Revardo Privacy Policy

 

Revardo Inc., (“Revardo”, “We” or “Us”), is committed to protecting your privacy. We make available the Revardo website located at www.revardo.com including all subpages and successor pages (together the “Website”), and the Revardo loan marketplace, our proprietary software-as-a-service platform (the “Platform”), (together the “Services”). Revardo set forth the terms and conditions that apply to your access and use of the Website in the Terms of Use and Conditions Agreement available through this link. This Privacy Policy describes how We collect, use and disclose information about our users through the Website and the Services.


 

1.      Consent

By using the Website, the Platform or the Services, you consent to the use of your Personal

Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information (as defined below) will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Website and/or Services. You will have the ability to withdraw your consent by using the unsubscribe mechanism included in all our communication with you. 

 

“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 System Logs & Cookies: We, and/or our service providers or partners on our behalf, may use cookies and other technologies to track content usage and traffic on the Website and/or Services. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. The Website and Services may use cookies to help it compile aggregate statistics about usage of this Website and/or Services, such as how many users visit the Website and/or Services, how long users spend viewing the Website and/or Services, and what pages are viewed most often. This information is used to improve the content of the Website and/or Services and for general authentication, security and marketing purposes. In addition, we use cookies to customize your browsing experience such as pre-populating application forms and logins to the Platform. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Website and/or Services. We do not link any of the information We use in cookies to any Personal Information submitted by you when you are on the Website and/or using the Services. Your IP address is reported by your web browser whenever you visit a page on the Website and/or access the Services. This information is recorded together with your registration information on our databases. By using our Website and/Services, you consent to having its cookies placed on your device, unless you have disabled them. For help managing cookies, consult the settings for your web browser. Explicit cookies permission request is not required under Canadian laws. However, we have adopted best practices from the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR") and the Data Protection Act 2018 in the United Kingdom.

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

Except in accordance with this Privacy Policy or as otherwise permitted or required by law, We will not disclose or transfer your Personal Information to other third parties without your permission.

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.

We may also disclose your Personal Information in connection with a corporate reorganization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

5.      Security

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

6.      Retention

We will keep your Personal Information for a minimum of 5 years, or else as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personal Information, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

7.      Amendments to this Policy

We reserve the right to change this Privacy Policy at any time. If We decide to change this Privacy Policy in the future, We will post an appropriate notice on the Website or Platform. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that We have about you. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Website and/or Services signifies your acceptance of any changes.

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 info@revardo.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 scott.wilson@revardo.com or Revardo Inc. 1660 North Service Rd. E. Suite 208, Oakville, ON L6H 7L9.

Last Updated: May 19, 2021