Last updated: December 20th, 2022
Personal Information – means information about an identifiable individual. Personal information does not include contact information (described below).
Aggregate Data – means information that has been aggregated in a manner that does not reveal any Personal Information and cannot reasonably be used to identify the client as the source of such data.
Platform – means collectively, the platform operated by PaySpyre at www.payspyre.com, and all associated subdomains, as made available from time to time.
Cookies – Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
Log Data – Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, and the time spent on those pages and other statistics.
Policy 1 – Collecting Personal Information
- 1.1 Unless the purposes for collecting Personal Information are obvious and the client voluntarily provides his or her Personal Information for those purposes, we will communicate the purposes for which Personal Information is being collected, either orally or in writing, before or at the time of collection.
- 1.2 We will only collect information from our clients that is necessary to fulfill the following purposes:
- To verify identity;
- To verify creditworthiness, including but not limited to instant bank verification;
- To identify client preferences;
- To understand the financial needs of our clients;
- To open and manage an account and provide access to PaySpyre’s Platform;
- To deliver requested products and services, including but not limited to loan agreements;
- To send Platform notifications and status updates;
- To send out membership information;
- To ensure a high standard of service to our clients;
- To meet regulatory requirements; and
- To collect and process payments.
- 1.4 We collect Log Data information that your browser sends whenever you visit our Site.
Policy 2 – Consent
- 2.1 We will obtain client consent to collect, use or disclose Personal Information (except where, as noted below, we are authorized to do so without consent).
- 2.2 Consent can be provided orally, in writing, electronically, through an authorized representative, through the Platform, or it can be implied where the purpose for collecting using or disclosing the Personal Information would be considered obvious and the client voluntarily provides Personal Information for that purpose.
- 2.3 Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of his or her Personal Information being used for mail-outs, the marketing of new services or products, notifications and the client does not opt-out.
- 2.4 Clients may withhold or withdraw their consent for PaySpyre Financial to use their Personal Information in certain ways, except in those circumstances where the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation.
- 2.5 We may collect, use or disclose Personal Information without the client’s knowledge or consent in the following limited circumstances:
- 2.6 You acknowledge and agree that we may collect or generate Aggregate Data in connection:
- When the collection, use or disclosure of Personal Information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the Personal Information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud; and
- To investigate an anticipated breach of an agreement or a contravention of law
- 2.6 You acknowledge and agree that we may collect or generate Aggregate Data in connection with access to the Platform and/or providing the client a particular service or product, and the client hereby grants PaySpyre and its service providers consent to use, reproduce, modify, adapt, create derivative works from, publicly perform, publicly display, distribute, sell, make and have made Aggregate Data for any lawful purpose.
Policy 3 – Using and Disclosing Personal Information
- 3.1 We will only use or disclose client Personal Information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- To facilitate the arrangement and implementation of loan agreement(s), which may include (but is not limited to) disclosure to third-party providers to complete bank verifications and obtain bank account data;
- To conduct client surveys in order to enhance the provision of our services;
- To contact our clients directly about products and services that may be of interest;
- 3.4 We may disclose or sell Aggregate Data to other persons or third-parties, in our sole discretion.
Policy 4 – Retention Policy
- 4.1 If we use client Personal Information to make a decision that directly affects the client we will retain that Personal Information for at least one year so that the client has a reasonable opportunity to request access to it.
- 4.2 Subject to policy 4.1, we will retain client Personal Information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
- 4.3 We may permanently retain Aggregate Data for future use.
- 4.4 We will store your Personal Information in Canada.
Policy 5 – Ensuring Accuracy of Personal Information
- 5.1 We will make reasonable efforts to ensure that client Personal Information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.
- 5.2 Clients may use the Platform to correct their Personal Information in order to ensure its accuracy and completeness.
- 5.3 If the Personal Information is demonstrated to be inaccurate or incomplete, we will correct the information as required or request that the Client provide corrected information.
Policy 6 – Securing Personal Information
- 6.1 We are committed to ensuring the security of client Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
- 6.3 We will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.
Policy 7 – Providing Clients Access to Personal Information
- 7.1. Clients have a right to access their Personal Information, subject to limited exceptions, including:
- aggregate data
- solicitor-client privilege;
- disclosure would reveal Personal Information about another individual; and/or
- health and safety concerns.
- 7.2. A request to access Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought.
- 7.3. Upon request, we will also tell clients how we use their Personal Information and to whom it has been disclosed if applicable.
- 7.4. We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
- 7.5. A minimal fee may be charged for providing access to Personal Information. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request.
- 7.6. If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.
Policy 8 – Questions & Complaints: The Role of the Privacy Officer or designated individual
- 8.2. Clients should direct any complaints, concerns or questions regarding PaySpyre’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of British Columbia.
Contact PaySpyre’s Privacy Officer at: firstname.lastname@example.org