Privacy Policy
Who we are and what we do?
Our company, 9385-8363 Quebec Inc, a Canadian company doing business under the name “CreditBook” (hereinafter referred to as “CreditBook”) acts as a personal Information agency. In keeping with our mandate, our company works with various subscribers, customers and business partners in the credit and/or financing industry, such as collection agencies, credit companies, creditors, lenders and security holders, management companies, as well as banking or payment service providers (hereinafter collectively referred to as our “Business Partners”).
For Information purposes and as a background to our business operations, CreditBook offers several distinct products and services that can benefit our customers and Business Partners involved in the credit and/or financing industry. CreditBook currently offers access to three (3) distinct products and services as part of our business operations (hereinafter referred to as our “Products”). Firstly, we offer our subscribers access to a database of debtors and loans, which allows us and our Business Partners to compile and use Information about individuals on file. This tool, which we have named CreditBook CHECK™, is designed to help subscribers analyze and assess the financial situation of loan applicants and debtors, namely by checking their level of reliability and creditworthiness, in addition to facilitating collection or recourse, in the event of a loan default on an existing debt by a debtor.
Secondly, we offer our customers and Business Partners access to a software designed to facilitate the management of loan and receivables applications, including the ability to compile and use Information about individuals who would have applied for loans. This tool, which we have named SLOAN™, is designed to assist lenders and security holders in their tasks and business processes related to third-party receivables and loans, including at the time of a loan application, for the purpose of setting up a loan or security interest, as well as for monitoring during the term of a loan and to facilitate collection or recourse in the event of a loan default on an existing debt by a debtor.
Thirdly, CreditBook offers its customers and Business Partners access to an ancillary service we have named IBV™ (or INSTANT BANKING VERIFICATION™), which is also designed to help subscribers analyze and assess the financial situation of loan applicants and debtors by providing access to certain specific data regarding their bank accounts, including the ability to view account statements and bank transactions, whether in real time or in a history spanning several months.
As a further context, in the normal course of events and in keeping with its role in the credit and/or financing industry, CreditBook receives personal Information from individuals (about themselves), as well as from its customers and Business Partners in the normal course of their own business operations, for example, when building a file on an individual seeking a loan. This personal Information may include, but is not limited to, Information about an individual’s identity, contact information and any other type of data related to such individual and his or her creditworthiness (as a consumer and debtor), including, for example, Information or numbers from public or non-public government databases (such as social insurance numbers and driver’s license numbers), Information about his or her employment or employers (current or past), financial Information about his or her debts or assets (including Information about his or her dwellings or properties that he or she may rent or own), Information about lenders and security holders and/or banking institutions with whom he or she deals or has dealt in the past, Information about his or her bank accounts, Information about his or her outstanding loans, Information about security interests in his or her property, etc. We collect and use Information only with the consent of the individual to whom it relates, either directly when providing the Information to us or indirectly when providing such Information to our customers or Business Partners (hereinafter collectively referred to as “Information”).
Upon receipt in our systems, this Information will be compiled into a profile and record for each individual debtor, which Information may subsequently be viewed, used and disclosed by CreditBook, including to and by its Business Partners, in accordance with this Privacy Policy (hereinafter referred to as our “Policy” in the remainder of this document). This Policy is intended to express how CreditBook collects, compiles, stores, communicates and uses such Information in the course of its business operations.
About us and our use and protection of personal data
It is important to understand that CreditBook receives, stores, compiles and retains, over time, Information about specific individuals who have consented to such handling of their personal Information, which Information may be accessed, disclosed and used by us, our subscribers, our customers and Business Partners, through our Products, in accordance with this Policy. Our operations are based on the collection of Information, such as that described above, and the compilation of that Information to create and maintain a file and credit profile on individuals who we may have on file, following the granting (directly or indirectly) of their consent. Once on file, the Information compiled about a given individual becomes immediately available online to our subscribers, customers and Business Partners, including when they subsequently wish to determine, assess or verify the individual’s reliability and creditworthiness, the risk of lending to that individual or the soundness of the individual’s financial situation. As such, it is important to note that we profile the consumers that we have on file.
That being said, as it continues to offer its Products and services, CreditBook is and intends to remain at all times a company with responsible practices, namely with respect to protection of privacy and personal Information, including, but not limited to, personal Information of those who avail themselves of the Products and services offered by our company or our Business Partners and whose Information is entrusted to us from time to time. For your Information, as used in the text of this Policy, in accordance with the definition set out in the Act respecting the protection of personal Information in the private sector (the “Act”), we define “Information” (or “Personal Information”) as any Information about an individual that allows the individual to be identified, directly or indirectly, regardless of format or subject matter.
It is in this context that we undertake to consider and treat all Information to which we have access, including all Information in an individual’s debtor or credit file, as confidential Information deserving of protection, using discretion and precautions appropriate to the nature of the Information entrusted to us. In order to achieve this, we also undertake to use our best efforts to ensure the protection of our customers’ and users’ Information, including the use of appropriate administrative, technical and physical safeguards.
This is the context in which we have developed this Policy, and we intend to be bound by its publication as our commitment to all individuals whose personal Information we handle. Accordingly, this Policy is intended to explain what types of Information we collect and how we protect it, and to state how we may then use and share that Information with specific third parties, as further described below.
How you can control what we do with you information
By operation of law and this Policy, individuals whose Information we may hold are entitled to withhold consent or withdraw consent at any time as we may request or obtain from time to time, for the handling of their personal Information, including the collection, storage, retention, use, sharing or disclosure of such Information to third parties.
In addition, all individuals whose Information we hold have the right to access that Information, verify its accuracy and have any outdated or inaccurate Information corrected, particularly in light of our role in the credit and financing industry as a personal Information agency. More specifically, any individual in respect of whom CreditBook has received or created a credit report or recommendations related to creditworthiness is entitled to contact us in order to have access to these reports and recommendations.
In either case, where appropriate, we encourage individuals to send us, as indicated in the “How to contact us to discuss our practices regarding your Information” section of this Policy, their requests for access to their own Information or for reports or recommendations concerning them. Where appropriate, we will process each such request in a timely and diligent manner, first by confirming the identity of each individual submitting such a request to us, with the understanding that such withdrawals of consent may be subject to practical, legal and/or contractual limitations, and may interfere with the ability of such individuals to obtain certain benefits or services from CreditBook or its Business Partners.
In addition, any individual whose name and/or contact information appears on our user lists or customer lists may also withdraw consent to the retention, use or disclosure of their Information for marketing purposes at any time by contacting us in writing, as set out in the “How to contact us to discuss our practices regarding your Information” section of this Policy, or by unsubscribing through the links provided in our messages, if any. Notwithstanding the foregoing, we advise individuals who are considering withdrawing their consent that such withdrawal may result in CreditBook or its Business Partners no longer being able to provide certain services or continue to do business with the individual, for example, to provide a loan or maintain a loan.
How we obtain the consent of individuals that we have on file
In effect, we generally consider that individuals who directly or indirectly choose to avail themselves of our Products and services are giving us their consent, including by agreeing to voluntarily provide us with their Information when seeking our services or completing and submitting a loan application, including to one of our subscribers, customers or Business Partners. When this occurs, we will generally understand that you have given us your consent to collect your Information and that you do not object to our use of it for our purposes as set out in this Policy. On the one hand, you obtain certain benefits, such as facilitating or enabling the processing of a loan application you submit to one of our subscribers, customers or Business Partners, and on the other hand, we obtain your consent to collect, use, process and, in some circumstances, share your Information. This is more or less a goodwill exchange between us.
In other instances, we may also receive or have access to Information about individuals who have voluntarily and knowingly provided it to some third parties who are our Business Partners and who share that Information with us following the granting of consent by each individual.
Notwithstanding your initial consent to the collection of your Information, it is important for you to understand that Quebec and Canadian laws give you the right, at any time, to withdraw your consent, including once the purpose of your interaction with our company has ended. If necessary, we encourage you to contact us, as stated herein, to exercise your rights under applicable privacy legislation.
Please note that our portal, Website, tools and services are not intended for minors. Therefore, CreditBook aims to avoid collecting or using Information from individuals under the age of eighteen. In the event that CreditBook becomes aware of the presence of a minor’s Information among its data, this data will be deleted in a timely manner, after diligent confirmation of the individual’s age.
The types of information we collect
Our systems may include a wealth of Information about individuals who have applied for loans in Canada, including for the purpose of enabling our Business Partners to assess the reliability of current or potential debtors who may approach them or interact with them from time to time. Our database of Debtors may include, among other things, personal Information such as names, contact information (physical and digital), date of birth, copies and/or data from official identification documents (including social insurance numbers), Information about their occupation, employment history, employment or current employer, as well as bank or credit card account and contact information, Information about loans (credit cards, lines of credit, mortgages and other loans) and repayment patterns, Information about bounced cheques and unpaid accounts, public Information such as bankruptcy or judgments against the individual, names of persons or organizations that have requested to see the file and credit rating.
Furthermore, like many companies with Websites or social media accounts and pages, we collect some data about visitors and users of our portal, Website and social media accounts and pages, including how they use our services and what content is relevant to our customers, users and visitors. We also ask our visitors to be aware that our Website and social media accounts and pages may include links to content or sites provided by third parties for which we are not responsible or liable. Where applicable, the exchange of Information with these sites, accounts or pages does not imply CreditBook or its privacy policies or practices. Where applicable, it is important for each individual to validate the practices and policies of the operators of such other sites, accounts or pages.
In doing so, from time to time, we may collect Information from individuals for various purposes, such as those described below in this Policy.
The Information we collect about users and visitors to our portal and Website
Users of our Website may choose to take advantage of some features and voluntarily share their own Information with us through our Web portal and/or site. The system associated with our portal or Website may also allow us to detect and collect Information about the hardware or software used by visitors or users of our portal or site, most of which does not necessarily allow us to identify the individuals themselves. Our portal or site may also use cookies, which may be stored on visitors’ computers, to, among other things, recognize visitors from one visit to the next and provide a more personalized experience, thereby improving the quality of the experience offered to each visitor, as well as providing potentially more relevant recommendations.
In addition, from time to time, we may also post online advertisements, either for third parties or for our own Products and services, using third-party vendors and intermediaries who specialize in this type of work to facilitate and increase the effectiveness of this process. Where appropriate, these vendors and intermediaries may implement devices through our portal or site that allow them to identify your device and track how you use our site, what you have viewed, including the pages or sites you have visited and the advertisements you have clicked on, if any, in order to increase the effectiveness of our advertising efforts and to provide you with the advertisements that are more relevant to your needs and tastes over time.
How we collect other Information
In the normal course of events, individuals who choose to use and/or acquire our products and services provide us with their Information themselves, which may include, for example, individuals who complete and submit a microloan application form directly to us. Where applicable, for example, when an individual chooses to complete a microloan application, he or she is giving us consent to verify his or her identity and contact information, including with third parties such as vendors with whom the individual has a business relationship, credit agencies, or public sources of Information, including for the purposes of detecting errors, attempted fraud, and identity theft. Where applicable, this consent from the individual will also include his or her consent for such third parties to disclose certain Information about him or her to us.
From time to time, we may request your consent to obtain certain Information about you from third parties, such as other personal information agents or credit reporting agencies.
When an individual applies for a loan from certain CreditBook Business Partners, his or her Information may be shared with us automatically. In other situations, we may also obtain Information about individuals from certain third parties, such as when individuals choose to do business with certain of our Business Partners (e.g., third-party lenders and security holders who subscribe to some of our services), for example, by completing a loan application with one of those partners. When this occurs, if at the time of initiating a relationship with a lender, an individual authorizes the lender to share his or her Information with our company, the Information may be routed to our systems in an automated fashion, giving us access to it.
In doing so, some of the Information we have access to comes from the individuals themselves, while other Information comes from Business Partners to whom the Information has been provided by the individuals concerned.
Depending on the circumstances, the types of Information we may receive and store in our systems may include the names and contact information of customers and users.
The purposes for which we may handle your Information
We will only use your Information in accordance with our Policy, or otherwise with your consent, or in accordance with Canadian and Quebec laws, including those relating to the protection of personal Information. In doing so, from time to time, we may collect, use, retain, process, communicate or disclose Information of individuals on our systems for a variety of purposes, including the following:
- To enable us to comply with applicable laws and legal and regulatory requirements, including those related to audits or other requirements applicable to businesses in the lending industry and/or credit report checks;
- To manage and conduct CreditBook’s business, including allowing us to add new customers, users or debtors to our databases, to deliver goods or services to our Business Partners and users, and to administer customer and user accounts at CreditBook, such as when we receive loan applications;
- In connection with the issuance of new loans and to enforce the terms and conditions of, and administer any loans that may be issued to the individuals involved, including facilitating the renewal of such loans, where appropriate;
- To compile and potentially communicate credit files to Business Partners, the content of which could be transferred directly or indirectly to third-party creditors or lenders or to security holders;
- To enable us to provide Information and support services to our customers;
- To allow us to evaluate the financial situation of the candidate debtors and to offer them financial products that are tailored to their profile and their needs;
- To process loan applications submitted to us, including verifying the identity of applicants and following our approval process for this purpose, including interviewing applicants through our customer service department, where applicable;
- To provide our Business Partners and users with access to a database of debtors to determine their debt and credit reliability and the risk that loans to these individuals may represent;
- To register or create credit or loan files for individuals applying for loans through us or one of our Business Partners;
- To ensure the safety and protection of individuals and property of CreditBook or its customers or users;
- For investigative and law enforcement purposes, such as suspected fraud;
- To communicate with our Business Partners and users, to respond to their questions, requests for advice, comments, complaints and requests for personal Information;
- In the context of the governance of our company, particularly in relation to its shareholders and board of directors, as required by commercial law;
- To detect and protect against fraud and identity theft, including the ability to trace or recover delinquent debtors;
- To determine your eligibility for our Products and services and to verify compliance with any conditions that may apply to the use of our Products or services or to loans that may have been granted to our customers or subscribers;
- In the context of our preparation of quotations, proposals or requests for quotations to offer our Products and services;
- To maintain or improve the quality of our Products and services, including conducting internal audits and continuous improvement activities;
- To confirm the veracity of Information provided to us by an individual, a customer or a CreditBook Business Partner;
- To collect debts owed by an individual who has defaulted or failed to meet his or her obligations to CreditBook;
- For the purpose of developing, designing, improving, marketing or recommending Products and services that meet the needs and interests of our Business Partners and users;
- To better manage and maintain our debtor files, including accounts created for our Business Partners and users for our various Products and services;
- For analysis, targeting, segmentation and statistical purposes, in particular to better understand and analyze the interests, needs and preferences of our Business Partners and users, provided that in such a case, the statistics thus collected will be adequately anonymized;
- To receive and process applications from candidates who have expressed an interest or who have been duly referred to us for employment at CreditBook;
- To process Information related to purchases or requests from our Business Partners or users, including the processing of related remittances or payments;
- To verify the identity of our Business Partners and users, especially in relation to transactions such as loan transactions that may be required;
- To invite current or potential customers and users to events;
- To recognize individual customers and users on our Website, platforms or applications and to better understand their preferences, among other things, to better personalize the experience of our Website visitors;
- To better analyze the use of our tools, such as our Website, platforms or applications, by our Business Partners and individual users, with a view to customizing and improving them over time;
- To send communications to our current or potential Business Partners and users;
- To facilitate or enable the collection of debts owed to CreditBook or one of its Business Partners; and
- In any other manner permitted or required by law.
How we may share or disclose your Information to third parties
Basically, CreditBook will not sell, rent or transfer to third parties Information on file about individuals, other than in accordance with this Policy and/or with the consent of the individuals involved. That being said, it is important to understand that we may disclose or share Information (about individuals that we have on file) through our Products to our subscribers, customers and Business Partners, including potential, current or prospective creditors of such individuals, where required in the context of the creditor-debtor relationship between them and such individuals.
It is also important that individuals who agree to have their Information included in our Products understand that some services offered by CreditBook, its subscribers, customers or Business Partners may involve collaboration and data sharing between the companies involved, including individuals seeking credit and/or services from those companies; in such a case, CreditBook may disclose Information to some of its subscribers, customers or Business Partners, in accordance with the documentation relating to such services and the consent requests made to individuals during the process of creating an account or applying for a loan with them, for example.
Like many Canadian companies, from time to time, CreditBook may also share the Information on file with subcontractors or technology or telecommunications service providers, such as hosting companies or data processing service providers. In such cases, we make these transfers on the basis of agreements whereby these subcontractors and suppliers undertake to adequately protect the Information in question and not to use it other than as required by CreditBook, in accordance with Canadian legislation on the protection of personal Information. From time to time, CreditBook may also share data on file with other companies, organizations, government or law enforcement agencies, either with the consent of the individual concerned and/or when required by law or court order.
From time to time, CreditBook may also disclose some Information to third parties, such as the employers of the individuals concerned, in order to validate Information reported by these individuals to CreditBook or its subscribers, customers or Business Partners. If necessary, CreditBook may also disclose some Information to collection agencies in order to assist in the collection of debts owed by the individuals concerned.
In the course of its business operations, CreditBook may also be called upon to transfer some Information outside Quebec, namely to other Canadian province(s) (hereinafter referred to as “Other Jurisdiction”), in order to process and host data and to allow CreditBook’s Products to work. Where applicable, we ask individuals whose Information we hold to be aware that the privacy laws applicable in such Other Jurisdictions may differ from those applicable in Quebec and/or the territory where the individual resides, in which case your Personal Information may be subject to the foreign laws applicable in such Other Jurisdictions. If we need to transfer your personal Information to Other Jurisdictions, we will protect it in the manner described in this Policy, but it is important to understand, with respect to data that would be exported by CreditBook in this manner, including to servers of its data hosting service providers, that courts, authorities or regulatory agencies, law enforcement or national security authorities may have access to their Information in these Other Jurisdictions.
In addition, from time to time, CreditBook may disclose and/or share Information with certain third parties in the context of its credit reporting and lending activities, including when required in the context of providing services that may be requested by its customers or users or by the customers or users of its Business Partners. This could, for example, include providing access to the credit file details of any individual dealing with us to subscribers of our credit check services.
After obtaining an individual’s consent to do so, CreditBook may also share his or her Information with third parties in order to meet his or her needs or to provide him or her with appropriate offers based on the status of his or her credit report or debtor profile.
When necessary, such as for a CreditBook customer or Business Partner, we may also disclose Information about individuals in the context of credit investigations, including to third parties engaged in fraud investigation or prevention and/or identity verification agencies, for example, for the purpose of verifying the identity or contact information of an individual. Assuming you also consent from time to time, this may include sharing Information we have about individuals with credit reporting agencies in the context of ongoing credit file maintenance.
How CreditBook stores and protects your Information at Amazon Web Services
The Information we collect about our users and customers and those of our Business Partners is stored on our servers and those of our IT service providers in a secure and encrypted manner. Access to such data is strictly controlled by administrative, technical and physical safeguards, including all Information provided to CreditBook or referred to us, Information provided to us by our users and customers, and Information provided to us (through our Business Partners) by individuals who are not directly our customers. These safeguards are regularly reviewed and updated.
Internally, only specifically authorized personnel may access the Information stored in our databases when directly required to perform their job duties at CreditBook, in addition to a limited number of authorized members of our technical team.
When and how we destroy or delete your Information
With respect to retention, it is important for individuals who agree to have their Information retained by us to know that our practice is to retain such Information for as long as we are not asked to delete it from our tools and products, up to a maximum of 7 years. In principle, our practice is to retain the Information we have only as long as necessary for the purposes for which it was collected, provided that the purpose of collecting Information from individual debtors is to build a useful file and profile for our subscribers and customers who may have a creditor relationship with the individuals.
In the normal course of events, we retain Information for a period of time that is reasonable in light of our mandate and circumstances, including deletion when individuals withdraw their consent and/or when they deactivate their account and/or when they request us to delete their Information from our systems and Products.
When deletion or removal of Information from our systems and Products is required, we delete such Information in a timely and reasonably secure manner so as to prevent further collection, use, retention, manipulation, communication or disclosure in any way. Notwithstanding the foregoing, however, in some circumstances, we may need to retain some Information for a longer period of time, including by obtaining your consent to do so, or when necessary to protect against fraud, when required by law, or when a legal relationship with the individuals involved warrants it, such as when a claim remains between a particular individual and our company or one of our subscribers, customers or Business Partners.
Changes to our Policy over time
As the world and the industry continue to evolve, including with respect to privacy, CreditBook hopes and intends to continue to improve its privacy practices and policies over time. Therefore, while this Policy is intended to describe our current privacy practices, we understand that we may from time to time adapt and/or update our Policy to better meet the needs of our customers and the marketplace. In such cases, CreditBook will post any new version of this Policy on its Website and the updated rules will apply from that point forward. We believe that it is the responsibility of each individual to ensure that they regularly review the most current version of our Policy in order to remain appropriately informed of our practices in this area.
How to contact us to discuss our practices regarding your Information
We encourage all individuals who know or believe that CreditBook holds, uses or discloses personal Information about them to contact our Privacy Officer, Mr. Lloyd Evetts, in writing, at the following contact information to discuss the matter, including accessing or correcting the Information or making a complaint to CreditBook about the Information, as well as to obtain clarification of CreditBook’s policies and practices, including its use of service providers in Other jurisdictions:
Our office
CreditBook c/o Privacy Officer
1641a Desserte Nord, Autoroute 440
Laval, QC,
Canada
Contact
*Latest Update: September 18, 2023.