iCASH Privacy Policy

Last updated October 7, 2022
This privacy policy for Finabanx Ltd. (doing business as iCASH) and our affiliates and subsidiaries (‘iCASH’, ‘we’, ‘us’, ‘our’), elaborates how and why we might collect, store, use and/or share (‘process’) your information when you use our services (‘Services’), such as: Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our services. If you have any questions or concerns, please contact us at [email protected].

By voluntarily providing us with Personal Information (as defined herein) through the use of our Services (including via telephone) and the Website or by purchasing our products, you are consenting to its collection, use and disclosure in accordance with this Privacy Policy. You acknowledge and agree that such Personal Information may be transferred for processing from your current location to the offices and servers of iCash and authorized third parties referred to herein that may be located outside Canada, such as in the United States and the Philippines.

Personal information you disclose to us

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: Other types of information we collect include: 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:

Information automatically collected

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:

Information collected from other sources

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.

Collection and disclosure

Consent to the collection, use and disclosure of Personal Information may be given in various ways. Consent can be expressed or implied. In some circumstances, where notice has been provided to you about our intentions in respect to your Personal Information and you have not withdrawn consent, you will be considered to have consented for the purposes identified and described to you. By submitting Personal Information to us or our service providers and agents, you consent to the collection, use and disclosure of such Personal Information as described in this Privacy Policy or otherwise at the time of collection. Should you provide us and our service providers and agents with Personal Information of another individual, it is your responsibility to obtain consent from such person to enable us to collect, use and disclose such information for the purposes set forth in this Privacy Policy. Subject to legal or contractual requirements and reasonable notice, you may withdraw your consent at any time by contacting our Privacy Officer at the contact information set out at the end of this Privacy Policy. If you withdraw your consent, we may be limited or unable to provide you with certain services or information.

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.

Processing method

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.

2. Place
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].

The use of the collected data

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: 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 abovementioned purposes between iCASH and any third party.

Identifying Purposes
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:

Direct registration
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.

Cookies

We use "website usage" information to help create a better user experience, to facilitate the online application process and for internal research and reporting purposes. We collect certain information from users' browsers using small text files called "cookies." We also use session ID cookies to confirm that users are logged in. This type of cookie helps us recognize you, if you visit multiple pages on our site during the same session, so that we do not need to require a password to access each page. You can set your browser to notify you when you receive a cookie or refuse cookies altogether. Please note: If you do not accept cookies from us, you will not be able to use our site.

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.

Correspondence Management

By registering, you agree to the terms and conditions of this Privacy Policy and give us and/or any of our affiliates permission where permitted by law to use your email address and/or full address in order to send relevant and promotional materials.

Contacting User

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.

Rights and Personal Data

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: 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.

Limiting use, disclosure and retention

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: 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.

Safeguards

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: 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.

Children Under the Age of 13

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.

Privacy Policy updates

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 reserve the right to make changes to this Policy without prior notice. The updated version will be indicated by ‘Last updated’ date and the updated version will be effective as soon as it is accessible. It is therefore strongly recommended that you visit and review our Privacy Policy frequently so that you stay informed on how we are protecting your information.

Website maintenance

We may at any time interrupt our online services to perform needed managerial updates and improvements without prior notification.

Legal action

We may use content collected through our system if legal action against a user is started due to improper use of the system.