INTRODUCTION
BrainFinance (9179186 Canada Ltd.) and our affiliates and subsidiaries ("Company" or "We") respect your privacy and are committed to protecting it by complying with this policy.
This policy describes:
· How we collect, use, disclose, and protect the personal information of our current and prospective customers, service providers (and their employees and representatives), visitors to the Company’s office and website users ("you").
· Describes the types of information we may collect from you or that you may provide when you visit the website brainfinance.com (our "Website").
· Our practices for collecting, using, maintaining, protecting, and disclosing that information.
We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
This policy applies to information we collect, use, or disclose about you:
· On this Website.
· Visitors to Company’s social media pages that refer to this Privacy Policy (e.g.LinkedIn)
· In email, text, and other electronic messages between you and this Website or the Company.
· Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website or the Company.
· When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
· When you provide business or other professional services to the Company
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
This policy DOES NOT apply to information that:
· We collect offline or through any other means, including on any other Company or third-party website (including our affiliates and subsidiaries).
· You provide to or is collected by any third party (including our affiliates and subsidiaries when in accordance with their respective privacy policy), through any application or content (including advertising) that may link to or be accessible from (or on) the Website.
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.
INFORMATION WE COLLECT ABOUT YOU
We collect and use several types of information from and about you, including:
· Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, and any other identifier we may use to contact you ("personal information").
· Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as associations, distances, comparison between available data sources, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specificWebsite feature.
· Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
· Direct interactions with you when you provide it to us, for example, by filling in forms, responding to ads and job postings published on the Website or corresponding with us by phone, email, or otherwise.
· Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
· Third parties or publicly available sources, for example, our business partners.
· The Company may also record calls or virtual meetings with You for training and note-taking purposes, in which case your voice and/or images may be captured.
· Visitors to the Company’s social media pages that refer to this Privacy Policy (e.g. LinkedIn)
· If attending Company’s offices, We may capture images and recordings of you by video and audio recording devices in order to maintain the physical security of our offices. The Company has no control over cameras that may be placed in the common areas of the buildings its offices are located in.
· When you use one of your devices (e.g. laptop, mobile phone, desktop computer) to browse our Website, We receive certain information about your device, including its hardware model, operating system, browser version, IP addresses, and geographic information derived from IP addresses.
Information You Provide to Us
The information we collect directly from you on or through our Website may include:
· Information that you provide by filling in forms on our Website. We may also ask you for information when you report a problem with our Website.
· Records and copies of your correspondence (including email addresses), if you contact us.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
· Information about your computer and internet connection, including your IP address, operating system, and browser type. We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services(behavioral tracking).
The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
· Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
· Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs)that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Third Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities overtime and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
· To operate, provide and maintain our services and the Website and its contents to you.
· To provide you with information, products, or services that you request from us.
· To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
· To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
· To notify you about changes to ourWebsite or any products or services we offer or provide through it.
· To improve, enhance, modify, add to and further develop our Website, products or services, marketing, or customer relationships and experiences.
· To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
· To investigate any misuse of our Website or services, including violations of our security policies, criminal activity, or other unauthorized accesses.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect, or you provide as described in this privacy policy:
· To our subsidiaries and affiliates, including those that may be located outside Canada.
· In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our customers and users is among the assets transferred.
· To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users(for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may make use of the personal information we have collected from you to enable us to display our advertisers' advertisements to that target audience.
· To third parties to market their products or services to you. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
· To third party credit reporting agencies for business purposes that include but are not limited to: investigating and monitoring of internal business practices, providing and supply of services to you; for research, testing and development of products offered by the Company; to detect security breached and protect against them. Were any of the following to be carried out, prior to any disclosures of personal data, a contract would be entered into that will ensure the protection, security and use for the above mentioned purposes between us and any third party.
· To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization, data processing, customer service, security, etc.) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. However, such third parties may not be located in Canada, such as, without limitation, in the United States of America or the Philippines.
· To fulfill the purpose for which you provide it.
· For any other purpose disclosed by us when you provide the information.
· With your consent.
We may also disclose your personal information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
· To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may also use and disclose personal information in connection with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets(including your loan and any agreement to which it relates), for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of our business or assets may use and disclose your personal information for similar purposes as those described in this policy.
You acknowledge and agree that your personal information may be transferred for processing from your current location to the offices and servers of the Company and authorized third parties referred to herein that may be located outside Canada, such as, without limitation, in the United States and the Philippines.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. We may process, store, and transfer your personal information in and to a foreign country, including the United States of America and the Philippines, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation. By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
DATA SECURITY
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure.Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
CHILDREN UNDER THE AGE OF 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@brainfinance.com
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. You also have a right to access the personal data belonging to you that is under our control subject to any legal restrictions or rights of refusal.
Such a request for access must be made in writing stating the details of the personal data you are requesting to the Company’s Privacy Officer at Brain Finance, 1751 Rue Richardson, Suite 1.100, Montréal, QC H3K 1G5.
To ensure we disclose information to you only, with your request please include photocopies (front and back) of two (2) pieces of government issued identification so that we may verify your identity. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
· Information protected by solicitor-client privilege.
· Information that is part of a formal dispute resolution process.
· Information that is about another individual that would reveal their personal information or confidential commercial information.
· Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at privacy@brainfinance.com.
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@brainfinance.com. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this page. We include the date the privacy policy was last revised at the top of the page.You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices.
Please contact us at:
Privacy Officer, Brain Finance,
1751 Rue Richardson, Suite 1.100,
Montréal, QC H3K 1G5
or via email at privacy@brainfinance.com
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.
