloaded.
• Transaction Information: We may collect transaction details related to your use of our Website and navigation on our Website, including the types and frequency of services you requested or provided, your transaction details, and the date and time the Website was used.

Information you provide:

• User profile: We may collect information when you create, edit or update your account. Such information can include, as the case may be, your name, email, phone number, login name and password, address, payment information (including related payment verification information), your social insurance or social security number, and information included on your government identification such as driver’s license number, birth date, photo and signature. It may also include equipment or insurance information and certificates as well as preferences and settings that you enable for your account(s).
• Demographic data: We may collect demographic information about you, including through user surveys.
• User content: We may collect information that you submit when you provide ratings, comments and feedback to others through the Website or otherwise contact us.

We do not knowingly or intentionally collect any personal information concerning individuals’ health, ethnic and racial origins, political opinions, genetic and biometric data, sex life or sexual orientation, or religious/philosophical beliefs (“sensitive personal information”) through the Website. You must not submit to us sensitive personal information of any kind through the Website.

Children’s Privacy: In light of the importance of protecting children’s privacy, we do not intend the Website for child audiences and do not collect, process or use on the Website any information relating to an individual whom we know to be under 13 years old without the prior, verifiable consent of his or her parent, guardian or other legal representative. If a parent or guardian discovers that his or her child has provided us with personal information, such parent or guardian has the right, upon request, to view the information provided by the child and/or to require that it be deleted from our records. In such a case, we ask that the parent or guardian of the child contact us at the contact information provided in the “Contacting Us” section below.

   2.  HOW IS YOUR PERSONAL INFORMATION USED?

We may use the information we collect for the following purposes:

• Develop, Offer and Provide Services and Features: We use the information we collect to develop, offer, provide, personalize, maintain and improve the Website and the Company’s products and services. This includes using the information to:
• Create and update your account.
• Verify your identity.
• Process your information.
• Create and enable features that allow you to share information with other people.
• Create and enable features to personalize your account.
• Perform internal operations necessary to provide our services and develop new products, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.
• Develop new products, services and offerings.
• Research and Development: We may use the information we collect for testing, research, analysis and product development. For example, this allows us to improve and enhance the efficiency and quality of the Website, develop new features and products, and facilitate insurance and finance solutions in connection with our Services.
• Legal Proceedings and Requirements: We may use the information we collect to investigate or address claims or disputes relating to your use of the Website, to investigate any actual or threatened security breach of the Website, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
• Communications from Us: Subject to your consent to receive communications from us, we may use the information we collect to tailor and send you communications about products, services, promotions, studies, surveys, news, updates and events.
• Consent: We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

We may also use information collected from the Website to measure interest in the various areas of the Website, to ensure that links on the Website facilitate easy navigation and to help make the Website more interesting and user friendly.

You acknowledge and agree that the Company shall also have the right to incorporate, use and reproduce any text, image, video, audio, or any information, content or other materials you provide through the Website, in whole or in part, in connection with the operation, marketing and promotion of the Company’s business. You always have the right to revoke such consent in the manner described in the section “How do I exercise my choices about the collection, use and disclosure of my personal information?” below.

In order to better serve you as well as maintain and improve our product and service offering, we may combine and aggregate information we collect directly or indirectly from you through the Website. We may also combine such information with readily available demographic or geographic information in order to enable us to communicate with you, subject to your consent to receive communications from us, by telephone (including by way of automated dialing answering device), e‑mail, mail, text, sms or otherwise.

We may use personal information and other information to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access the Website, or other analyses. De-identified and/or aggregated information may, depending on the jurisdiction in which you reside, not be considered personal information, and in such cases we may use, disclose, and retain such information as permitted by applicable laws.

   3.  TO WHOM MAY YOUR PERSONAL INFORMATION BE DISCLOSED?

We may disclose your personal information as provided below:

• To Company Affiliate: We may disclose your personal information to any of the Company Affiliates, so that, subject to your consent to receive such communications, they may communicate with you (whether by e‑mail, telephone, text, post or otherwise) and provide you with promotional materials and additional information about their products, services, promotions and special offers that may be of interest to you, or as required to carry out the business purposes described above in this privacy policy.
• In a Sale Context: In the event of a sale of all or substantially all of our business or another similar transaction (such as a sale of a division or business unit), we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating and/or effecting a proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this privacy policy.
• Non-Affiliated Third-Parties: We may provide your personal information to the following categories of service providers or business partners of the Company in order to carry out the business purposes described above in this privacy policy:
• Payment processors and facilitators.
• Background check providers.
• Credit agencies for credit verifications.
• Cloud storage providers.
• Marketing partners and marketing platform providers.
• Data analytics providers.
• Research partners, including those performing surveys or research projects in partnership with the Company or on the Company’s behalf.
• Vendors that assist the Company to enhance the safety and security of the Website.
• Consultants, lawyers, accountants and other professional service providers.
• As Required by Law: We reserve the right to disclose your personal information as required by law, in response to legal or regulatory process and law enforcement requests by government authorities that have asserted a lawful right to access such information, to our legal counsel, or as necessary to protect the property, interests and rights of the Company and any Company Affiliates.

We, as well as third parties that provide content or other functionality on our Website, may use cookies, web beacons, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Website.

• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Web Beacons/Pixel Tags. A web beacon (also known as a pixel tag) is a piece of code embedded in our Website that collects information about engagement on our Website. The use of a web beacon allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories: 

• Operationally Necessary. This includes Technologies that allow you access to our Website, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Website, including as part of our analytic practices to help us understand how individuals use our Website (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Website. This may include identifying you when you sign into our Website or keeping track of your specified preferences, interests, or past items viewed;

See the section below titled “HOW DO YOU EXERCISE YOUR CHOICES ABOUT THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION?” to understand your choices regarding these Technologies.

• Analytics. We may use Technologies and other third-party tools to process analytics information on our Website. Specifically, we use Hubspot’s built-in analytics, reports, and dashboards to track activity on the Website
  

   5.  WHOW DO YOU EXERCISE YOUR CHOICES ABOUT THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION?

We will collect, use and share your personal information for the purposes and in the manner described in this privacy policy, including in order to contact you and provide you with promotional communications. We want you to know that you have choices about how we collect and use your personal information, including the choice to refuse to provide us with personal information and withdraw any consent you have provided to us, in accordance with applicable law and/or as described below.

General. You have the choice simply not to submit any personal information to us; however, this may limit our ability to serve you as it may prevent you from using or restrict your use of the Website. You may also choose only to submit information constituting required fields. In the event that you have already consented to the collection, use and/or disclosure of your personal information, you may be able to subsequently “opt out” at any time, in accordance with applicable laws or contractual restrictions and upon reasonable notice, by contacting our privacy officer as described in the section entitled “Contacting us” below. Our privacy officer will also be able to provide you with additional information regarding the implications of withdrawing consent.

Promotional Communications. You can opt-out of promotional communications from us by following the opt-out instructions provided in the promotional materials sent to you. If you send us a request not to receive promotional communications from us, please be sure to include your full name, address, telephone number and any email address you used when you signed up on the Website or otherwise communicated with us. It may take up to ten (10) business days to process your request, during which period you may continue to receive communications from the Company or the Company Affiliates.

Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. The Company does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to or honor Do Not Track (DNT) signals or similar mechanisms transmitted by web browsers.

   6.   HOW CAN YOU ACCESS OR CORRECT YOUR PERSONAL INFORMATION OR MAKE INQUIRIES OR COMPLAINTS IN RELATION TO THIS PRIVACY POLICY AND THE COMPANY’S PRIVACY PRACTICES?

In accordance with applicable law, you may be entitled to request access to and/or correct your personal information collected by us. In order to make such a request, please contact our privacy officer in writing (see the “Contacting Us” section below).

You can also contact our privacy officer for any questions about or to make any complaint in relation to this privacy policy or the Company’s privacy practices in general (see the “Contacting Us” section below).

   7.  HOW LONG IS YOUR PERSONAL INFORMATION RETAINED?

Your personal information is maintained on our networks or on the networks of our service providers. We retain personal information only as long as it is needed to fulfill the identified purposes or as may be required to comply with applicable laws. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. To satisfy regulatory requirements, certain personal information may be retained for at least seven years, after which all documentation will be destroyed in a manner commensurate with its sensitivity (unless there are legal requirements that require its further retention).

   8.  HOW SECURE IS YOUR PERSONAL INFORMATION?

We use commercially reasonable efforts to adopt physical and technological processes and procedures designed to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. Furthermore, each Company employee, worker, mandatary or agent must abide by the privacy policy. Unfortunately, no system is 100% secure and we cannot ensure or warrant the security of any personal information we process. To the fullest extent permitted by applicable law, we do not accept liability for any theft, misuse, unauthorized disclosure, loss, alteration or destruction of data.

You also play an important role in protecting your privacy and the confidentiality of your personal information. For example, you should:

• Create a strong and unique password for your user accounts.
• Never share your user accounts or password with anyone. We will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please contact us if you receive such a request.
• Log out of your user account once you are finished using it, especially if you share your device with anyone else.
• Have a strong and unique password on your device, too.
• Never post information on our Website (such as on message boards and in chat rooms) that you are against or unwilling to be viewed or used by others.

     9.  CALIFORNIA PRIVACY PROVISIONS

The following provisions supplement the information contained in this privacy policy and apply solely to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”) in our role as a business. Any terms defined in the CCPA have the same meaning when used in this section.

Information We Collect

The CCPA provides California residents with the right to know what categories of personal information the Company has collected about them and whether the Company disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Categories of Sources from Which Personal Information is Collected

We obtain the categories of personal information listed above from the types and categories of sources described above in this privacy policy.

Business or Commercial Purposes for Collecting Personal Information

We may use or disclose the personal information we collect for the business purposes described above in this privacy policy. 

Sales of Personal Information

In the preceding twelve (12) months, we have not disclosed your Personal Information to any third party in a manner that would be considered a sale under the CCPA, nor do we have actual knowledge of any sale of personal information of minors under 16 years of age under the CCPA.  

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know - You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you a copy of your personal information in a readily available format, and the information required under the CCPA.

Right to Delete - You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception in the CCPA applies.

Exercising Your Rights

To exercise the access and deletion rights described above, or if you have any questions about these rights, please submit your request to us at privacy@finloc.com or contact us in writing at the address listed below in this privacy policy. We will process such requests in accordance with applicable laws. 

Non-Discrimination

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. 

Authorized Agent

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

Verification

When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the e-mail address associated with any personal information we have about you. 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below in this privacy policy.

10. NEVADA PRIVACY PROVISIONS

If you are a resident of the State of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below. 

11. INTERNATIONAL TRANSFERS 

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States of America, Canada or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

   12.  PRIVACY POLICY CHANGES

We may revise this privacy policy from time to time in our sole discretion. If there are any material changes to this privacy policy, we will notify you as required by applicable law. Following the effective date of such changes, you will be bound by such changes unless you advise us in writing, by phone or by email before the effective date of such changes that you do not agree to the changes in which case you may not be able to continue using the Website. You are responsible for regularly reviewing this privacy policy and any changes thereto.

   13.  OTHER WEBSITES

THE WEBSITE MAY CONTAIN LINKS TO OTHER WEBSITES THAT ARE NOT OPERATED BY THE COMPANY. THE POLICY DOES NOT APPLY TO THE PRACTICES OF THIRD PARTIES AND THE COMPANY DOES NOT ASSUME ANY RESPONSIBILITY FOR ANY SUCH THIRD-PARTY PRACTICES OR FOR THE PRIVACY PRACTICES OF THE WEBSITES THAT IT DOES NOT OPERATE. BY USING THE WEBSITE AND/OR ACCESSING A THIRD PARTY’S WEBSITE FROM THE WEBSITE, YOU RELEASE THE COMPANY OF ANY RESPONSIBILITY FOR THE ACTIONS, PRACTICES AND OMISSIONS OF THIRD PARTIES. BY CLICKING ON ANY HYPERLINKS TO OTHER WEBSITES FROM THE WEBSITE, YOU MAY AUTOMATICALLY SUBMIT TO THE PRIVACY PRACTICES OF THOSE WEBSITES. PLEASE CHECK THE PRIVACY POLICIES OF THESE THIRD-PARTY WEBSITES. IN NO EVENT SHALL THE COMPANY OR ANY COMPANY AFFILIATES BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DAMAGES OR INJURY WHATSOEVER (INCLUDING BUT NOT LIMITED TO DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES) ARISING OUT OF OR IN CONNECTION WITH THE MISUSE OF PERSONAL INFORMATION BY THOSE WEBSITES.

   14.  CONTACTING US

The Company has appointed our Corporate Secretary as our Privacy Officer. The Privacy Officer is accountable for the Company’s compliance with the principles of any applicable privacy legislation and this privacy policy.

If you have questions or complaints with respect to our privacy policy and practices or if you wish to request access to, or correction of, your personal information under the Company’s care and control, please contact the Privacy Officer at:

BY E-MAIL 

privacy@finloc.com

BY PHONE 

1 866 634-6562

BY POST MAIL 

11505, 1^st Avenue, Suite 500, Saint-Georges, Québec, Canada, G5Y 7X3

Last Updated: February 15th, 2022