Last Updated: June 15, 2023
Purpose of This Notice
At Solidifi we are committed to providing our clients with financial products and services to meet their needs. Our commitment includes protecting personally identifiable information we obtain about you. This Privacy Notice (“Notice”) describes how we collect, use, disclose and protect Personal Information (as defined below) that Solidifi Corp. and its Canadian subsidiaries, affiliates and divisions (“Solidifi,” “we,” “us,” or “our”) collect about you. This Notice applies to any party whom we receive Personal Information from or about, including, but not limited to our clients, our clients’ consumers, vendors and users of this website and our mobile applications (collectively, “Sites”) that display or link to this Notice. By using our Sites, you consent to the collection, use and disclosure of your Personal Information in compliance with this Notice and subject to the applicable federal and provincial laws of Canada.
Privacy for Other Websites
Our Sites may contain links to the websites of non-affiliated companies. Solidifi is not, however, responsible for the privacy practices or the content of these websites. We recommend that you review the privacy notice of each linked website that you visit.
Information We Collect
We collect certain personally identifiable information in the ordinary course of the business (also known as “Personal Information”). In particular, we may collect the following types of Personal Information about you:
- identifying information such as your name, address, contact information (e.g. telephone number, email address, etc.), social insurance number, driver’s license number, passport number or other similar identifiers;
- demographic information such as your date of birth, gender, preferred language, occupation, marital status or other similar information;
- financial information such as bank account numbers, credit card numbers, debit card numbers or other similar information;
- commercial information such as transaction records pertaining to the products or services we provide to you;
- network or internet browsing activity such as Internet Protocol (IP) address and your location as derived therefrom, data about your device, how you and your device interact with our Sites or other similar information; and
- other information you provide to us and the content of messages you send to us when you submit feedback, or when you make Personal Information inquiries, request products or services, contact us for customer support or complete surveys.
Collecting Personal Information is necessary for performance of the products and services and functionalities offered on the Site. If you decline to provide the requested Personal Information, we may not be able to provide some or all of the requested products or services or process your inquiry or other requests.
We keep the Personal Information we collect from you for so long as is reasonably necessary and proportionate to the original purpose for which it was collected. We base our criteria in determining appropriate retention periods on regulatory and legal requirements, contractual requirements, business needs and your expectations.
How Information is Collected
We obtain the types of Personal Information listed above from the following sources:
- directly from you when you complete forms and applications in connection with the products and services we provide, use our products and services or otherwise interact with us and our Sites;
- from our clients (i.e., lenders) when they provide us with information collected about you in connection with forms and applications completed by you or our clients on your behalf, products and services ordered by our clients on your behalf or other correspondence and communications between us and our clients related to your transaction; and
- directly from any affiliates and third-party service providers performing services for us in relation to your transaction.
We may also receive information about you from other third parties. Such third parties may provide information about you and your use of its products and services to us. We may also collect Personal Information about you from commercially or publicly available sources, including government entities.
Use of Personal Information
We may use the Personal Information we collect for one or more of the following business purposes:
- to fulfill or meet the reason you provided the information, including responding to your inquiries, questions and/or other requests or providing our services and products;
- to support, develop and improve our Sites, products and services;
- to create, maintain, customize and secure your account with us;
- to process your requests, transactions and payments and prevent transactional fraud;
- to help maintain the safety, security and integrity of our Sites, products and services, databases and other technology assets;
- marketing purposes;
- for such other purposes as may be described to you when collecting your Personal Information or as otherwise set forth in this Notice.
We will not collect additional types of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you prior notice. See “Changes to our Privacy Notice” for further details.
Disclosing Personal Information
We may disclose your Personal Information to the following third parties:
- our subsidiaries and affiliates;
- our clients (i.e. lenders);
- service providers and/or other third parties who provide or perform certain services on our behalf, or whom we otherwise engage in connection with our business;
- law enforcement or other governmental authorities if we become legally compelled to do so (i.e. by deposition, interrogatory, subpoena, court order or to comply with applicable law) or otherwise upon good faith belief that such disclosure is necessary for fraud prevention or otherwise to investigate or prevent a violation of law;
- a third-party purchaser or potential purchaser in connection with a potential merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Solidifi is among the assets transferred;
- potential third-party investors in Solidifi or any of its affiliates; and
- other parties for whom you have given us written authorization to disclose your Personal Information.
How we Safeguard and Store Personal Information
We implement and maintain physical, electronic and procedural safeguards reasonably designed to: (i) protect the security, confidentiality and integrity of your Personal Information; (ii) prevent unauthorized use, access to, disclosure, loss or theft of your Personal Information; and (iii) prevent and detect unauthorized intrusions into our systems.
To ensure that your Personal Information is adequately protected, we maintain internal policies and controls to prevent your Personal Information from being lost, accidentally destroyed, misused or unintentionally disclosed or accessed. Such protective measures include, but are not limited to, the following: (i) annual Company-wide cyber security and privacy training for all employees; (ii) operational controls and processes aligned to industry best practices; (iii) regular internal and external assessments of the Company’s information security posture; (iv) utilization of data-loss prevention tools; and (v) management approved policies and standards, including, without limitation, an Information Security Policy, a Security Incident Response Policy, a Data Protection Policy, an Information Classification and Retention Policy, a Physical Access Policy and a Remote Access Policy. Furthermore, we carefully select and monitor third party service providers and require that they protect the confidentiality of your Personal Information by implementing appropriate information security policies, processes, controls and other safeguards.
We store all of your Personal Information in Canada. However, it may be stored outside of the province or territory in which you reside.
Your Rights and Choices regarding Personal Information
Subject to applicable laws, you have a number of rights regarding your Personal Information including:
- Accessing your Personal Information – you may request a copy of the Personal Information that we have collected about you;
- Correcting your Personal Information – you may request that we correct Personal Information that we have collected about you;
- Deleting your Personal Information – you may request that we delete Personal Information that we have collected about you;
- Restricting Use of your Personal Information – you may opt-out of providing all or some of your Personal Information, provided, however, that if you choose to opt out, we may not be able to provide some or all of our services or products to you; and
- Withdrawing your consent – you may withdraw your consent to our use of your Personal Information, provided, however, that if you withdraw your consent, we may not be able to provide some or all of our services or products to you.
If you would like to exercise any of these rights regarding your Personal Information, please contact us through one of the methods set forth under “Chief Privacy Officer Contact Information” below.
Information from Children
Our Sites are meant for adults and are not intended or designed to attract children under the age of 16. We do not knowingly collect or sell Personal Information from any person under the age of 16 without permission from a parent or guardian. If you are under the age of 16, do not provide us with any information about yourself, including your name, address, email address, telephone number, etc. If we learn we have collected or received Personal Information from anyone under the age of 16 without parental consent, we will promptly delete that information. If you believe we might have any Personal Information from or about anyone under the age of 16, please contact us at:
50 Minthorn Boulevard, Suite 401
Markham, ON L3T 7X8
Attention: Compliance Department
Email: [email protected]
In accordance with the Accessibility for Ontarians with Disabilities Act, 2005, we take all reasonable measures to aid consumers requiring assistance to address any disability related needs. As such, consumers with disabilities may access this Notice in an alternative format by calling us toll-free at (877) 240-6310 or by contacting us by email at [email protected]. If you require telecommunication via teletype (TTY), please dial 711 for TTY.
Changes to Our Privacy Notice
We reserve the right to amend this Notice in our sole discretion at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice’s effective date. Your continued use of our website and/or our products and services following the posting of changes constitutes your acceptance of such changes.
Chief Privacy Officer Contact Information
If you have any questions or comments about this Notice, the ways in which we collect, use, and disclose your Personal Information and/or your choices and rights regarding such use or your desire to exercise any such right contemplated in this Notice, please do not hesitate to contact our Chief Privacy Officer at:
50 Minthorn Boulevard, Suite 401
Markham, ON L3T 7X8
Attention: Chief Privacy Officer
Phone: (877) 240-6310
Email: [email protected]