As part of the application and approval process when you register to use our Services, your voluntarily given Personal Information may be collected. We may collect Personal Information that is necessary for our identified purposes (“Personal Information”) from our clients, which may include:
- Email addresses
- Phone or cell number
- Mailing address and location information
- Contact preferences
- Payment-related information such as banking information and history
- Information about the loan or account, current and historical information, balance and indebtedness, account transaction history and records relating to the handling of any inquiries or complaints
- Contact or authentication data and other browsing data
- Social Insurance Number/Social Security Number and income
- Such information that may be necessary for our identified purposes and that is collected with your consent or as permitted or required by law
Other types of information we collect include:
- Non-Personal Information, that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as, demographic information, or statistical or aggregated information. We may derive personal and non-Personal Information, statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific app feature.
- Technical information, including your login information, device type and unique device identifier, IP address, operating system, browser type, network information, time zone setting and usage details.
Some of this information may be stored in our system to better identify clients for future transactions.
Failure to provide the Personal Information required for us to provide the Services, such as the assessment of your loan application may tamper with the provision of the service offered by us.
We use Personal Information as required by provincial and federal regulators to comply with applicable law, such as promoting safe and responsible lending.
When you use the Website, apply for a loan with us or purchase or use our Services, we ask to create an account and then to voluntarily provide certain Personal Information. We collect, use, and disclose this information to:
- Determine your eligibility for the loan according to the law of the appropriate province, as well as to obtain credit assessment, details of employment and any other services that may be of your interest;
- Maintain your account;
- Inform you about their account and any products and services that may be of your interest;
- Securely process the funding and repayment of transactions to which you and we may contract;
- Extract information for the purpose of generating statistics and analysis for the purposes of conducting and improving our business and to ensure a high standard of service;
- Meet all the legal and regulatory requirements;
- Confirm your identity, to prevent and detect fraud;
- With your consent to iCash’s insurance partners to the extent that it is required to provide the Services or so that they may offer other products and services that may be of interest to you;
- Collect any debt that may arise.
We automatically collect certain information when you use, visit or navigate our Services. This information does not reveal your specific identity, but may include device and usage information, such as your IP address, browser and device characteristics, referring URLs, location and other technical information.
This kind of information is needed to maintain the security and operation of our Services and for analytics and reporting purposes.
The data collected includes:
- Log and usage data. Depending on how you interact with us, this log data may include IP address, device information, browser type, information about your activity (such as date/time stamps associated with usage, pages and files viewed, searches and other actions such as what features you use)
- Device data. We collect information about your computer, phone, tablet, or other device you use to access our services. Depending on the device used, the data collected may include IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, operating system and system configuration information.
- Location data. We collect information such as information about your device’s location, but the information precision depends on the type and settings of the device used.
For the purpose of providing accurate and relevant marketing, offers and Services to you, we may obtain information about you from other sources, such as public databases, affiliate programs, data providers and other third parties. This information may include IP addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted marketing.
In certain circumstances, as permitted or required by law, we may collect, use or disclose Personal Information without the knowledge or consent of the individual. These circumstances include but are not limited to: Personal Information that is publicly available as defined by regulation; where collection is clearly in the interests of the individual and consent cannot be obtained in a timely way; where disclosure is made for the purposes of collecting a debt owed to us; or to comply with a subpoena, warrant or court order.
Additionally, to the abovementioned, Personal Information may be shared between our affiliates or subsidiaries (including those that may be located outside Canada) for internal audit, billing, management or administrative purposes including actions related to legal actions. For the purposes mentioned above, we may transfer your Personal Information to service providers, including affiliates or other third-party organizations to perform actions, such as data processing, marketing, customer service, security, collections, financial and taxation services. Should your Personal Information be transferred, we use contractual or other means that ensure that a comparable level of protection is provided. Some of our services providers may be located outside of Canada, such as in the United States and the Philippines, and will be subject to applicable legal requirements in the country they are located, including lawful requirements to disclose Personal Information to government authorities in certain circumstances.
We may also use and disclose Personal Information in connection with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets (including your loan and any agreement to which it relates), for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of our business or assets may use and disclose your Personal Information for similar purposes as those described in this Policy.
We may disclose your Personal Information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law.
We process your information to provide, improve and administer our services. We use that to communicate with you, for security and fraud prevention and to comply with the law. Our processing method ensures that unauthorized users are prevented from accessing the system. The data will be kept in the system according to need. Some information may be retained even after you are finished repaying the loan. This allows us to better identify users in the future. Loan agreements and other documents related to the process of obtaining the loan must be kept for a number of years (the length depends on specific provincial regulations).
1. Method of Processing
The person responsible for the control of data (the “Data Controller”), processes the data of users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the data.
The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller’s activities, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of the site (Administration, Sales, Marketing, Legal, System Administration Departments) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Finabanx.
The data is processed at our headquarters and in any other places where the parties involved with the processing are located. If you would like to know more about the protection of your data, please reach out to our Privacy Officer at [email protected].
We collect and use Personal Information for purposes limited to those which are related to its businesses, which include providing financial services to its customers under lease agreements. We collect Personal Information primarily from you, for instance through applications and supporting documentation you provide. We may also collect Personal Information about you through your ongoing interactions with us, from references, employers and other financial institutions you have identified in your application as well as credit bureaus and other third-party sources. For example, we may collect Personal Information from credit bureaus for the purpose of locating you to collect outstanding debts. In connection with loan agreements, we may also collect Personal Information from credit bureaus in order to verify your current and ongoing creditworthiness and other information you may provide to us.
All information and data concerning you are collected to allow us to provide our Services, as well as for the following purposes: analytics, interactions with external social networks and platforms, contacting you, advertising, remarketing and behavioral targeting, managing email addresses and sending messages, using geolocation, content performance and features testing (A/B testing), registration and authentication, displaying content from external platforms and social applications
You acknowledge and consent to your personal data being used and shared with a third-party credit reporting agency for business purposes that include, but are not limited to:
- Investigating and monitoring of internal business practices
- Provision and supply of services to the user
- Research, testing and development of products offered by iCash
- Detection of security breaches and protection against them
Were any of the following to be carried out, prior to any disclosures of personal data, a contract would be entered into that will ensure the protection, security and use for the above mentioned purposes between iCash and any third party.
The data used for each purpose is outlined in the specific sections of this document. Data is collected and where permitted by law will be used for the following services:
These services allow user data to be utilized for advertising and promoting products and services that may be of interest to customers, including by mail, email, text message, telephone, automatic dialers and announcing devices.
The services contained in this section enable us to monitor and analyze web traffic and can be used to keep track of user behavior.
3. Contacting the user
- Contact form
By filling in the contact form with their data, you authorize us to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form's header.
Data collected: email, first name and last name.
- Mailing List or Newsletter
By registering to the mailing list or to the newsletter, your email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature. Your email address might also be added to this list as a result of signing up to use our services.
Data collected: email, first name and last name.
- Phone contact
Should you provide us with your phone number, you acknowledge and consent that you might be contacted by phone call and SMS (text message) for commercial or promotional purposes related to our services, as well as for fulfilling support requests.
Data collected: phone number and name.
4. Content Performance and Features Testing (A/B testing)
The services contained in this section allow us to track and analyze your responses concerning web traffic or behaviors regarding changes to the structure, text or any other component.
We may collect, use and share your location in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, your location data may be tracked by us.
Data collected: geographic position.
6. Registration and authentication
By registering or authenticating, you allow us to identify you and give you access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, we will be able to access data, stored by the third-party service providers, for registration or identification purposes.
You register by filling out the registration form and providing the data directly to us. Data collected includes: address, city, country, date of birth, email, fax number, first name, gender, last name, phone number, profession, province, Social Insurance Number and other types of data.
We also use a persistent cookie that stores your login ID (but not the password) to make it easier to login when you come back to us on future visits. We encode our cookies so that only we can interpret the information stored in them, but they do not contain personally identifiable information. You can remove or block the persistent cookie using the settings in their browser if they want to disable the feature.
To comply with Google's advertising policies, we use Google Adwords Search Engine Marketing (Pay Per Click) and Display Advertising (Remarketing and Google Display Network). We use Google AdWords Remarketing in compliance with the Google AdWords Interest-Based Advertising Policy, which means that you may see our advertisements on Google and other third-party websites on the internet after visiting our website.
We use Google Analytics for Display Advertising, including Remarketing, Google Analytics Demographics and Interest Reporting, Google Display Network Impression Reporting and the DoubleClick Campaign Manager integration. You have the option to opt out of Google Analytics for Display Advertising and customize Google Display Network ads. For all the currently available opt-outs, please visit https://tools.google.com/dlpage/gaoptout
We use the data collected through Google Analytics Demographics and Interest Reporting to better understand our website visitors in terms of demographics and interests, to improve our website content in order to cater to our audience, and to customize advertisements based on our audience's interests and demographics.
When you complete an “information request form”, you are thereby agreeing to the use of your name and email address in a reply to your request as provided through the request form. When you register your name to receive our newsletter and promotions, you consent to receive marketing information at the provided email address. To this end, your email will be added to our emailing marketing group. Your phone contact will be used mostly to address your request and to provide support.
1. Interaction with External Social Networks and Platforms
Such services allow interactions with social networks or other external platforms directly from the Website's pages. The interactions and information obtained by the Website are always subject to your privacy settings for each social network.
2. Managing Email Addresses and Sending Messages
Such services make it possible to manage the Email Contacts Database used to communicate with you via email. The services used to collect data concerning the date and time when the mail is viewed by you, as well as when you interact with incoming mail, for example by clicking the links included in the email.
We allow you to manage your account and information you provided. Once you log in, you may update your Personal Information, if your account is in good standing. In that case, we will retain only the Personal Information required by law or that we deem necessary. We may not be able to provide access to some or all individual's Personal Information. Reasons for refusing access may include situations where:
- Personal Information is unreasonably costly to provide;
- The release of the Personal Information may threaten the life or security of a third party;
- Personal Information is subject to, or generated in a formal dispute resolution process;
- Personal Information cannot be disclosed for legal, security, or commercial proprietary reasons; or
- Personal Information is subject to solicitor-client or litigation privilege.
You are entitled to opt-out from our mailing list. Furthermore, you may request not to be contacted by us at any instant, provided that your file is in good standing with us and with our subsidiary websites. That means that you have made your payments on time.
All information provided can be used in legal proceedings and/or in the Court of Law if deemed necessary. Additionally, we will release any information if mandated by local, provincial, or federal laws and/or their officers.
You also have a right to access the personal data belonging to you that is under our control subject to any legal restrictions or rights of refusal. Such a request for access must be made in writing stating the details of the personal data you are requesting to iCash’s Privacy Officer, iCash, 372 Bertha Street, Hawkesbury, Ontario, K6A 2A8. To ensure we disclose information to you only, with your request please include photocopies (front and back) of two (2) pieces of government issued identification so that we may verify your identity. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.
Copies of records containing Personal Information may be subject to a fee. If this is the case, we will inform you of the amount of the fee in advance. We will use our best efforts to ensure that Personal Information is as accurate, complete and up-to-date as necessary for the identified purposes. If you successfully demonstrate the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If we refuse access to Personal Information or disagree with an assertion that information held by us is incorrect, we will provide a written explanation for such refusal and a description of our complaint’s procedure should you decide to challenge such written explanation. Your right to access or correct Personal Information is subject to applicable legal restrictions. To prevent fraudulent access to the Personal Information stored by iCash, we may take reasonable steps to verify your identity before granting access or making corrections.
Personal information will not be used or disclosed for purposes other than those for which it was collected, excluding minor exceptions and after obtaining express consent of the individual affected or as required by law.
In addition, we may use and disclose your Personal Information to third parties that are as follows:
- A Finabanx affiliate seeking information as an agent of the individual;
- A Finabanx agent that will evaluate the customer's creditworthiness or to collect a potential debt;
- The issuer and/or payer of negotiable items to confirm identity;
- A third party – where individual consents to disclosure;
- A third party – where disclosure is required by law;
- A public authority or an agent of said public authority where there is imminent danger to the life or property of an individual that could be avoided or minimized by disclosure; and
- A third party hired to conduct surveys in order to enhance our products and services to meet customer needs.
- A third party credit reporting bureau for the purpose of payment reporting and research and development purposes.
Where Personal Information is disclosed to a third party, we will ensure that appropriate security measures are utilized to protect the use and disclosure of Personal Information.
Only Finabanx employees and those of authorized third parties or service providers can be authorized or granted access to Personal Information of customers when their duties require it.
We will retain Personal Information only if necessary for the fulfillment of identified purposes and/or as required by law.
Personal information will be protected by reasonable security safeguards appropriate to the sensitivity of the data collected.
We are committed to the protection of Personal Information against loss, theft, unauthorized access, disclosure, duplication, use and modification regardless of the format in which the data is held.
We will protect Personal Information disclosed to third parties by means of contractual agreements with respect to the confidentiality of the Personal Information and the purposes for which the Personal Information is to be used.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
We will use reasonable security measures in the disposal of Personal Information.
You must immediately notify us if:
- Anything abnormal occurs while using our website;
- you suspect they are the victim of a fraud utilizing Finabanx name,
- you are contacted by phone number or by email address through our website.
You may be liable for an unauthorized transaction depending on the promptness of your response notification to us. We will inform you about the results of our investigation within ten (10) business days. We will correct any errors we may have made, provided the error is brought to our attention promptly.
By signing up, you agree to give access to your registration information in order to authenticate them.
Our Website and our Services are not intended for children under the age of majority in their respective jurisdiction. No such person may provide any information to or on the Website. Without limiting the foregoing, we do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Website or on or through any of its features/register on the Website, use our Services, or provide any information about yourself to us, including your name, address, telephone number, email address. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact our Privacy Officer.
We are under no obligation to inform you about any modifications made to our Policies via any correspondence (post mail or electronic mail); it is your responsibility to keep up to date. Having said that, all additions and modifications will be clearly marked on our website located at iCash.ca.
We may at any time interrupt our online services to perform needed managerial updates and improvements without prior notification.
We may use content collected through our system if legal action against a user is started due to improper use of the system.
Last updated April 12, 2023