Last updated:  October 24^th, 2018

PYLOfinance.com is owned and operated by PYLO Finance Inc.^TM (the “Company”) (“PYLO”, “us”, “we”); a Canadian incorporated Company and is committed to protecting your privacy.  This Privacy Policy sets out the manners in which information about you (“Personal Information”) is collected, used, disclosed and otherwise managed in connection with the www.pylofinance.com website (the “Website”), your loan application and the administration of your loan and through other interactions with consumers.  This Privacy Policy does not apply to an individual’s business contact information where collected, used, or disclosed solely for the purpose of communicating with the individual business, employment or profession.

Our privacy policy was created to adhere to Canada’s Federal Personal Information Protection and Electronic Documents Act (PIPEDA) formerly referred to as Bill C-6. The Act has two primary objectives:

1. to establish rules that govern the collection, use and disclosure of personal information by private sector organizations; and
2. to acknowledge the validity and legality of electronic documents.

For more information regarding this legislation, please visit the official Web site of the Privacy Commissioner of Canada at https://www.priv.gc.ca.

PYLO collects and uses personal information for the purposes limited to those which are related to its business of providing private lending services.

1. Collection and Use of Personal Information include but not limited to, the following:

Loan Application: When applying for a loan, PYLO collects information about you including your name, contact information (such as mailing address and email address), date of birth, purpose of the loan, income, information about your rent or mortgage payments, credit related information and your social insurance number (if you choose to provide it). This information is used by PYLO to assess your application and determine your eligibility for a loan. At the time you apply for a loan, you will be asked to provide your consent to a credit check (see section on Credit Reports below), and any other third party service providers engaged by PYLO.

Loan Agreement: If you are approved for a loan, additional information will be collected including your proof of income (such as pay stubs or Notices of Assessment from your tax return), your Canadian bank account number, and information regarding your employment such as occupation, current or former employer(s), previous address, number of dependents, driver’s license number. We may also collect personal and employment references with your consent.

Your information is used for the following purposes:

• approving, opening, administering, servicing and enforcing your Loan, including collecting outstanding debts;
• determining your eligibility and suitability for, and providing you with, other products and services you request (not applicable to payday loan agreements under Payday Loans Regulation B.C. Reg.57/2009, Section 20.1(2) );
• verifying your identity and other information you have provided to us (including your identity and bank account);
• meeting legal and regulatory requirements;
• detecting and preventing fraud and other unauthorized or illegal activities;
• as otherwise permitted or required by applicable law.

Credit Reports: At the time you apply for a loan, we will obtain your consent to collected credit-related information from consumer reporting agencies. PYLO may or may not, at its discretion, choose to check your credit score in order to help us determine your eligibility for a loan. PYLO may also exchanges Personal Information with credit bureaus as necessary at the time of your application and throughout the term of your Loan Agreement in order to review and verify your ongoing creditworthiness, and manage and assess our risks. You authorize credit bureaus to provide such information to us.

Online Registration: At the time you apply for a loan, PYLO will collect your email address and a password you choose in order to create and administer an online account for you to access information about your application and/or loan. PYLO strongly recommend that you do not disclose your password to anyone. PYLO will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

Social Insurance Number: You are not required to provide your social insurance number in order to apply for a loan or enter into a loan agreement. However, if you choose to provide it, PYLO uses it to assist in identifying you with credit reporting agencies and for internal fraud prevention purposes.

Marketing Communications: PYLO may use your information to send you communications by mail, email or telephone marketing for promoting our products and services that may be of interest to you (not applicable to payday loan agreements under Payday Loans Regulation B.C. Reg.57/2009, Section 20.1(2) ).  If you register for an account or provide your email address your are aromatically enrolled to receive marketing offers, you can opt-out at any time by clicking on the unsubscribe link included in our marketing email communications or by contacting PYLO as set out under Contact Us below. Please note that you may continue to receive certain transnational or information electronic communications from us.

Call Recording: PYLO may monitor and record telephone conversations with you for training and quality assurance purposes. 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.

Customer Service: When you contact PYLO with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. PYLO may retain this information to assist you in the future and to improve our customer service and product and service offerings (not applicable to payday loan agreements under Payday Loans Regulation B.C. Reg.57/2009, Section 20.1(2) ).  PYLO also uses Personal Information to establish and manage our relationship with you and provide quality customer service.

Employment: In connection with a job application or related inquiry, you may provide PYLO with certain Personal Information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). This information will be used for the purpose of processing and responding to your application for current and future career opportunities.

Survey and Customer Research: From time to time, PYLO may offer you the opportunity to participate in one of our surveys or other customer research. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable form to help us understand our customers and to enhance our product and service offerings (not applicable to payday loan agreements under Payday Loans Regulation B.C. Reg.57/2009, Section 20.1(2) ).

Contests and Promotions: When you enter a contest or participate in a promotion, PYLO may collect your name, address, phone number, email address, and other information you provide. This information is used to administer your participation in the contest, sweepstakes or promotion.

2. How Personal Information is Collected

PYLO collects Personal Information directly from you (such as information you provide in connection with your loan application and documents you provide, as well as, through your ongoing interaction with us, from third parties such as credit bureaus, current or former employers, personal references provide by you, other financial Institutions, and other third party sources).

3. Disclosure of Personal Information

PYLO will not disclose trade, rent, sell or otherwise transfer your Personal Information, without your consent, except as otherwise set out herein:

Service Providers: Your Personal Information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf. Lender uses service providers (including PYLO and its authorized sub-contractors) to provide services such as payment processing, billing, administration, and debt collection, to verify information you have provided to us (such as your identity and bank account number) and to administer pre-authorized debit agreements, for the purposes of fraud detection and prevention, in connection with audits (internal and external), including defending and bringing legal actions, as well as, meeting legal, regulatory, industry self-regulatory, risk management, security requirements, or as permitted by law.  With your consent to PYLO’s insurance partners or other lenders so that they may offer you other product and services that may interest you.

PYLO may use service providers to host the Website, 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 PYLO, affiliates and other third party service providers in the US or other jurisdictions. In the event Personal Information is transferred to the US 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.

Investors: 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.

Legal/Compliance: PYLO, each of their affiliates and Canadian, US and other service providers may provide your Personal Information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, US or other law. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

Sale of Business: Personal Information may be transferred as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of PYLO  or as part of a corporate reorganization or stock sale or other change in corporate control.

4. 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 (such as Google Analytics) 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.

PYLO does not guarantee the confidentiality of any communication made by you via e-mail or otherwise through our website.  If you wish to provide information of a confidential or sensitive nature to PYLO, please contact us directly by telephone at 1-855-211-8211 to arrange for delivery/transmission of such information by secured means.

Cookies, Tracer Tags & Web Beacons:  Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our Website where you are prompted to log in or that are customizable. If you have registered with our Website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to deliver products and personalized services, and (3) will provide us and our service providers with information that we will use to personalize our Website in accordance with your preferences. We and our service providers (such as Google Analytics) also use cookies to help us understand our website activity, to improve our Website and provide better customer service. For more information about Google Analytics, see www.google.com/policies/privacy/partners/.

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, you may not be able to take advantage of all of the features of our Website.

Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.

Interest-Based Advertising:  We may use third parties (such as Remarketing with Google Analytics) to serve our advertisements on other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our Website and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant to you, both on and off our Website.

You can opt-out of interest-based ads from Google by visiting https://www.google.com/settings/ads. To find out more about the collection and use of information by third parties for behavioural advertising purposes, or if you would like to opt-out of certain third-party cookies and make selections about what online advertisement you choose to receive, you can visit the Digital Advertising Alliance of Canada website.

Third Party Links:  Our Website may contain links to other sites 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. 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. These other websites are not governed by our Privacy Policy and 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.

5. Safeguards and Retention

We have implemented reasonable 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. Access to your Personal Information is restricted on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.

We have Personal Information retention processes designed to retain Personal Information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements (which may extend beyond the end of your relationship with us).

6. 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. As well, 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 below. You may also update certain contact information through our online portal. We will respond to written requests within a reasonable time.  Copies of records containing personal information may be subject to a fee; if applicable, PYLO will inform/notify the individual in advance of the amount of such fees.

We will use our best efforts to ensure that personal information is as accurate, complete, and up-to-date for the identified purpose. If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information as necessary.  If we refuse access to personal information, or disagree with the individual that their information is incorrect, we will provide a written detailed explanation and a description of our complaints procedures should and individual decide to challenge our written explanation.  An individual right to access or correct personal information is subject to applicable legal restrictions.

To prevent fraudulent access to the personal information we may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records.

7. Terms of Use

Please also review our Terms of Use section establishing the use, disclaimers, and limitations of liability governing the use of our website.

8. Consent

Consent to the collection, use and disclosure of personal information may be given in various ways and can be express or implied. You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. By submitting personal information to PYLO or its service providers and agents, you consent to the collection, use and disclosure of such personal information as described in this Privacy Policy or otherwise at the time of collection.

If you provide PYLO or our service providers and agents with personal information of another individual, you will be deemed by PYLO to have obtained consent from such person to enable us to collect, use and disclose such information for the purposes set forth in this Privacy Policy. Subject to legal or contractual requirements and reasonable notice, you may withdraw your consent at any time by contacting PYLO’s Privacy Officer. If you withdraw your consent, we may be limited or unable to provide you with certain services or information.

In certain circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual. These circumstances include but are not limited to: personal information that is publicly available as defined by regulation; where collection is clearly in the interests of the individual and consent cannot be obtained in a timely way; where disclosure is made for the purposes of collecting a debt owed to us; or to comply with a subpoena, warrant or court order.

9. Changes to the Privacy Policy

This Privacy Policy may be updated periodically to reflect changes to our Personal Information practices. We will post the updated Privacy Policy on our website. Your continued provision of personal information or use of our services following any changes to this policy constitutes your acceptance of any such changes.

10. Contact Us

Please contact our Privacy Officer if you:

• have any questions or comments about this Privacy Policy,
• wish to access, update, and/or correct inaccuracies in your Personal Information, or
• 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 info@pylofinance.com  (please don’t send confidential information by unencrypted email)