BANKEROO LEGAL

Bankeroo’s Privacy Policy

Let’s address the elephant in the room

Bankeroo’s Privacy Policy

EFFECTIVE DATE: JUNE 30, 2017


Introduction

At Bankeroo Inc. (“Bankeroo”), we understand that privacy is an important issue. That’s why we’ve designed our privacy policy to comply with Canada’s Federal Personal Information Protection and Electronic Documents Act along with all respective provincial legislation. We are dedicated to promoting a world of transparency and complete disclosure about how we collect, and use the personal information that you may provide to us through our website www.Bankeroo.com (the “Website”) and/or related services or that we may otherwise collect about you.

By purchasing our products or using our services and/or Website, you consent to the collection, and use of your personal information in accordance with the terms set forth herein. We recommend that you familiarize yourself with this Privacy Policy. You can scroll down this page to learn what type of personal information we collect from our consumers, how we collect and use it, and how we protect that information. In the event that you do not agree with any or all of the terms and conditions contained herein, we urge you to terminate the use of our Website.

Rest assured that Bankeroo we continuously review this Privacy Policy to ensure that it remains current with all laws and regulations in effect.


Definitions

“Collection” means the act of gathering, acquiring, recording, and/or obtaining personal information from any source, including third-parties, by any means.

“Consent” means your voluntary agreement with the collection, use and disclosure of personal information for purposes deemed reasonable by Bankeroo from time to time.

“Customer” means an individual who visits the Website and/or uses, or applies to use, Bankeroo’s products or services.

“Electronic messages” means communication received via e-mail, SMS or any other electronic method.

“Personal Information” means information which is collected with the intention of identifying, locating, or contacting an individual, which may include but is not limited to, name, home address, home telephone number, birth date, social insurance number, employer’s name, pay dates, net pay, credit report, banking details, and other similar type of personally identifiable information.

“Third party” means an individual or organization outside of Bankeroo, which may be based within or outside of Canada.

“Use” means the treatment, handling, and management of personal information by and within Bankeroo.


Personal Information

Bankeroo is permitted to collect, and use Personal Information under the various privacy acts in Canada and respective provinces to ensure that we are promoting safe and responsible lending. For instance, when you first apply for a Bankeroo loan via our Website, we ask you to create an account and then ask you to supply certain Personal Information that serves to identify you.

Use of Personal Information

Bankeroo may use your Personal Information, either on its own or aggregated with other information, for any of the following purposes:

  1. Process your application for any products and/or services available through our Website

  2. Provide financial services to our customers;

  3. Verify your identify and confirm the accuracy of the information provided by you during the application process and avoid fraud;

  4. To develop, manage and market products and services to meet the needs of customers;

  5. Confirm your employment details and source of income;

  6. Obtain your credit information from various credit reporting agencies;

  7. Maintain your account;

  8. To communicate with you via telephone, email, and/or SMS about your loan;

  9. Provide you with information about other products we offer or plan to offer in the future;

  10. To ensure a high standard of service to our customers;

  11. Determine your eligibility for the different loan products we offer;

  12. Administer contests and sweepstakes and notify you if you’ve won;

  13. Administer, service, and manage your Bankeroo account;

  14. Securely process all transactions, including monetary transactions, involving your Bankeroo account;

  15. Develop, manage and promote new products to better meet the needs of our customers;

  16. Conduct portfolio/statistical analysis for the purpose of improving our underwriting practices;

  17. To extract certain information for the purpose of generating statistics and analysis for purposes of conducting and improving our services and business;

  18. Manage risks including, but not limited to credit risk, fraud risk, and operational risk;

  19. Improve our products and services and conduct research and analysis;

  20. Collect monies that may become owed by you to Bankeroo;

  21. Enforce the terms and conditions arising from any contract entered between us;

  22. Contact customers about promotional offers and products which may be of interest;

  23. Respond to customer service requests;

  24. Comply with all Provincial and Federal regulatory requirements.

If you do not provide us with your Personal Information, we will be unable to process your application.

Bankeroo will notify you, either by posting a notice on our Website or by electronic messages, if we modify or identify new purposes for which your Personal Information is being collected, used, and disclosed before such use ever occurs. Nonetheless, it is your responsibility to continuously check our Privacy Policy every time you visit our Website or before you decide to use our service to make sure that you agree with its terms and conditions. If you do not agree with the version of the Website’s Privacy Policy that exists at the moment of your access or use of our Website, you should terminate all access or use of the Website.

Type of Personal Information Collected

The types of Personal Information we collect for the purposes identified above can include, but are not limited to:

  1. Personal details such as your name, date of birth, education, gender, social insurance number, email address, and phone number

  2. Address details such as your home address and home status

  3. Employment details such as your source of income, type of employment, employer’s name

  4. Credit information such as your credit report containing personal credit information

  5. Bank details such as your bank name, institution number, transit number, account number, and banking transactions

  6. Technical information such as your IP address, browser type, login information, referring/exit pages, operating system, time zone setting, browser types and versions

  7. Visit information such as the URL to, through, and from our Website, products you viewed, page response time, download errors, length of visit, page interaction, and methods used to browse on our Website

Bankeroo may also collect your Personal Information from other sources including;

  1. Credit bureaus

  2. Bank account aggregators

  3. Payment service providers and financial institutions

  4. Fraud prevention agencies

  5. Search engines

  6. Research agencies

  7. Third party marketing lists lawfully obtained

Disclosure of Personal Information Collected

Your Personal Information will not be used or disclosed for purposes other than for those for which it was collected, except with your prior consent or as required by law.

Bankeroo will never sell your personal information to any third party.

We may use and disclose your Personal Information with third parties such as:

  1. Credit reporting agencies, ratings agencies and any business which provides information about your credit worthiness;

  2. Payment processors;

  3. Customer’s legal and financial advisers;

  4. Bankeroo employees who evaluate loan applications;

  5. Canadian Revenue Agency or other Government departments, agencies or bodies, to whom we may be required by law to disclose such information;

  6. Credit providers, financial institutions, and our financiers;

  7. Enquiry and debt collection agencies and their agents;

  8. Anyone to whom we may transfer our contractual rights;

  9. Any other person or party as set out in this privacy policy;

  10. In good faith, if Bankeroo believes that the disclosure of Personal Information is necessary to protect our rights, protect your safety or the safety of others, or to report suspected illegal activity, or to investigate violations of our terms and conditions;

  11. Any party approved by you.

Where Personal Information is disclosed to a third-party, Bankeroo will ensure that appropriate security measures are utilized to protect the use and disclosure of your Personal Information.

Bankeroo also reserves the right to disclose and transfer all Personal Information, visitor information, and other types of information collected via our Website to a third party in the event of a proposed merger or acquisition, or any other type of transaction, including a disposal, transfer, conveyance or financing of all, or any portion of Bankeroo. Should such an event occur, Bankeroo will try to require that the new entity follows our Privacy Policy with respect to all the Personal Information you have entrusted us with.


Security and How We Protect Your Personal Information

At Bankeroo, we go beyond industry standards to make sure your Personal Information is always safe and secure with us, including when it is being processed by a third-party. However, we are not responsible nor liable for the use of Personal Information by a third-party.

We use advanced technology, secure third-party suppliers, and well-defined corporate practices to ensure that your Personal Information is protected against loss, fraud or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held.

Bankeroo uses computer safeguards such as firewalls and data encryption, and authorizes access to Personal Information to all but a few employees that require this information to provide our services and products.

Bankeroo does not store payment or related personal data at our offices. Instead of storing information on company systems, your information will be stored in a secure data center that has been specifically chosen because of the heighten level of security it provides. Your information will be protected by physical, electronic and procedural safeguards which are compliant with all federal and provincial standards to guard your non-public information from any and all unauthorized access and use. Furthermore, your information is encrypted so that it cannot be read by anyone but us.

We will also use reasonable security measures in the disposal or destruction of your Personal Information to prevent any unauthorized parties from gaining access to your information after we have disposed of it.

However, you do acknowledge that despite all the precautions we may take to guarantee your security, no method of transmission on the Internet, or method of electronic storage, is 100% secure.

Where we have given you a username and password which enables you to access certain parts of our Website, you accept personal responsibility for safeguarding any PIN or password that might be assigned to you and are responsible for any misuse of these details. You also authorize us to act upon instructions and information from any person that enters your user id or password, even if it was not entered or provided by you.


Consent

Bankeroo collects your Personal Information through our Website, from various other third-parties and from information that is voluntarily provided to us. Use of the products and services offered by Bankeroo constitutes implied consent for the Collection, and of your Personal Information for all the identified purposes indicated above.

Bankeroo will make a reasonable effort to ensure that all its customers understand the purpose for which their Personal Information is being collected, and used, except when deemed inappropriate because of the sensitivity of the information or the reasonable expectations of the individual.

Bankeroo will obtain your consent to use and disclose your Personal Information at the time the Personal Information is collected. In certain circumstances, consent might be sought after the Personal Information was collected, but prior to the Personal Information being used or disclosed for a purpose not previously identified.

Bankeroo will never obtain consent through the use of deception. You acknowledge that an individual’s consent may be explicit or implied and that consent can be given either orally, electronically or in writing. You further understand that use of the products and services offered by Bankeroo constitutes implied consent for the Collection, and of your Personal Information for all of the identified purposes.

You understand that your consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent, please contact Bankeroo’s Privacy Department at customercare@bankeroo.com. We will inform you of the implications of withdrawing consent.

Bankeroo will not, as a condition of the supply of a product or service, require consent to the Collection, or use of your Personal Information beyond that required to fulfill the explicitly specified purposes for which the information is being provided. However, your refusal or withdrawal of consent may prevent Bankeroo from providing you with a product or service. Bankeroo will not unreasonably withhold products or services from you should you refuse or withdraw consent, but if the Personal Information is required to offer the product or service, Bankeroo may decline to deal with you. You agree that Bankeroo shall not be held liable for any product or service that was denied to you due to your refusal or withdrawal of consent

In certain cases, as permitted or required by law or deemed reasonable by Bankeroo from time to time, Bankeroo may collect, or use your Personal Information without your prior knowledge or consent. These circumstances may include but are not limited to;

  1. When the Collection, and use is permitted or required by law;

  2. When the Collection, and use is required to investigate a breach of an agreement or a contravention of a law;

  3. When the Collection or use is clearly in your interest but consent cannot be obtained in a timely manner;

  4. When use of the information is for an emergency that threatens the life, health, or security of an individual;

  5. When needed for debt collection, or to comply with a subpoena, warrant or court order, or as otherwise required by any Government department, agency or body;

  6. When the information is publicly available or subject to solicitor-client privilege.


Limiting Collection

Bankeroo will limit the amount and type of Personal Information we collect, use and disclose to that which is related to the identified purposes referenced above.

Bankeroo will only collect Personal Information by fair and lawful means.


Limiting Use, Disclosure, and Retention

Bankeroo will not use or disclose your Personal Information for purposes other than that for which it was collected, except without your prior consent or as required or permitted by law.

You understand that your Personal Information will be retained only as long as necessary for the fulfillment of the identified purposes, or as required to comply with all provincial and federal laws, enforce our terms and conditions, and prevent fraud or other financial crimes.

Your personal Information which was used to make a decision about your loan application will be retained long enough to allow you to access the information after the decision has been made and, in the event of an access request or challenge, long enough to exhaust any recourse you may have under the law. When your Personal Information is no longer required to fulfill the identified purposes, it will be destroyed, erased, or made anonymous in a secure fashion.


Accountability

Bankeroo is responsible for all the Personal Information under its control and has a designated individual who is accountable for Bankeroo’s compliance with this Privacy Policy. We take the safeguarding of your Personal Information seriously and we make sure that all the appropriate security measures are utilized to protect your Personal Information when it is being processed by a third party.

As part of our commitment to you, Bankeroo is continuously investing to develop and refine its Privacy Policy to better protect your Personal Information.

Upon written request, Bankeroo will gladly disclose the title of the individual(s) who oversees Bankeroo’s compliance with this Privacy Policy.


Accuracy of Your Personal Information and Updating your Bankeroo Account

You promise to make reasonable efforts to ensure that the Personal Information provided by you is accurate. We will also use best effort to ensure that the Personal Information we hold about you is accurate, complete and up to date for the purpose for which it is being used. If you would like to update your Personal Information, you can easily manage your information by logging into your dashboard and updating your details, or by contacting us at the address below:

Bankeroo Inc.
1730 Saint-Laurent Boulevard, suite 800
Ottawa, Ontario, K1G 3YYY7
Phone Number: 1-888-863-4112
Email: customercare@bankeroo.com

Upon written request, we will, as a general rule, inform you of the existence, use, and disclosure of your Personal Information and we will give you access to your Personal Information. Bankeroo will take reasonable efforts to make this information available to you within 30 calendar days of your request. You will be required to provide sufficient Personal Information to confirm your identity to Bankeroo before we can process your request. While our response will typically be provided free of charge, depending on the nature of the request and the amount of information and time involved, we reserve the right to impose a reasonable cost for the transcription, reproduction or transmission of such information to you. Customers can request to gain access to their Personal Information by making a request to customercare@bankeroo.com or contacting us at the address above.

You will be able to challenge the accuracy and completeness of the Personal Information we hold on record and have it amended as appropriate. Bankeroo will update any Personal Information held on file when a customer successfully demonstrates the inaccuracy or incompleteness of their Personal Information. Any unresolved disagreements relating to the accuracy and completeness of your Personal Information will be noted for as long as such information remains relevant.

You further acknowledge that Bankeroo may not be able to provide any or all of your Personal Information. If a request for Personal Information is denied, we will notify you of the reason for the refusal and the resources available for redress. Reasons why we might refuse you access to your Personal Information include, but are not limited to:

  1. Gathering the information is unreasonably costly;

  2. Release of the information might threaten your safety or the safety of others;

  3. Release of the information cannot be disclosed for legal, security, or commercially proprietary reasons; or

  4. Release of the information is subject to solicitor client or litigation privilege.


How we Use Cookies and other Tracking Technology

At Bankeroo, we use "website usage" information to help us create a better user experience for our customers. We collect certain non-personally identifiable information called “cookies” to compile general aggregated statistics about our users and how they use our website.

Bankeroo may also collect additional information in other ways not specifically described here. For instance, we may collect information pertaining to our marketing campaigns, customer service, or use other forms of aggregated data collected from third parties using application programming interfaces (APIs).

Bankeroo collects this information primarily for the purpose of providing its customers with a safe and effective website, but we may also use this information to monitor the general operations of our business and better understand and optimize how our Website is used. Other uses for cookies might include:

  1. Provide customer service and handle disputes;

  2. Detect illegal activity;

  3. Enforce our terms and conditions;

  4. Improve the user experience on our website;

  5. Process transactions and notifications.

You may be able to configure your browser or mobile device to not accept “cookies” or other types of tracking technology. However, if you do so, you might not be able to view our Website as intended and this might affect your ability to use the services we provide.


A Privacy Policy for Everyone to See

Bankeroo’s privacy policy and procedures regarding the Collection, use and disclosure of your Personal Information will be readily available on www.bankeroo.com. The information that we would make available include:

  1. How to contact the Privacy Officer;

  2. How to gain access to the Personal Information held by Bankeroo;

  3. A brief description of the type of Personal Information held by Bankeroo, including a general account of its use as well as the Bankeroo employees who have access to this information;

  4. The location of where your Personal Information is kept;

  5. General information concerning Bankeroo’s privacy policies and procedures.

We reserve the right to modify our Privacy Policy, without your consent, from time to time and such modifications shall be considered effective from the date they are posted on our website. In the event that we make any material changes to this Privacy Policy, we will notify you either by posting a new version on our website, by sending you a notification on your Bankeroo account, or by emailing you a link to review the new Privacy Policy. It is your responsibility to continuously check our Privacy Policy every time you visit our website or before you decide to use our service to make sure that you agree with the Privacy Policy.


Marketing

Your Personal Information will not be used or disclosed for purposes other than for those for which it was collected, except as required by law. Bankeroo will never sale your Personal Information to third-party marketing vendors.


Text Messages

By providing your cell phone number during the application process you are deemed to have provided us with your consent to send you text messages about your loan and our services. You hereby recognize that the text messages we send may be seen by anyone with access to or near your phone. Accordingly, you agree to hold us harm free of any third party who see our text messages and it is your responsibility to safeguard your phone and your text messages if you want them to remain private. Should your cell phone number change, you agree to notify us immediately.


We Always Give You the Choice to Opt-Out

With Bankeroo, you can always choose to be removed from our contact list to stop receiving our newsletter or marketing emails simply by contacting at us customercare@bankeroo.com.

However, as a requirement for obtaining one of our loans, you consent that you will not be able to unsubscribe from all our service announcement, as some of our notifications, which include but are not limited to electronic messages (such as e-mail and SMS), may contain important information about to your loan.


Sharing Content on Social Media

Some of the pages on our Website may allow you to share content via your profile on various social networks, including but not limiting to, LinkedIn, Facebook, Twitter, and other shared platforms. You hereby recognize that when you share content from our Website in this manner you also become subject to the terms and conditions, privacy policies and consent to disclosures of those third parties


Partial Invalidity

If any time, any part of this Privacy Policy, including these terms and conditions, are found to be illegal or unenforceable under, or inconsistent with the provisions of any applicable law or would by reason of the provisions of any such law, then such provision shall not apply and shall be construed so as not to apply to the extent that it is so illegal, invalid, unenforceable, and such provision shall be modified to allow it to be enforced in line with the intention of the original text to the fullest extent permitted by the applicable law. In any case, such finding will not affect the validity or enforceability of the remainder of Bankeroo’s Privacy Policy.


Complaints handling and our privacy policy

You can address any questions, comments or challenges concerning our compliance with any of the Privacy Policies to customercare@bankeroo.com.

Bankeroo will investigate all written complaints and will inform you of the outcome of the investigation. If we find a complaint to be justified and valid, we will take all appropriate measures to remedy the situation promptly and fairly.

If you are unsatisfied with the outcome, please note that this Privacy policy does not preclude you from any available recourse you have under the law regarding the protection of your Personal Information.

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