Privacy Policy
Borrowell is committed to the protection of personal information. As part of this commitment, we have prepared this Privacy Policy to describe the manner in which Borrowell Inc. and its affiliated companies (“Borrowell”, “we”, “us” or “our”) collect, use, disclose and otherwise manage information about you (“Personal Information”) in connection with your access to and use of our Services (as defined in our Terms of Use) including through www.borrowell.com (the “Website”), Borrowell’s mobile application (the “App”) and through other interactions with us.
By registering for or obtaining a Service, using our Website or App and/or providing us with Personal Information, you consent to Borrowell collecting, storing, using and disclosing your Personal Information in accordance with the terms of this Privacy Policy.
If you do not agree with any term in this Privacy Policy, please do not provide us your Personal Information or use our Website, App or Services.
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; and
information we collect about you based on your use of our Services
A. INFORMATION YOU PROVIDE 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, photo ID (such as government-issued information), referral information if you participate in our referral programs, 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, such as Borrowell Credit Builder, 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). We may also verify your identity by (1) asking you questions from Equifax Canada Co. (“Equifax”) or other identity verification service providers; (2) by verifying your name, address, date of birth and mobile phone number with your mobile service provider; (3) or by comparing a government photo ID to your physical likeness using tools like Veriff or otherwise.
If you enroll in Borrowell Rent Reporting, you may be asked to agree to have Borrowell connect to your bank account on your behalf using a third-party service. Should you use automatic account linking, your account data (including account credentials) may be shared with the third-party service provider, in accordance with their privacy policies. 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, and verify your rent payments, as the case may be. To cancel Borrowell Rent Reporting, see the Rent Reporting Terms and Conditions.
When you communicate with us, we may monitor and record our telephone and chat conversations with you to check our instructions to us, assess and improve our services, for training and quality assurance purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us. 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 request on your behalf 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 determine your likelihood of approval or pre-qualify or pre-select you for offers such as: personal loans, auto loans, or credit card offers (“Pre-Qualification Offers”), which may involve sharing anonymized data with participating providers. With your consent, Borrowell may also periodically share your Personal Information with participating providers so that they can identify and return rates on loan offers (“Instant Quotes”) and/or pre-populate their application form (“Quick Apply”). These attempts to pre-qualify, pre-select or conduct an Instant Quote may result in a soft credit check from Borrowell with a consumer reporting agency that will not impact your credit score. Pre-Qualification Offers and Instant Quotes are subject to change and are not guaranteed approval as they are based on your credit report and your Borrowell account profile information we have on record. Members will still need to submit an application with participating providers and that provider may run a hard inquiry, which can impact your credit score.
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 AUTOMATICALLY 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 various technologies which may include cookies, browser web storage, web beacons and similar information. This information is a key part of how we improve the Borrowell experience and provide you with more personalized insights and recommendations. The information we may collect includes the following:
Website Information:
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; and
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 from you and third parties 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 Credit Builder, Borrowell Marketplace (including Pre-Qualification Offers and Instant Quotes) or Borrowell Rent Reporting;
assessing your application and eligibility for a Borrowell Loan or Borrowell Credit Builder 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, push notification 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;
administering 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 or improve existing 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; and
as otherwise permitted or required by applicable law.
MARKETING COMMUNICATIONS
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 promotional emails at any time by clicking on the unsubscribe link included in our promotional 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 on your mobile device.
SHARING OF PERSONAL INFORMATION WE COLLECT
As a starting point, we do not sell your Personal Information to or share your Personal Information with third parties for their own marketing or advertising purposes. Below, we explain how we could share your Personal Information for the purposes described in this Privacy Policy and in accordance with applicable law. Your Personal Information may be shared outside of Québec and/or Canada (including, in the United States, United Kingdom or European Economic Area) as necessary to provide the Services.
Service Providers: Your Personal Information may be transferred (or otherwise made available) to our service providers or agents to have them perform on our behalf any activities we are permitted to conduct under this Privacy Policy and our Terms of Use. Borrowell uses service providers (including its authorized sub-contractors) to provide services such as billing, administration, debt collection, research, 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 outside of Québec and/or Canada; including, in the United States, United Kingdom, European Economic Area or other jurisdictions. In the event Personal Information is transferred to the United States 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. We always require that appropriate safeguards are in place to protect the Personal Information when it is processed.
Equifax or other consumer reporting agencies: If you have signed up for Borrowell’s Services, Borrowell will obtain your consent to provide your first and last name, date of birth, mailing address and telephone number to Equifax or other consumer reporting agencies so that they can provide you with your credit score and/or credit report for free at the time of account creation and on a regular basis thereafter for the purposes set out above in this Privacy Policy. We may disclose your personal information and payment history with respect to our Services (such as Borrowell Credit Builder and Rent Advantage) to credit reporting agencies for the purposes of updating and maintaining the information in their records.
Borrowell Marketplace Partners: We offer a Borrowell Marketplace where you can view and interact with various financial products offered by third party partners. If you use the Borrowell Marketplace, you have an opportunity to send your Personal Information to the partner. For example, you may choose to have us pre-populate an application through Quick Apply or choose to apply for a Pre-Qualification Offer or Instant Quote, in which case we will receive your confirmation that you wish to do so. In other cases, if you wish to learn more about a partner or offer, we may 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 actual financing, securitization, merger, assignment or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Borrowell or our business or assets, for the purposes of evaluating and/or performing the proposed transaction.
Legal & Compliance: Borrowell and its affiliates and Canadian, United States 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, United States 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, United States or other law. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims, to investigate or prevent actual or suspect loss or harm to persons or property or to comply with our legal obligations.
Fraud Prevention: We may transfer or disclose your Personal Information to third parties to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability, and for required institutional risk controls.
With Consent: There may also be other limited contexts in which we share specific types of personal information with your express consent.
We may also share with third parties de-identified or aggregated data we collect, such as de-identified or aggregated credit reports or scores, de-identified demographic information, or information about the computer or device from which you access the Service. We share such information for a variety of purposes, including to analyze Service usage, develop shared services, and improve our own products and features.
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.
Analytics
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”.
Interest-Based Advertising
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.
CHATBOTS
Our Services may incorporate automated features powered by artificial intelligence, including but not limited to, chatbots or digital assistants (“Chatbots”). While Chatbots can provide helpful information, artificial intelligence has limitations and may not be able to answer your question or may generate a response that is inaccurate. You are responsible for determining if the response provided by the Chatbot applies to your circumstances and should not rely solely on the Chatbot responses.
THIRD PARTY LINKS
Our Website may contain third party content or links to other websites or applications that we do not own or operate, including social media websites. Also, links to our Website may be featured on third party websites on which we advertise our Services. Except as provided herein, we will not provide any of your Personal Information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your Personal Information.
SAFEGUARDS AND RETENTION
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. We train our employees to keep your personal information strictly private and confidential.
Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).
We will retain your Personal Information in accordance with our retention policy and for as long as reasonably necessary to perform the Services, protect our Website, App and Services from fraud or unlawful activity, meet our legal obligations, and protect and enforce our legal rights. If you delete or deactivate your account, we will no longer use or disclose your Personal Information to provide the Services, but we may retain your Personal Information as necessary for the purposes noted above. All retained Personal Information will remain subject to the terms of this Privacy Policy. Please note that if your Personal Information is collected by a third party, it will be retained in accordance with their privacy policies and retention requirements. To learn more about how we retain your Personal Information see here.
YOUR RIGHTS
Deactivating or Deleting Your Account
If you decide you no longer wish to use our Services, you may deactivate or delete your Account through our App . Due to our recordkeeping and retention requirements, we do not immediately delete information about you upon deactivation or deletion, but permanently delete your information in accordance with our retention requirements. We will, however, immediately disable your account and stop sending you further communications.
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. If you reside in Québec, you also have the right to request that we provide your Personal Information to you or a third party authorized by you in a structured and commonly used technological format.
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.
CHANGES TO THE PRIVACY POLICY
We may update this Privacy Policy at any time without notice to you. We will post the updated Privacy Policy on the Website and will revise the “Last Updated” date at the bottom of this page. If there are any material changes in the way we treat your Personal Information, we will send you a notice before the change goes into effect. Please revisit this page to stay informed about our Personal Information practices. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of changes. Your continued use of the Website, App or Services following the publication of an update to this Privacy Policy will be deemed your acceptance of those changes.
CONTACT US
Please contact our Privacy Officer if:
you have any questions or comments about this Privacy Policy;
you wish to access, transfer, 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: WeWork c/o Borrowell Inc., Attn: Privacy Officer, 1 University Ave, 3rd Floor, Toronto, Ontario, M5J 2P1.
Last Updated: September 17, 2024