Privacy Policy

This privacy policy pertains to Hovert Extrade Ltd. (operating under the trade name ePayLoan) and its affiliated companies and subsidiaries (referred to as 'ePayLoan', 'we', 'us', 'our'). It outlines the purposes and methods by which we may collect, store, utilize, and/or disclose ('process') your information when you engage with our services ('Services'), including:

• Explore our website at ePayLoan.ca, encompassing, without limitation, all other websites and mobile applications under our ownership and operation, along with all subdomains offered through such sites or the main website. This includes all downloadable applications, features, functionality, content, or information provided by us (referred to as the "Website").
• Connect with us through various other channels, such as marketing initiatives and social media interactions.
• Obtain, request, or utilize the products and services offered by us.
• Interact with you directly, such as completing forms, communicating with us, or participating in contests or promotions sponsored by us.

Reviewing this privacy policy will help you comprehend your privacy rights and options. If you disagree with our policies and procedures, please refrain from using our services. For any inquiries or concerns, kindly reach out to us at info@epayloan.ca. By willingly 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 giving consent to its collection, use, and disclosure as outlined in 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 ePayLoan and authorized third parties mentioned herein that may be situated outside Canada, such as in India, the United States, and the Philippines.

Personal Information Declared to us by the client

During the registration process to utilize our Services, we gather Personal Information provided voluntarily by you. This Personal Information is essential for our stated purposes and may encompass:

• Name
• Email addresses
• Phone or cell number
• Mailing address and location details
• Profession
• Cookies
• Contact preferences
• Payment-related details like banking information and transaction history
• Information concerning loans or accounts, both current and historical, including balance, indebtedness, transaction history, and records pertaining to inquiries or complaints
• Contact or authentication data, along with other browsing data
• Social Insurance Number/Social Security Number and income

We only collect such information with your explicit consent or as permitted or mandated by law.

Additionally, we gather other forms of information, such as Non-Personal Information. This type of information does not directly or indirectly disclose your identity or pertain directly to an identified individual. It may include demographic details or statistical or aggregated data. From Personal Information, we may derive both personal and non-personal Information, as well as statistical or aggregated data. For instance, we might aggregate Personal Information to determine the percentage of users accessing a particular app feature.

• Essential technical details, such as login credentials, device specifications, IP address, operating system, browser information, network details, time zone settings, and usage patterns, are gathered. Some of this data may be retained in our system for future reference to better serve our clients.
• It is crucial to provide the necessary Personal Information for us to deliver our Services effectively, including assessing loan applications. Failure to do so may impact our ability to provide the desired service.
• We utilize Personal Information in accordance with provincial and federal regulations to ensure compliance with applicable laws, particularly in promoting safe and responsible lending practices.
• When utilizing our Website, applying for loans, or engaging with our Services, you are prompted to create an account and voluntarily furnish specific Personal Information. We collect, utilize, and disclose this information for various purposes:
• Determining loan eligibility and conducting credit assessments in accordance with provincial laws, along with providing additional services as needed.
• Managing your account and keeping you informed about relevant products and services.
• Facilitating secure transactions, including funding and repayment.
• Analyzing data to improve business operations and maintain service standards.
• Meeting legal and regulatory obligations.
• Verifying your identity to prevent fraud.
• Sharing information with ePayLoan’s insurance partners, with your consent, as necessary for providing services or offering relevant products.
• Managing debt collection if required.

Automatically Gathered Data

We automatically gather specific information during your use, visitation, or navigation of our Services. This information does not divulge your individual identity but may comprise device and usage details, such as IP address, browser specifications, referring URLs, location data, and other technical particulars.

This information is essential for maintaining the security and functionality of our Services, as well as for analytical and reporting purposes. The data collected encompasses:

• Log and usage data: This includes IP address, device specifics, browser type, activity details (like date/time stamps associated with usage, viewed pages and files, searches, and feature utilization).
• Device data: Information regarding the computer, phone, tablet, or other device utilized to access our services is collected. Depending on the device, data collected may involve IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, operating system, and system configuration details.
• Location data: Information related to your device's location is collected, although the precision of this data relies on the type and settings of the device used.

Data Obtained from External Sources

To ensure precision and relevance in marketing, offers, and Services delivered to you, we acquire information from alternate sources, including public databases, affiliate programs, data providers, and other third-party entities. This data may encompass IP addresses, social media profiles, social media URLs, and customized profiles, utilized for targeted marketing endeavors.

Acquisition and Disclosure

Consent for the collection, utilization, and revelation of Personal Information may be provided through various means, either expressed or implied. If we have provided notice regarding our intentions regarding your Personal Information and you haven't withdrawn consent, it will be deemed that you've consented to the identified purposes. By providing Personal Information to us or our service providers and agents, you agree to its collection, utilization, and disclosure as outlined in this Privacy Policy or as communicated during collection. If you provide Personal Information of another individual, it's your responsibility to obtain their consent for us to collect, utilize, and disclose such information as stated in this Privacy Policy. You may withdraw your consent by contacting our Privacy Officer, but this may limit or prevent us from providing certain services or information.

In specific circumstances, as allowed or mandated by law, we may collect, use, or disclose Personal Information without the individual's knowledge or consent. These circumstances include situations where Personal Information is publicly available, when collection is clearly in the individual's interests and obtaining consent is impractical, when disclosure is necessary for debt collection, or to comply with legal obligations such as subpoenas or court orders.

Furthermore, Personal Information may be shared among our affiliates or subsidiaries, including those located outside Canada, for internal audit, billing, management, or administrative purposes. We may transfer your Personal Information to service providers, affiliates, or third-party organizations for various purposes such as data processing, marketing, customer service, security, collections, and financial services. Measures are taken to ensure a comparable level of protection when transferring Personal Information, particularly when service providers are located outside Canada.

Additionally, Personal Information may be used and disclosed in connection with the proposed or actual financing, sale, or disposal of our business or assets, including your loan agreements. Assignees or successors of our business or assets may use and disclose Personal Information for similar purposes.

We may disclose Personal Information to meet legal, regulatory, insurance, audit, and security requirements, or with your consent, or as permitted or required by law.

Methodology of Data Processing

We engage in processing your information to deliver, enhance, and manage our services. This encompasses communication with you, ensuring security and fraud prevention, and adherence to legal requirements. Our processing method is designed to deter unauthorized access to the system. Data retention aligns with operational needs, and certain information may persist even after loan repayment to facilitate future user identification. Loan agreements and related documents are retained according to provincial regulations.

1. Data Processing Method:

The Data Controller, responsible for data management, employs appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of data. Data processing utilizes computers and/or IT tools, following established organizational procedures strictly aligned with stated purposes. Besides the Data Controller's involvement, certain personnel (such as Administration, Sales, Marketing, Legal, and System Administration departments) or external entities (like third-party technical service providers, mail carriers, hosting providers, IT companies, and communication agencies) may access the data as Data Processors if appointed by ePayLoan.

2. Processing Location:

Data processing occurs at our headquarters and any other relevant locations involving the parties responsible for processing. For further inquiries regarding data protection, please contact our Privacy Officer at info@epayloan.ca.

Utilization of Gathered Data

We gather and utilize Personal Information solely for purposes directly related to our business operations, specifically in providing financial services to our customers through lease agreements. This information is primarily collected from you, such as through applications and supporting documents provided by you directly. Additionally, we may obtain Personal Information from ongoing interactions, references, employers, other financial institutions identified in your application, credit bureaus, and third-party sources. For instance, information from credit bureaus may be gathered for debt collection purposes or to assess creditworthiness for loan agreements.

All data pertaining to you is collected to facilitate the provision of our Services, as well as for the following purposes: analytics, interactions with external social networks and platforms, communication, advertising, remarketing, and behavioral targeting, email address management and messaging, geolocation, content performance, and feature testing (A/B testing), registration and authentication, and displaying content from external platforms and social applications.

You acknowledge and consent to the use and sharing of your personal data with third-party credit reporting agencies for various business purposes, including internal investigations, service provision, product research and development, and security breach detection and prevention.

Any disclosure of personal data to third parties for these purposes would be preceded by a contract ensuring the protection, security, and appropriate use of the data between ePayLoan and the third party.

Identification of Purposes:

The data used for each purpose is detailed in the relevant sections of this document. Data collected may be used for the following services:

1. Advertising: Utilizing user data for advertising and promotion via various channels such as mail, email, text message, and telephone.

2. Analytics: Monitoring and analyzing web traffic and user behavior.

3. Contacting the user: Through contact forms, mailing lists, newsletters, and phone contacts for informational or promotional purposes related to our services.

4. Content Performance and Features Testing (A/B testing): Tracking and analyzing user responses to changes in web content.

5. Geolocation: Collecting and utilizing location data for location-based services.

6. Registration and authentication: Allowing user identification and access to dedicated services through registration and authentication processes. This may involve direct registration or third-party registration and authentication services.

Data collected for registration and authentication purposes may include address, city, country, date of birth, email, fax number, first name, gender, last name, phone number, profession, province, Social Insurance Number, and other relevant data.

Cookies

We utilize website usage data to enhance user experience, streamline the online application process, and conduct internal research and reporting. This involves gathering certain information from users' browsers through small text files known as "cookies." Session ID cookies are employed to verify user logins and maintain login status across multiple pages during the same session, thus eliminating the need for repeated password entry. Users can adjust their browser settings to manage cookie preferences, though refusal of cookies may restrict site functionality.

A persistent cookie is utilized to store login IDs (excluding passwords), simplifying future login attempts. These cookies are encoded to ensure privacy, containing no personally identifiable information. Users can opt to remove or block persistent cookies via browser settings if desired.

In accordance with Google's advertising policies, we employ Google Adwords Search Engine Marketing (Pay Per Click) and Display Advertising (Remarketing and Google Display Network). AdWords Remarketing aligns with Google's Interest-Based Advertising Policy, enabling our advertisements to appear on Google and third-party websites subsequent to visiting our site.

We leverage Google Analytics for Display Advertising, encompassing Remarketing, Demographics and Interest Reporting, Display Network Impression Reporting, and DoubleClick Campaign Manager integration. Users have the option to opt out of Google Analytics for Display Advertising and customize Google Display Network ads. For available opt-outs, please refer to: [https://tools.google.com/dlpage/gaoptout](https://tools.google.com/dlpage/gaoptout).

Data acquired via Google Analytics Demographics and Interest Reporting aids in understanding website visitors' demographics and interests, enhancing website content to suit audience preferences, and tailoring advertisements based on audience demographics and interests.

Management of Correspondence

By registering, you consent to the terms and conditions outlined in this Privacy Policy. You authorize us and/or any of our affiliates, where permitted by law, to utilize your email address and/or full address for the purpose of sending relevant promotional materials.

User Communication

When you complete an "information request form," you are consenting to the use of your name and email address for replying to your request, as provided within the form. Similarly, by registering your name to receive our newsletter and promotions, you are agreeing to receive marketing information at the email address provided. Your email will be included in our email marketing group for this purpose. Your phone contact will primarily be used to address your requests and provide support.

Interaction with External Social Networks and Platforms:

These services enable interactions with social networks or other external platforms directly from the Website's pages. Any interactions and information acquired by the Website are subject to your privacy settings for each social network.

Managing Email Addresses and Sending Messages:

These services facilitate the management of the Email Contacts Database used for communication via email. They may also collect data concerning the date and time when emails are viewed by you, as well as when you interact with incoming mail, such as by clicking on included links.

Rights and Personal Data Management

You have the ability to manage your account and the information you provided. Upon logging in, you can update your Personal Information if your account is in good standing. In such cases, we will retain only the Personal Information required by law or deemed necessary. However, access to some or all individual Personal Information may not be provided under certain circumstances.

These may include situations where:

Violations of these Terms of Use

Violations of these Terms and Conditions of Use will result in the following actions:

• Providing the Personal Information is unreasonably costly.
• Releasing the Personal Information may endanger the life or security of a third party.
• The Personal Information is subject to, or generated in, a formal dispute resolution process.
• The Personal Information cannot be disclosed for legal, security, or commercial proprietary reasons.
• The Personal Information is subject to solicitor-client or litigation privilege.

You have the right to opt-out of our mailing list and request not to be contacted by us at any time, provided your account is in good standing, indicating timely payments. All information provided may be used in legal proceedings and/or in the Court of Law if necessary. Additionally, we will release any information if mandated by local, provincial, or federal laws and/or their officers.

You also have the right to access your personal data under our control, subject to any legal restrictions or rights of refusal. Requests for access must be made in writing to ePayLoan’s Privacy Officer at the following address: epayLoan, 300-5500 North Service Road, Burlington, Ontario, L7L 6W6. To ensure disclosure only to you, please include photocopies (front and back) of two (2) pieces of government-issued identification for identity verification. We may charge a fee for accessing your personal information, and we will notify you of any fee in advance.

Copies of records containing Personal Information may be subject to a fee, and we will inform you of the amount in advance. We make every effort to ensure that Personal Information is accurate, complete, and up-to-date for the identified purposes. If you demonstrate inaccuracies or incompleteness, we will amend the information accordingly. If access to Personal Information is refused or there is a disagreement regarding its accuracy, we will provide a written explanation for such refusal, along with details of our complaint procedure if you decide to challenge it. Your right to access or correct Personal Information is subject to applicable legal restrictions. To prevent fraudulent access, we may verify your identity before granting access or making corrections.

Restrictions on Use, Disclosure, and Retention

Personal information will not be utilized or disclosed for purposes other than those initially collected, except for minor exceptions or when express consent is obtained from the affected individual or as mandated by law.

Moreover, we may use and disclose your Personal Information to the following third parties:

• A ePayLoan affiliate acting as an agent of the individual.
• A ePayLoan agent responsible for assessing the customer's creditworthiness or collecting potential debts.
• The issuer and/or payer of negotiable items for identity verification.
• A third party with the individual's consent for disclosure.
• A third party as required by law.
• A public authority or its agent in instances where imminent danger to life or property could be mitigated by disclosure.
• A third-party hired for surveys to enhance our products and services based on customer needs.
• A third-party credit reporting bureau for payment reporting and research and development purposes.

When Personal Information is disclosed to a third party, appropriate security measures are implemented to safeguard its use and disclosure. Only ePayLoan employees, authorized third parties, or service providers are granted access to customers' Personal Information when necessary for their duties.

We retain Personal Information only as long as necessary to fulfill identified purposes and/or as required by law

Security Measures

We will employ adequate security measures to safeguard personal information according to its sensitivity. Our commitment entails protecting personal data from loss, theft, unauthorized access, disclosure, duplication, utilization, and alteration, irrespective of its storage format. Personal information shared with third parties will be safeguarded through contractual agreements ensuring confidentiality and specifying authorized purposes for its use.

The protection of your information also relies on your cooperation. If you receive a password for accessing specific sections of our website, it is your responsibility to maintain its confidentiality and refrain from sharing it with others. While we strive to secure your personal information, please note that transmitting data over the internet carries inherent risks. We cannot guarantee absolute security during transmission to our website. Any such transmission is undertaken at your own risk. We do not assume liability for evading privacy settings or security measures on the website.

Appropriate security measures will be taken in disposing of personal information. You should promptly notify us in case of any irregularities while using our website, suspicion of fraud using the ePayLoan name, or receiving contact via phone or email through our platform. Depending on the promptness of your notification, you may be held accountable for unauthorized transactions. We will provide the results of our investigation within ten (10) business days and rectify any identified errors promptly upon notification.

By registering, you consent to provide access to your registration details for authentication purposes.

Children Below 14 Years of Age

Our website and services are designed for individuals who have reached the age of majority in their respective jurisdictions. Individuals below this age are not permitted to provide any information on our website. Specifically, we do not knowingly gather personal information from children under the age of 14. If you are under 14 years old, refrain from using our website, its features, registering on the website, utilizing our services, or disclosing any personal details such as your name, address, phone number, or email address. If we become aware of having collected personal information from a child under 14 without proper parental consent, we will promptly delete such information. If you suspect that we may have information concerning a child under 14, please reach out to our Privacy Officer.

Updates to Privacy Policy

We are not obligated to notify you of any changes to our policies via postal mail or email; it is your responsibility to stay informed. However, all additions and modifications will be clearly indicated on our website at epayloan.ca.

We retain the right to amend this policy without prior notice. The updated version will be marked with a 'Last updated' date and will become effective as soon as it is accessible. Therefore, it is strongly advised that you regularly visit and review our Privacy Policy so that you stay informed.

Maintenance of the Website

We reserve the right to temporarily suspend our online services for necessary management updates and enhancements without prior notice.

Legal action

We reserve the right to utilize content gathered through our system in the event that legal action is initiated against a user for improper utilization of the system.