By using the Website, the Platform or the Services, you consent to the use of your Personal
“Personal Information” is any information about an identifiable individual, such as your name, telephone number, address, location, e-mail address, and phone number.
2. Collection of Personal Information
We aim to collect, use and disclose Personal Information only to be able to provide the Services, including but not limited to facilitating the submission and processing of credit applications made by collection agencies we partner with (“Agencies”) on behalf of individual customers (“Customers), or by the individual Customers as directed by the Agencies, through our Platform, providing Customers and Agencies access to third-party financing institutions (“Lenders”) for the purposes of sourcing available credit offers, to determine your credit qualifications, to maintain our Agency and Lender databases, to respond to your inquiries or provide feedback, for identification and authentication purposes, for service improvement, for product development and marketing offers.
At the time of collection, We will clearly identify the information being collected and the purposes for which it will be used. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information you may not be able to use certain features of the Website, Platform and Services.
We collect Personal Information when you authorize an Agency to use our Platform through our LendEngine portal, when you use the link provided to you to use our platform through our Lend Engine portal, during communications with you and/or when you file a loan application through the Services, through user support, and/or by way of user surveys.
3. Use of Personal Information
We collect and use information for the following purposes:
o Loan Applications: For Customers to begin a loan application through the Services, Customers must provide certain Personal Information to us, including but not limited to Customer’s full name, date of birth, phone number, email address, home address, certain financial information relating to income, home and car ownership (if applicable), banking transactions and social insurance number (optional). This data is collectively used to communicate with Customers, direct loan seeking Customers to offering Lenders, to share banking transaction data with Lenders to assist in their credit decisions, to develop option analysis tools that will deliver settlement offers for collection items and counter offers of settlement models to Agencies, to share selected data with Agencies and/or debt owners regarding the status of Customer’s applications and to communicate with Customers the various offers and requests to be fulfilled through our Platform. To provide the Services, you acknowledge that Agencies and Lenders may share certain Personal Information and Customer details with us and each other, but only to the extent it is required for the purposes of providing the Services. As such, Agencies may share data such as Customer’s previous addresses, previous debt settlements, as well as past settlement offers and the details of any parties with outstanding debts.
o Credit Bureau Checks: To assist us in determining Customers’ credit qualifications and to match Customers with accepting Lenders, we, as well as the accepting Lenders, will also collect certain credit bureau data via credit reports to be obtained with your consent. To collect credit reports, we will ask you to provide your name, date of birth and address via our Platform, which utilizes TransUnion’s Application Programming Interface (API). By requesting these credit reports, you acknowledge that your information will be shared with TransUnion and their API.
o Identity and Transactions Verifications by Flinks: To assist Lenders making a credit decision, we may pull and share with them banking transactions data obtained through the Flinks technology. Flinks’ API allows us to pull transaction history from a financial account into an application, allowing for easier evaluation and management of lending risk.
o Completing your Loan: For Customers who have been approved by a Lender and are proceeding to accept and finalize the terms of their loan, Customers may need to provide additional Personal Information. This additional information may include the provision of other documents in support of the initial loan application such as a copy of Customer’s driver’s license, utility bills, cell phone bills, certain tax documents including but not limited to notices of assessment and/or reassessment from the Canada Revenue Agency and any other documents that the Lender may reasonably request to finalize Customer’s loan. These additional documents and/or Personal Information may be retained on our Platform for the purposes of providing our Services.
o Provision of Services to Agencies and Lenders: To provide the Services, including account credentials, to individuals who use the Services on behalf of Agencies and Lenders, We collect Personal Information of such users, including their name, email address, company name and company address.
o Statistics: We also collect statistics about use of our Services, including how users interact with our Website, Platform and Services. This information is used to monitor and improve the Services. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by Us and such aggregate statistics may be made available to third parties.
o Marketing: We may use your Personal Information for marketing purposes. Marketing purposes includes the marketing of debt resolution products and services. If We plan to use your Personal Information in the future for any other purposes not identified above, We will only do so after notifying you.
4. Disclosures & Transfers
From time to time We may employ third parties to help Us improve or otherwise make available features on the Website, Platform and/or the Services, whether through the provision of maintenance services, database management, web analytics or otherwise. Currently, Revardo engages Microsoft’s Azure cloud hosting data services for the purposes of providing our own. Revardo may provide Personal Information collected from you, to its service providers as necessary to enable the service provider to perform its obligations to Us. They will be subject to contractual restrictions prohibiting them from using or disclosing any Personal Information for any other purpose. Such third parties may be located in jurisdictions outside of Canada and, if it is the case, they are bound by the laws of the jurisdiction in which they are located and may disclose personal information in accordance with those laws.
We may disclose your Personal Information to third parties without your consent, where permitted or required by law, for example if We have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when We believe in good faith that such disclosure is required by and/or in accordance with the law.
The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff or other permitted persons or companies as are reasonably necessary to carry out the stated purposes We have communicated to you.
Our servers are located in Canada and accordingly your Personal Information may be available to government agencies and/or law enforcement in those countries under a lawful order, irrespective of the safeguards We have put in place for the protection of your Personal Information. By using our Website, App and Services, you consent to the hosting of your Personal Information in Canada
7. Amendments to this Policy
8. Access and Accuracy
You have the right to access the Personal Information We hold about you in order to verify the Personal Information We have collected in respect to you and to have a general account of our uses of that Personal Information. Upon receipt of your written request, We will arrange to provide you, within the time period required by law, with a copy of your Personal Information although in certain limited circumstances, We may not be able to make all relevant Personal Information available to you, such as where that information also pertains to another individual or as otherwise required or permitted by law. In such circumstances We will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date. As appropriate, this amended Personal Information will be transmitted to those parties to which We are permitted to disclose your information. Having accurate Personal Information about you enables Us to give you the best possible service. You can help by keeping Us informed of any changes to your Personal Information by contacting us at email@example.com.
9. Contact Us
If you would like to access your information, have any questions, concerns, comments or suggestions, or if you find any errors in our information about you, please contact our Privacy Officer via email at firstname.lastname@example.org or Revardo Inc. 1660 North Service Rd. E. Suite 208, Oakville, ON L6H 7L9.
Last Updated: May 19, 2021