Privacy Policy

At CanCap Group, our subsidiaries and affiliates ("CanCap," "we," or "us"), we sincerely value the trust that you have placed in our business. We have adopted this privacy policy (the "Policy") to affirm our commitment to maintaining the accuracy, confidentiality, and security of your personal information. This Policy explains how we collect, use, disclose, and safeguard the personal information that you or a third party provide. Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to CanCap Group's collection, use, and disclosure of your personal information in accordance with this Policy. For the purposes of this Policy, "personal information" means information that can identify an individual directly or through other reasonably available means. The meaning of "personal information" shall be interpreted in a manner that conforms to the minimum requirements of applicable privacy legislation.

Our Privacy Principles
Identifying Purposes and Obtaining Your ConsentWe identify the purposes for collecting your personal information at or before the time it is collected. We will not collect, use, or disclose your personal information without your consent unless we are required or permitted to do so by law. We collect, use, and disclose personal information about you so we can: Respond to your application. Provide financing to you by determining your financial situation through the collection of credit and related financial information from our affiliates, strategic partners, credit agencies, other financial institutions, and from references you provideFacilitate the financing by sharing your information with our third-party service providers, financial institutions, funders, credit agencies, and similar parties connected to our financing offering for the collection and servicing of the financing provided to youInvestigate potentially fraudulent or questionable activities regarding your application to us or financing provided to youReport under any applicable rules or regulations to regulators, financial institutions, or other related entitiesOffer you related products and services that might be of interest to youWe will also use your personal information to communicate with you. If we require your information to fulfill a purpose that is not identified in this Policy, we will obtain your consent. Limiting the Collection, Use, and Disclosure of Your Personal Information.

The information we collect: We collect personal information by fair and lawful means and limit collection to that information which is necessary for the purposes identified in this Policy. The types of personal information that we collect from time to time include: Contact information that allows us to communicate with or contact you (e.g., address, telephone number, email or other electronic address, social media account name, and fax number)Identity information that allows us to identify you or to meet tax, anti-money laundering, and other "know your client" legal and regulatory obligations (e.g., name, Social Insurance Number (SIN), date of birth, occupation, and government-issued identification)Financial information that allows us to determine creditworthiness or eligibility for or appropriateness of products or services (e.g., employment and financial history with others, income, net worth, credit reports, and details of security provided for loans). Transactional information about how you use different products or services or otherwise do business with us (e.g., purchase and payment history). Relationship information that helps us understand more about you, including how you like to do business and what types of products, services, or offers you may like (e.g., language and communication preferences, location, demographics, and interests). The choice to provide us with your personal information, either directly or through a third party, is always yours. However, your decision to withhold particular information may limit our ability to provide you with some of our products or services.

How your information is collected
Personal information may be collected in a number of ways, including in person, over the phone, by mail, by fax, over the Internet, and from third parties who you have authorized to disclose personal information to us. Web cookies are very small text files that are stored on your computer from a webpage to keep track of information about your browsing on that site. Through the use of web cookies, we may monitor the ads you see and the number of times you view them. The use of cookies also allows us to capture standard web traffic information, such as the time and date you visited our website, your IP address, and your browser information. In no circumstances do the cookies capture any information that can personally identify you. We also gather anonymous/non-personal information from our website and digital properties that is used primarily for technical, research, and analytical purposes like evaluating the various sections of our website. This information does not include any personal information, and it is only retained until its intended purpose is fulfilled. We make every reasonable effort to ensure that those third parties that disclose your personal information to us have first obtained your consent. If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not respond sufficiently to your inquiries, please let us know immediately. Your personal information will only be used or disclosed in accordance with the purposes for which it was collected, unless you have otherwise consented or except where required or permitted by law. We may monitor and record telephone calls for the purpose of obtaining consent and maintaining quality service.

Disclosure to Third Parties
The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose your personal information to authorities. Only the information specifically requested is disclosed, and we take precautions to satisfy ourselves that the authorities making the disclosure request have legitimate grounds to do so. Your personal information may be disclosed in situations where we are legally permitted to do so, such as in the course of employing reasonable and legal methods to enforce your rights, our rights, or to investigate suspicions of unlawful activities. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property, and safety of ourselves and others. You also understand and agree that we may use your personal information and disclose it to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment, or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing an actual or proposed transaction. These purposes may include, for example, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing personal information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use, and disclose your personal information for substantially the same purposes as those set out in this Policy. In the event the transaction does not go through, we will require, by contract, the other party or parties to the transaction not to use or disclose your personal information in any manner whatsoever for any purpose and to return or destroy such personal information.

Keeping Your Information Accurate
We make every reasonable effort to keep your personal information as accurate, complete, and up-to-date as necessary. If desired, you may verify the accuracy and completeness of your personal information in our records. Despite our best efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.

Protecting Your Personal Information
Access to your information within CanCap Group is restricted to authorized employees with legitimate business reasons. We require all our employees to abide by CanCap's privacy standards and to maintain the confidentiality of personal information at all times. We employ security safeguards that are on par with industry standards to protect your personal information. Our server environment and firewall infrastructure are well-maintained, and our security practices are reviewed regularly. Electronic customer files are kept in a highly-secured environment with restricted access, and paper-based files are stored in locked filing cabinets. When you call our customer service center, you will be required to verify your identity. We use Secure Socket Layer (SSL) and 128-bit encryption technologies to enhance security for the secured areas of our website. SSL protects and maintains the security of messages transmitted over the Internet by scrambling your data into an unreadable format, preventing unauthorized access by others.

Addressing Your Inquiries and Concerns
We are happy to provide you with a copy of this Policy and to discuss any of its content with you. Upon request, we will also inform you of the type of personal information we have collected, how your personal information has been used, and any third parties to whom your personal information has been disclosed. Please direct all questions or inquiries about this Policy to our Privacy Officer by email at privacyofficer@acancapgroup.ca or by mail at PO Box 980, Station A, Toronto, ON M5W 1G5.This Privacy Policy:Any changes to our privacy standards and information handling practices will be reflected in this Policy in a timely manner. CanCap reserves the right to change, modify, add, or remove portions of this Policy at any time. Please check this page periodically for any modifications. The modification date at the bottom of this Policy indicates when it was last updated.Websites Governed by this Privacy Policy:Our website at www.cancapgroup.ca is governed by the provisions and practices stated in this Policy. However, please note that our website may contain links to third-party sites that are not governed by this Policy. We are not responsible for the privacy practices of third-party sites, and we recommend reviewing the privacy policies of those sites to understand how they collect, use, and disclose personal information.

Governing Law
This Policy and all related matters are governed solely by the laws of the province of Ontario and the applicable federal laws of Canada. CanCap Group may perform activities outside of Canada through third parties, and as a result, your personal information may be processed, used, stored, or accessed in other countries and may be subject to the laws of those countries. Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.

Last revised June 28, 2018.