ASSET DIRECT OF CANADA (dba LoanConnect) PRIVACY POLICY

Last Updated: March 28, 2021

Introduction
At Asset Direct of Canada Inc, doing business as LoanConnect (“ADC”, “we” or “us” and terms of similar meaning), we are committed to your privacy. This policy (the “Privacy Policy”) outlines how we collect, use, transfer and disclose your Personal Information (as defined below) in using our online platform (the “Platform”) and/or utilizing the services offered through the Platform (“Services”). The ADC Platform may be either accessed directly through the ADC website (www.loanconnect.ca) or through the website of our network of referral partners and affiliates (the “Referral Partners”)
ADC has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws. By accepting this Privacy Policy in registration or by visiting and using the Platform and/ utilizing the Services, you accept this Privacy Policy and expressly consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms of Service.

Scope
This Privacy Policy governs our practices to the collection, use and disclosure of Personal Information that we collect from identifiable individuals, including users of the Services, and any individual that provides us with their Personal Information, for example visitors to our website (“Users”).

Information We Collect
a. Personal Information
Personal Information is any information recorded in any form that identifies or can identify an individual and includes any information provided to us by you, including in using the Platform or Services.
Personal Information about you that we may collect includes, but is not limited to:

• Contact information such as your name, address, title, phone number, email address.
• Information to verify your identity such as date of birth, driver’s licence, passport number, and social insurance number.
• Financial information such as housing status, total annual income, total monthly debt payments and employment status.
• Credit file information, including credit account and collection information.
• Loan information such as loan amount, loan term, and purpose.
• Your communications – this includes any communications and personal information that you provide through our messaging system, email or other correspondence directed to us, or comment and feedback forms.

Please note that disclosure of your social insurance number is not required to use our Services, but providing it will increase the likelihood of us correctly verifying your information.

b. Non-Personally Identifiable Information
Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any User (“Non-Personally Identifiable Information” or “NPI”). Such information by itself or together cannot be tracked to a specific individual’s Personal Information.
We collect NPI about Users when they interact with the Platform or use the Services. NPI may include, but is not limited to, device information, IP address, geo-location information, browser name, type of computer or device, and technical information about a User’s means of connecting to the Platform, such as operating system, Internet service provider utilized, and mobile network information.

Definitions
To better understand this Privacy Policy, ADC has set out some basic definitions to use when reading and interpreting it.

• Collection: the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.
• Consent: voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of ADC. Implied consent is consent that can reasonably be inferred from the circumstances or from an individual’s action or inaction.
• Disclosure: making Personal Information available to a third party for that party’s own use.
• Personal Information: information about an identifiable individual that is recorded in any form.
• Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of ADC.
• Use: the treatment, handling and management of Personal Information by and within ADC.

Principles
ADC’s Privacy Policy is organized along the ten privacy principles of PIPEDA.

Principle #1 - Accountability
ADC is responsible for the Personal Information under our possession and control. We have designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and privacy legislation.
Accountability for ADC's compliance with the provisions of ADC's Privacy Policy rests with the Privacy Office within ADC, which shall designate one or more persons to be accountable for compliance with the ADC policy. Other individuals within ADC may be delegated to act on behalf of designated person(s) or to take responsibility for the day-to-day collection and processing of Personal Information. The Privacy Office has been created to ensure Users have a designated avenue to answer their privacy-related inquiries.
ADC shall make known, upon request, the title of the person or persons designated to oversee ADC's compliance with this policy.
ADC is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. ADC shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party. ADC shall implement policies and practices to give effect to these principles, including:

• Implementing procedures to protect Personal Information;
• Establishing procedures to receive and respond to complaints and inquiries;
• Training staff and communicating to staff information about the organization’s policies and practices; and
• Developing information to explain the organization’s policies and procedures.

Principle #2 – Identifying Purposes
Personal Information
ADC collects Personal Information for the following purposes:

• to provide Services to our Users;
• to establish and maintain responsible commercial relations and to communicate with you in order to provide service. This includes, but is not limited to, communications relating to advertising, promotion and verification;
• to respond to any correspondence you may direct to us;
• to understand, research, and improve our Services, including User feedback;
• to communicate with you regarding customer service issues and/or product or service issues;
• to direct advertisements to you about our company and our products and services that may be of interest to you;
• to enforce our Terms of Service and other legal agreements;
• to provide you with system or administrative messages;
• to meet legal and regulatory requirements; and
• for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied.

Non-Personally Identifiable Information
In an ongoing effort to better understand and serve the users of our Services and improve our Service and user functionality, we conduct research on our customer and User demographics, and behavior based on Personal Information and other information that we have collected. This research may be used by ADC to analyze and improve our services to our customers, including the usage and evolution of the Platform. This research will be compiled and analyzed on an aggregate basis and this aggregate does not identify any individual and therefore is considered and treated as Non-Personally Identifiable Information under this Privacy Policy. We may share such information to third party business partners.

Principle #3 - Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except in certain circumstances as described below.
In certain circumstances, Personal Information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate where there is an emergency threatening the individual's life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available.
Where appropriate, ADC will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when ADC wants to use information for a purpose other than those identified above).
In obtaining consent, ADC will use reasonable efforts to ensure that a User is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by ADC may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, ADC shall take into account the sensitivity of the Personal Information and the reasonable expectations of its customers and users.
ADC will seek consent when the information is likely to be considered sensitive, such as obtaining a credit check. Implied consent will generally be appropriate where the information is less sensitive. In certain circumstances, your consent may be implied by your actions. For example, indicating that you wish to compare loan options, and then providing us with your relevant financial and credit information and proceeding with an affirmative action (for example pressing the ‘Apply’ button), is implied consent to use such information to provide you with the associated services including disclosing this information to third party lenders (see Principle #5 – Limiting Use, Disclosure and Retention).
With respect to Personal Information already collected by ADC prior to the publication of this Privacy Policy, this Privacy Policy will constitute reasonable notice to ADC's current Users of the purposes and uses for which such Personal Information has been collected. Should an individual object to these ongoing uses or disclosures, consent may be withdrawn upon providing notice to ADC in writing.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, however, withdrawing consent may result in our inability to provide you with certain Services. In order to withdraw consent, you must provide notice to ADC in writing.

Principle #4 – Limiting Collection
ADC will limit the collection of Personal Information to that which is necessary for the purposes identified by ADC. ADC will collect information by fair and lawful means.
ADC collects Personal Information from its Users for the purposes described under Principle #2. ADC may also collect Personal Information from such third parties as employers of Users or other third parties that represent they have the right to disclose the information.

Principle #5 – Limiting Use, Disclosure and Retention
Unless required by law, or in connection with a business transaction, ADC shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining your consent, where such consent may not reasonably be implied.
ADC may disclose or transfer your Personal Information in the following instances:

• To Provide Services – as part of our Services, we may disclose your Personal Information to third-party financial lenders for the purpose of evaluating your eligibility to receive financing pre-approval from their financial institutions.
• Our Service Providers – we may provide your Personal Information for processing and handling to our service providers that help us with our business operations and developing our products and services. We require our service providers to keep your Personal Information secure. In addition, our service providers may not use or disclose Personal Information for any purpose other than providing the services on our behalf unless we or they have obtained your consent. ADC takes reasonable contractual or other measures to protect your Personal Information while processed or handled by such service providers.
• Our Referral Partners – in the event that you access the Platform using or through the website of a Referral Partner (“Your Referral Partner”), we may, at the request of the Referral Partner, disclouse your Personal Information to Your Referral Partner. The treatment of such disclosed Personal Information will be governed by the privacy policy of Your Referral Partner.

Our third party suppliers may be located outside of Canada, including in the United States, and your Personal Information may be collected, used, disclosed, stored and processed in such jurisdictions for the purposes described in this Privacy Policy. ADC takes reasonable contractual or other measures to protect your Personal Information while processed or handled by such Affiliates. If your Personal Information is located outside Canada it will be subject to legal requirements in those foreign countries applicable to our service providers, for example, lawful requirements to disclose Personal Information to government authorities in those countries.
In the event your Personal Information is disclosed to a third party pursuant to a business transaction (including a potential sale or financing), ADC will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction. Subject to the foregoing, only ADC’s and our service providers’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about our Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of your Personal Information.
ADC will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by ADC.
ADC may also disclose your Personal Information to other third parties where you consent to the disclosure or where disclosure is required or permitted by law.

Third Party Services
The Services may allow you to connect with other websites, products, or services to enhance your experience. Your use of these third party services is entirely optional. We are not responsible for the privacy policies and/or practices of these third party services, and you are responsible for reading and understanding those third party services’ privacy policies.

Principle #6 - Accuracy
Personal Information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
The extent to which Personal Information will be accurate, complete and up-to-date will depend upon the use of the information, taking into account the interests of the individual. Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about that individual.
ADC will update Personal Information about Users as and when necessary to fulfill the identified purposes or upon notification by the individual.

Principle #7 - Safeguards
ADC will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information, and the method of storage.
We take administrative, technical and physical measures to safeguard your Personal Information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your Personal Information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your Personal Information is stored and archived are secure and in a controlled environment with limited access. We utilize access and firewall controls for our computer services and encrypt Personal Information where appropriate. We educate our employees with respect to their obligations to protect your Personal Information.
ADC makes its employees aware of the importance of maintaining the confidentiality of Personal Information. All of ADC's employees with access to Personal Information will be required as a condition of employment to contractually respect the confidentiality of Personal Information.
ADC will protect Personal Information it discloses to third parties through contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your Personal Information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur.

Principle #8 - Openness
ADC shall make readily available to our Users specific information about its policies and practices relating to the management of Personal Information.
ADC will make information about its policies and practices easy to understand, including:

• The title and address of the person(s) accountable for ADC's compliance with the policy and to whom inquiries or complaints can be forwarded;
• The means of gaining access to Personal Information held by ADC; and
• A description of the type of Personal Information held by ADC, including a general account of its use.

ADC will make this privacy policy available online at https://loanconnect.ca/privacy-statement. On request, a copy of this Privacy Policy shall be provided by mail.

Principle #9 - Individual Access
Upon request, ADC will provide information to a User regarding the existence, use and disclosure of his or her Personal Information. ADC will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. A User may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, ADC may not be able to provide access to all the Personal Information it holds about a User. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. ADC will provide the reasons for denying access upon request.

Principle #10 - Challenging Compliance
An individual may address a challenge concerning compliance with this Privacy Policy to ADC's Privacy Officer.
ADC will maintain procedures for addressing and responding to all inquiries or complaints from Users about ADC's handling of Personal Information. ADC shall investigate all complaints. A User shall direct all inquiries or complaints involving ADC's handling of Personal Information or compliance with this policy or with PIPEDA to ADC's Privacy Officer.
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If ADC finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact our Privacy Office as follows:
Email: privacy@assetdirect.io
Mail: Asset Direct of Canada Inc. 379 Dundas Street Unit 101 London, ON N6B 1V5

Using the Platform & Cookies
In order to improve the Platform, we may use small files commonly known as “cookies”. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Platform and is stored on your device’s browser or hard drive. Cookies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may generate reports based on the use of these technologies an aggregated basis.
The cookies we use on the Platform collect personally identifiable information about you in order to improve the user experience. This personally identifiable information is only stored locally, and expires after five minutes and then is deleted. We won't disclose information stored in cookies that we place on your device to third parties. We also use cookies to remember users’ settings, store login addresses, authenticate users, run website experiments, and store analytics data, such as browser, device type and operating system.
Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting https://www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

Cookies from third parties
We use Google Analytics, a web analytics service provided by Google Inc. ("Google") on the Platform. Google Analytics uses "cookies", which are text files placed on your computer, to help ADC analyse how users use the Platform. The information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Platform, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Platform. By using the Platform, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
We may use additional third party and such parties will have their own privacy policies describing how they use information that they collect.

Communication
By using Platform, you agree to receive communications from us via email, text message, calls, and push notifications. You may unsubscribe from receiving such communications by using the unsubscrbie mechanism provided in the communication or by contacing ADC at support@loanconnect.ca.

Children and Minors
Our Platform and the Services offered are not directed to children under the age of 18 years. We will not knowingly collect Personal Information about a child under the age of 18.

General
ADC reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our website and will be effective as of the date of posting.