Finally is committed to the protection of personal information. As part of this commitment, we have prepared this Privacy Policy statement to describe the manner in which Finally Financial Services Inc. and its affiliated companies (collectively, “Finally”, “we”, “us” or “our”) collect, use, disclose and otherwise manage information about you (“Personal Information”) in connection with your access to and use of our Services (as defined in our Terms of Use) including through www.myfinally.com and www.myfinally.ca (the “Website”) and Finally’s mobile application (the “App”) and through other interactions with us.

Finally may provide third party content or links to third-party web sites or applications. When you leave our Services or interact with a third-party feature, you should read the applicable third party’s privacy policies and terms of service to make sure you understand how they might collect and share information about you.

We do not share your Personal Information with third parties for their advertising or marketing lists without your consent.

1. COLLECTION AND USE OF INFORMATION

The ways we collect information about you include:

• information you give us
• information we collect from third parties about you
• information we collect about you based on your use of our Services

• INFORMATION YOU GIVE US

You may give us information about you when you use our Services or by communicating with us. This includes information you provide when you create an account, answer specific questions through various forms, provide us with feedback, participate in surveys, contests or promotions and when you contact us with a question or to report a problem.

The information you give us may include your name, contact information (such as mailing address and email address), date of birth, income and other financial related information, information about your rent or mortgage payments, credit-related information, your financial goals, referral source and your social insurance number. You are not required to provide your social insurance number. However, if you choose to provide it, we use it to assist us in identifying you with credit reporting agencies and for internal fraud prevention purposes.

If you use our Services, we may require you to verify your bank account using a third party service to ensure we are retrieving information from the correct accounts, and to ensure we debit and credit your funds to the correct accounts (Finally does not receive your bank account login information). If you choose to verify your bank account using the third-party service offered to you through our Services, you will agree to additional terms provided such third-party involved in verifying your identity, which will apply in addition to these Terms of Use.

As part of this verification process, we may also verify your identity by asking you questions from Equifax or other identity verification service providers or by verifying your name, address, date of birth and mobile phone number with your mobile service provider.

We may monitor and record our 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.

• INFORMATION WE COLLECT FROM THIRD PARTIES ABOUT YOU

We collect Personal Information from third parties or service providers with your consent or where otherwise permitted or required by law. This information includes financial information which is relevant to the provision of our Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity. We also work closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, social media) and may receive information from them, such as whether or not you have taken out a product with them, what other products you may have used, and other such details. We might also collect information from other users like you through things like a member referral program.

If you register for an account, Finally will obtain your consent to collect personal information such as but not limited to first and last name, date of birth, and additional information such as your email address, financial goals, annual income range, and referral source. Finally uses this information to better understand your financial needs and provide you with tailored personal finance information, educational insights and recommendations which may include products and offers from third-party providers, information on steps to plan various financial goals or improve your financial position, as well as personalized offers for Finally and third-party financial services products and services that may be of interest to you based on your financial plan, provided information and other information retrieved. If you wish to withdraw your consent to the collection and use of your personal and financial information, you may close your account at any time.  For information and instructions on how to close your account, please refer to the Terms of Use. 

• INFORMATION WE COLLECT ABOUT YOU BASED ON YOUR USE OF OUR SERVICES

Each time you visit our Website or use our App we may automatically collect certain information about how you access and interact with our Services. We and third parties may use various technologies to collect, use and store this information. These may include cookies, browser web storage, web beacons and similar technologies. The information we may automatically collect includes the following:

• Website Information:
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number
  • technical information, including the Internet protocol (IP) address, device information, device operations, your login information, browser type and version, time zone setting, operating system and platform
  • location information, including your internet protocol (IP) address or other device information or information about your visit to estimate your location (e.g., your city or province).
• App Usage Information & Analytics:
  • Certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
  • We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our Services. We will only use these location-enabled services on your device with your consent.
• See Cookies and Interest-Based Advertising below for more information

USE OF INFORMATION WE COLLECT

Some examples of how we use the information we collect:

• provide you with Services, such as our financial planning Budget Tools
• manage your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message or other electronic means about your account
• verify your identity as part of our identity authentication process and other information you have provided to us (including your bank accounts)
• provide you with information, products and Services
• notify you about changes to our Services
• ensure that content from our Website and App is presented in the most effective manner for you and your device
• aggregate it on an anonymous basis with other data for data analysis and reporting purposes
• undertake analysis of your credit information in order to identify and inform you of credit products that we consider are likely to interest you or be suited to your credit circumstances or to enhance our Services
• meeting legal and regulatory requirements
• detecting and preventing fraud and other unauthorized or illegal activities
• as otherwise permitted or required by applicable law.

MARKETING COMMUNICATIONS

If you have provided your consent, we may provide you with information about Finally or other products and services we feel may interest you or be best for you based on information we have about you (including emails, text messages, and notifications).

You can opt-out any time by contacting us as set out under Contact Us below, or by taking the following steps:

• You can opt-out of receiving marketing emails at any time by clicking on the unsubscribe link included in our marketing email communications. Please note that you may continue to receive certain transactional or account-related emails from us.
• To opt-out of push notifications, you can manage your notification preferences within Your Account Settings on the App.

SHARING OF INFORMATION WE COLLECT

We will not disclose, trade, rent, sell or otherwise transfer your Personal Information, without your consent, except as otherwise set out herein. We use information we hold about you to provide our Services to you and improve those services, manage your account and communicate with you and to use information on an anonymous basis for research, profiling and analytical purposes.

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. Finally uses service providers (including its authorized sub-contractors) to provide services such as billing, administration, advertising and analytics services, to verify information you have provided to us (such as your identity and bank account number) and to administer pre-authorized debit agreements. Finally may use service providers to host the Website, App, 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 Finally, affiliates and other third-party service providers in Canada or other jurisdiction. 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. 

Business Partners: If you use certain Services we will share certain personal information we have about you (such as your contact information) with third party business partners (for example, if you submit a mortgage questionnaire or if we pre-populate an application with your information). In these situations, we will confirm with you that we will be sending your information or we will send you to the business partner’s site or platform for you to provide the information directly to them.

Legal/Compliance: Finally and its 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 (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud 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 prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Finally or as part of a corporate reorganization or stock sale or other change in corporate control.

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 may 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.

Cookies, Tracer Tags & Web Beacons

Our Website or App uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. Cookies may provide us and our service providers with information that we will use to personalize our Website and App in accordance with a user’s preferences. 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 or App, you may not be able to take advantage of all of the features of our Website or App.

We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. For more information or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.

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 work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website and App in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and App and third-party websites and Apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate our online advertising campaigns.

Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may, therefore, be less relevant to you and your interests.

To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

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. 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.

SAFEGUARDS AND RETENTION

We have built-in user authentication systems to safeguard user data with password hashing, salting, and encryption, and we use industry-standard services such as Amazon Web Services, Cloudfare, and Bubble.  Your data is safeguarded and encrypted in transit with TLS and at rest through RDS AES-256. 

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. We restrict access to your Personal Information on a need-to-know basis to employees and authorized service providers who require access to fulfil 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).

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. 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 may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records.

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 Personal Information will be treated in accordance with the Privacy Policy in place at the time your Personal Information was collected unless you otherwise consent.

CONTACT US

Please contact us if:

• you have any questions or comments about this Privacy Policy,
• you wish to access, update, and/or correct inaccuracies in your Personal Information, or
• you otherwise have a question or complaint about the manner in which we or our service providers treat your Personal Information.

You may contact us by email at contact@finally.com.