Client Privacy Code
Our policies and procedures to protect your privacy are in place.
We, at LendDirect value you as a client and take your personal privacy seriously. As such, we would like to inform you of our policies for collecting, using, securing, and disclosing your personal information. It is our intention to manage and handle information in a manner consistent with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and other relevant privacy legislation to the extent required by law.
What personal information do we collect?
Why do we collect your personal information?
We collect, use and disclose your personal information to: (a) meet legal and regulatory requirements; (b) authorize and process your transactions; (c) detect and prevent fraud and help safeguard the financial interests of LendDirect and its clients; (d) develop, offer, and manage the products and services provided by our company; (e) maintain adequate accounting, tax and business records; (f) assess the quality and quantity of our products and services; and (g) send you information on products and services that may be of interest to you. We collect, use and disclose information that we believe is reasonable for the above purposes or those purposes indicated to you at the time the information is collected.
Who sees or obtains your information?
We may provide your personal information to a third party in the following limited circumstances:
• where we have your consent, whether express or implied;
• to consumer or credit reporting agencies to verify your current and ongoing creditworthiness, or to maintain your credit history;
• to your financial institution to verify an account;
• where we are required or permitted, by law or our regulators, to do so;
• to service providers (including affiliates acting in this capacity) that perform services on our behalf, such as pre-paid credit card financing, online loan underwriting, data hosting, data processing, information technology, marketing and analytics, call centre, mailing, collections and billing;
• in the unlikely event of a sale or lease of our business, in whole or in part, or a corporate re-organization; or
• where such third party assists us in serving you.
In such cases we will make disclosure to the extent that is necessary to accomplish the required purposes or discharge our regulatory, legal or public duty. We will endeavor to obtain from the third party receiving the information reasonable assurances that it will respect the privacy of personal information in accordance with applicable laws. As certain of our operations are conducted in the United States of America and certain of our service providers may have operations in the United States of America, your information may be sent outside of Canada by secure electronic or other means. In the event that your information is sent outside of Canada, there is a remote possibility that it may be accessed by the courts, law enforcement and national security authorities of the jurisdiction where it is sent.
What are our safeguards for protecting your information?
Our security safeguards are designed and maintained to protect your personal information against loss or theft, as well as unauthorized access, use, copying, modification, disclosure or disposal. Our current methods of protection include:
• physical measures including restricted access to branches, alarm systems, and secure filing cabinets;
• technological measures for electronic transfers including our email and point of sales systems running on a VPN with a minimum of 128 encryption and a firewall, and our POS system requiring several passwords including a sequel server;
• organizational security measures including security clearances, limiting access to a 'need to know' basis, staff training, and required confidentiality agreement; and
• investigative measures, should LendDirect have reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
LendDirect protects personal information regardless of the format in which it is held.
How long do we keep your information and how do we dispose of it?
The length of time we retain your information varies depending on the services you have requested and your relationship with us. We keep information for so long as it is reasonably required by us or legally necessary for us to retain such information. Your information is confidentially destroyed, deleted, erased or converted to an anonymous form when reasonably appropriate.
How do you gain access and verify your personal information?
We will provide you access to the personal information we have about you. If you require information, simply contact our Privacy Officer. We will respond to your request within 30 days. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to us, is too costly to retrieve, or cannot be disclosed for other legal reasons.
Having accurate information about you enables us to give you the best possible service. You can help by keeping us informed of any changes, for instance if you move or change telephone numbers. If you find any errors in our information about you, let us know and we will make the corrections immediately and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in our file. Requests can be made through the client's local branch, website or the Privacy Officer.
How are your choices handled?
Subject to legal or contractual restrictions and reasonable notice, you are free to refuse or withdraw your consent to the collection, use or disclosure of your personal information at any time. You may do so by contacting our Privacy Officer. However, once you are using our service you may not be able to withdraw your consent to our collection, use and disclosure of personal information as necessary to provide that service. You may also wish to limit the amount of personal information we collect, use or disclose about you. However, by doing so, we may not be able to provide our services or connected services to you. You may opt out of receiving marketing information, via email, SMS, telephone or direct mail at any time.
Telephone calls made to LendDirect may be recorded for quality assurance and record keeping purposes. If you do not wish to have your telephone calls recorded, you have the option to conduct your business with us through a LendDirect store or by writing us.
How is your privacy treated by our website and mobile app?
In general, you may visit LendDirect on the web or use our mobile app without telling us who you are or revealing any information about yourself.
We may, however, collect non-personally identifiable information from you when you visit our website or download or use or mobile app. For our website, this includes your domain name, the IP address of the web page from which you enter the site, the pages you visit on our site and the amount of time you spend there. For our mobile app, this includes device ID and model number. This information is used to improve and customize the content and layout of our website or app.
From time to time, we may utilize cookies or scripts on our website. You may disable these features, but by doing so, you may not be able to utilize the services we provide on our website.
We collect the e-mail addresses of those who communicate with us by e-mail and information volunteered by our visitors. The information we collect is used to improve our content and contact these visitors, if they have requested to be contacted.
How will we amend our Client Privacy Code?
We may amend our Client Privacy Code from time to time. If it changes at some point in the future, we will publish the changes on the version posted on our website and in our branch lobbies. An up-to-date version of our Client Privacy Code will be available for handout at our branches.
How do you talk to us?
Our Privacy Officer is your point of contact if you wish to raise any matters regarding our collection, use, storage or disclosure of your personal information. For information, questions or concerns on LendDirect privacy practices contact:
Our Privacy Officer has the decision-making authority to resolve most concerns. If you are not satisfied with our resolution of your privacy matters, you may address your concerns to the Privacy Commissioner of Canada at http://www.privcom.gc.ca.