COLLECTION AND USE OF INFORMATION
The ways we collect information about you include:
information you provide us
information we collect from third parties about you
information we collect about you based on your use of our Services
A. INFORMATION YOU GIVE US
Borrowell collects Personal Information when you create an account to use our Services, access and use the Website or App, and when you communicate with us.
The Personal Information you give us may include your name, contact information (such as mailing address and email address), date of birth, income, information about your rent or mortgage payments, credit-related information, financial transaction history, your financial goals, referral source, credentials for third party services when you authorize us to connect to them on your behalf and your social insurance number. You are not required to provide your social insurance number in order to use our Services. However, if you choose to provide it, we use it to assist us in identifying you with credit reporting agencies and for internal fraud prevention purposes. You may provide us with other Personal Information when you contact us with questions, inquiries, complaints or suggestions.
For some of our services, we require you to verify or connect your bank account using a third party service to ensure we deposit and/or withdraw your funds through the correct account (your credentials are securely maintained by our service provider and Borrowell does not receive your bank account login information). For a loan, as part of this verification process, we may collect transaction history from your bank account in order to verify that your income deposits match the documents you have submitted and, in certain circumstances, to assess your suitability for the loan. We also verify your identity by asking you questions from Equifax or other identity verification service providers or by verifying your name, address, date of birth and mobile phone number with your mobile service provider.
If you enroll in Borrowell Bill Tracking and/or Rent Advantage, you will be asked to agree to have Borrowell connect to your bank account on your behalf using a third-party service. We will collect your bank account data and historic and on-going transaction-level data from your bank (such as your income, balance, bills and other payments) in order to personalize our Services to you, list your financial transaction history, track and predict your upcoming bills and estimate your available account balance, as the case may be. If you no longer wish to participate in Borrowell Bill Tracking, you can cancel your Borrowell Bill Tracking enrollment at any time by unsubscribing within the App. To cancel Rent Advantage, see the Rent Advantage Terms and Conditions.
When you communicate with us, we may monitor and record our telephone and chat conversations with you for training and quality assurance purposes. You will be provided with a notice at the beginning of any call that is being recorded. If you do not wish to have your call recorded, please let us know.
B. INFORMATION WE COLLECT FROM THIRD PARTIES ABOUT YOU
We collect Personal Information from third parties or service providers with your consent or where otherwise permitted or required by law. This information includes the credit reports and credit scores we obtain from Equifax or other credit reporting agencies, information about your credit history and other financial information which is relevant to the provision of our Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity. We also work closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, social media) and may receive information from them, such as whether or not you have taken out a product with them, what other products you may have used, and other such details. We might also collect information from other users like you through things like a member referral program.
If you register for an account in order to obtain a free credit score and/or credit report, Borrowell will obtain your consent and collect Personal Information (first and last name, date of birth, mailing address and telephone number) in order to obtain and provide you with your credit score and/or credit report for free from Equifax or another consumer reporting agency. Borrowell may also periodically use this information to attempt to pre-qualify you for credit offers such as: personal loans, auto loans, or credit card offers (“Pre-Qualification Offers”). This attempt to pre-qualify or pre-select may result in a soft credit check from Borrowell with a consumer reporting agency that will not impact your credit score. Pre-Qualification offers are not guaranteed approval and are subject to change. Members will still need to submit an application with participating providers.
Your credit report may include information such as the types and amounts of credit advanced to you, payment histories, negative banking items, collection actions, legal proceedings, previous bankruptcies and other information reported by your creditors. Borrowell also collects additional Personal Information from you, including your email address, financial goals, annual income range, and referral source. Borrowell uses your credit score, information from your credit report and other information you provide in order to better understand your financial needs and credit history, and provide you with tailored personal finance information, educational insights and recommendations which may include information on steps to improve your credit score, as well as personalized offers for Borrowell and third-party financial services products and services that may be of interest to you based on your credit-related and other information. Borrowell will obtain and provide your credit score and credit report to you for free at the time of account creation and on a regular basis thereafter as long as you have an account with Borrowell in order to provide you with up-to-date information and offers. If you wish to withdraw your consent to the collection and use of your credit score and credit report information, you may close your account at any time by contacting us.
C. INFORMATION WE COLLECT ABOUT YOU BASED ON YOUR USE OF OUR SERVICES
Each time you visit our Website or use our App we may collect certain information about how you access and interact with our Services using technologies which may include cookies, browser web storage, web beacons and similar information. The information we may collect includes the following:
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number
technical information, including the Internet protocol (IP) address, device information, device operations, your login information, browser type and version, time zone setting, operating system and platform
location information, including your internet protocol (IP) address or other device information or information about your visit to estimate your location (e.g., your city or province). You may control or disable the sharing of location Information via your device settings.
App Usage Information & Analytics:
Certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our Services. We will only use these location-enabled services on your device with your consent.
See Cookies and Interest-Based Advertising below for more information
USE OF INFORMATION WE COLLECT
Some examples of how we use the information we collect may include, but are not limited to, the following:
providing you with our Services, such as Borrowell Free Credit Score, Borrowell Credit Coach, Borrowell Loan, Borrowell Bill Tracking, Borrowell Credit Builder,Borrowell Marketplace or Rent Advantage
assessing your application and eligibility for a loan and, if approved, administering your loan and collecting outstanding debts
managing your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message or other means about your account
verifying your identity as part of our identity authentication process and other information you have provided to us (including your bank account, employment and income)
notifying you about changes to our Services
improving and enhancing our Website and Services and ensuring that content is presented in the most effective manner for you and your device
administer contests, promotions, surveys and other Website and App features
aggregating it on an anonymous basis with other data or removing direct personal identifiers for data analysis, market research (including to develop new products or services) and reporting purposes
undertaking analysis of your credit information and bank account data in order to identify and inform you of products that we consider are likely to interest you or be suited to your circumstances
responding to your inquiries about our Website, App and our Services
resolving any issues related to the Website, App and our Services
meeting legal and regulatory requirements
detecting and preventing fraud and other unauthorized or illegal activities
as otherwise permitted or required by applicable law.
If you have provided your consent, we may provide you with information about Borrowell or other products and services we feel may interest you or be best for you based on credit and other information we have about you (including emails, text messages, mail, in-app notifications and push notifications).
You can opt-out any time by contacting us as set out under Contact Us below, or by taking the following steps:
You can opt-out of receiving marketing emails at any time by clicking on the unsubscribe link included in our marketing email communications. Please note that you may continue to receive certain transactional or account-related emails from us.
To opt-out of receiving push notifications, you can manage your notification preferences within Your Account Settings on the App.
To opt-out of receiving push notifications on your mobile device, you can adjust your settings in your mobile device.
SHARING OF PERSONAL INFORMATION WE COLLECT
Service Providers: Your Personal Information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf. Borrowell uses service providers (including its authorized sub-contractors) to provide services such as billing, administration, debt collection and advertising and analytics services, to verify information you have provided to us (such as your identity and bank account number), to access your bank account data as reasonably necessary to provide our Services and to administer pre-authorized debit agreements. Borrowell may use service providers to host the Website, App, operate certain of its features, send email, SMS text messages or other communications, or manage and analyze data and our advertising effectiveness. Your Personal Information may be maintained and processed by Borrowell, affiliates and other third-party service providers in the US or other jurisdictions. In the event Personal Information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. Service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose Personal Information for their own marketing or other purposes.
Borrowell Marketplace Partners: If you use the Borrowell Marketplace, with your consent, we may share certain Personal Information we have about you (such as your contact information) with third party partners (for example, if we pre-populate an application with your Personal Information or provide you with a Pre-Qualification Offer). In these situations, we will confirm with you that we will be sending your Personal Information to the third party partner prior to sharing such Personal Information or we will send you to the partner’s site or platform for you to provide the information directly to them.
Investors: Borrowell Loans are funded through capital provided by third-party investors. Information about current and former customers will be shared on a non-identifiable basis with current as well as potential investors. The information provided to investors includes aggregated data derived from customer credit history data and loan performance information. The information is presented in a manner that the identity of an individual would not be identifiable from the data. We share this information in order to allow current and potential investors to evaluate the performance of the loans. For example, the data may be used to determine default and delinquency rates in the loan portfolio, or to present aggregate information on creditworthiness.
Sale of Business: Personal Information may be transferred as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Borrowell or as part of a corporate reorganization or stock sale or other change in corporate control.
Legal/Compliance: Borrowell and its affiliates and Canadian, US and other service providers may provide your Personal Information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud or as otherwise required or permitted by applicable Canadian, US or other law. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.
COOKIES, INTEREST-BASED ADVERTISING, AND ADDITIONAL INFORMATION ABOUT OUR WEBSITE
Visiting our Website
In general, you can visit the Website without telling us who you are or submitting any Personal Information. However, we and/or our service providers collect IP (Internet protocol) addresses from all visitors to the Website and other related information such as page requests, browser type, operating system and average time spent on our Website. This information is used to help us understand our Website activity, and to monitor and improve the Website.
Cookies, Tracer Tags & Web Beacons
Our Website or App uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. Cookies may provide us and our service providers with information that we will use to personalize our Website and App in accordance with a user’s preferences. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website or App, you may not be able to take advantage of all of the features of our Website or App.
Our Website and App may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website and App. These tracer tags are used to help us optimize and tailor our Website and App for you and other future visitors to our Website and App.
We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. For more information or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.
We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies, pixel tags and web beacons) on our Website and App in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and App and third-party websites and Apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate our online advertising campaigns.
Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website.
Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may, therefore, be less relevant to you and your interests.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
THIRD PARTY LINKS
SAFEGUARDS AND RETENTION
We maintain your Personal Information on a confidential basis on servers located in Canada and the United States. We have implemented appropriate administrative, technical and physical measures in an effort to safeguard the Personal Information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your Personal Information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.
ACCESS TO YOUR PERSONAL INFORMATION
You have the right to access, update, and correct inaccuracies in your Personal Information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in Personal Information we have in our custody or control by emailing or writing to us at the contact information set out in the “Contact Us” section below. You may also update certain contact information through our Website or App. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records.
WITHDRAWING YOUR CONSENT
You may withdraw your consent to our collection, use and disclosure of Personal Information at any time, subject to contractual and legal restrictions and reasonable notice, by emailing or writing to us at the contact information set out in the “Contact Us” section. If you choose to not provide us with certain Personal Information, we may not be able to provide you with certain Services and certain functionality of the Website and App may be unavailable to you.
Please contact our Privacy Officer if:
you wish to access, update, and/or correct inaccuracies in your Personal Information, or
you otherwise have a question or complaint about the manner in which we or our service providers treat your Personal Information.
You may contact our Privacy Officer by email at [email protected] or by mail at the following address:
Attn: Privacy Officer
1 University Ave, 3rd Floor, Toronto, Ontario, M5J 2P1
Last Updated: July 19, 2022