Statement of Principle
Definition of "personal information"
Collection of Information
- When you register for a general account (“General Account”) on the Site, Loop will collect certain information from you, such as your title, full name, e-mail address, telephone number, name of business (if applicable) and password. If you register for Loop’s newsletter, Loop will collect your full name and e-mail address.
Lender Account or Borrower Account
- When you apply for a Lender account (“Lender Account”) or Borrower account (“Borrower Account”) on the Site, Loop will collect certain information from you, including, but not limited to:
- contact information (title, full name, e-mail address, mailing address and telephone number)
- date of birth;
- social insurance number;
- income, assets, debt and other financial information; and/or
- bank account information (including financial institution number, branch transit number and account number).
- If you apply for a Lender Account or Borrower Account on behalf of an entity, Loop will collect certain information about the entity, including, but not limited to:
- the entity’s business, affairs and industry;
- the entity’s income, assets, debt, and other financial information;
- the ownership and control of the entity, which may include, at Loop’s discretion, information about its shareholders, directors, officers, partners, and/or trustees; and/or
- the entity’s bank account information (including but not limited to financial institution number, branch transit number and account number)
- When you apply for a Lender Account or Borrower Account on the Site, Loop may collect information from a Credit Agency that you authorize us to collect. This includes credit history, financial and identification information and any other information disclosed in a credit report or any document provided by the Credit Agency to Loop. Loop may request and use social insurance numbers, as required, to facilitate Credit Agency searches.
Log and Website Information
- When you access or use the Site, Loop may automatically collect certain technical information about your visit, including the date, time, browser type, your internet service provider, your IP address, device information (including device identifiers), geo-location information, computer and network performance data, the URL that you are coming from and your navigation history in order to customize and personalize your experience on the Site, diagnose and detect potential problems with the Site, manage and improve the Site and for statistical research purposes.
Correspondence and Q & A
- Loop will collect records of all correspondence with Loop. This includes questions, answers and other user-generated comments submitted to the Site.
- Loop may collect the personal information about third-parties that you provide to Loop or authorize Loop to collect. You are responsible for obtaining the necessary consent for the collection and use of this information and for the disclosure of this information to Loop.
Use and Disclosure of Information
Opening an Account
- Loop will use the personal information that Loop collects from you to open and maintain your Lending Loop account, including verifying your identity and the information that you provide to Loop and determining your eligibility to become a Lender or a Borrower on the Site.
- Loop may use your personal information to communicate with you about your Lending Loop account and to provide you with technical support.
Processing and Transferring Loans
- Loop may use the information that it collects to process and transfer loans funded on Lending Loop. Loop may also share this information with its third-party agents that help Loop to process and transfer loans.
Collections and Loan Repayments
- Loop may use a Borrower’s information in order to collect loan repayments or to enforce a loan agreement, a security interest or a guarantee. Loop may also disclose a Borrower’s information to a third-party service provider performing loan collection and enforcement services on Loop’s behalf, including, but not limited to any collections agency, legal counsel or receiver.
Borrower Information Accessible to Lenders
- Certain information about each Borrower will be displayed on the Site and accessible to General Account holders and Lenders to allow them to evaluate a Borrower’s loan request. This includes information regarding a Borrower’s location, business and operations and the loan terms (such as the loan principal amount, the interest rate and the term of the loan). Lenders will have access to additional detailed information about a Borrower, such as a Borrower’s full legal name, financial data and information with respect to the security securing the loan.
- Loop may use and disclose your personal information in order to detect, investigate, address and prevent fraudulent or illegal activities. Loop reserves the right to disclose your personal information as required by law, when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal process served on us and to defend against legal claims. Loop may be required to disclose your personal information to law enforcement, securities regulators and regulatory authorities, such as the Financial Transactions and Reports Analysis Centre of Canada, in the context of an investigation or audit. Loop also reserves the right to disclose your personal information to another organization to investigate the breach of an agreement, including the Terms, and for the purposes of detecting, suppressing or preventing fraudulent activities.
- Loop may disclose your personal information to Canadian regulators and regulatory authorities in order to meet applicable filing requirements. By engaging in borrowing and/or lending activities on Lending Loop, you consent to the filing of your personal information and copies or originals of any documents provided to Loop with any Canadian regulator. Should you have any concern in this regard, please consult your legal advisor.
- Loop may from time to time offer to compensate you, subject to certain terms and conditions, for referring prospective Lenders to Lending Loop. In the event you refer a prospective Lender to Lending Loop, your name will be disclosed to that prospective Lender where required by law.
- Loop may disclose and share your personal information to explore and/or undertake a corporate transaction, including a merger, acquisition, amalgamation, IPO, reorganization or sale of Loop. Your personal information will be used and disclosed solely for the purposes related to the transaction and will be protected by security safeguards appropriate to the sensitivity of the information.
Analysis and Research
- Loop may use the information that it collects for statistical analysis and market research purposes.
Retaining Your Information
- Loop will retain any and all personal information that Loop is required to retain under any applicable laws for the full duration of time required under those laws. Loop may also retain any and all personal information obtained from any Lending Loop account holder for the full duration of time required under applicable laws.
Third-Party Service Providers
- Loop may transfer your personal information to a third-party service provider for processing and storage. Whenever Loop engages a third-party service provider, Loop ensures that the information is properly safeguarded at all times at a comparable level of protection the information would have received if it had not been transferred. Loop may transfer your personal information to a third-party service provider outside of Canada. In the event that your personal information is transferred outside of Canada, the government, courts or law enforcement or regulatory agencies of that jurisdiction may be able to obtain disclosure of your personal information through the laws of that jurisdiction.
- Loop pays special attention to the protection of personal information and has therefore instituted industry standard security measures (firewalls, passwords, physical security, etc.) to protect users against any unauthorized access or disclosure. Although Loop strives to protect users' personal information, it cannot guarantee the absolute security of such information as no system is immune from fraud or hacking. In the event of a data breach, Lending Loop will notify users at the first reasonable opportunity of the breach and immediately apply remedial measures. Neither Loop nor any of its officers, directors, employees, consultants, representatives, agents, successors and assigns may be held liable in case of theft, illegal use, unauthorized disclosure, loss or the alteration or destruction of information by a third party.
- You may correct any inaccurate or out-of-date personal information by contacting Loop by telephone at 1 (888) 223-5667 or by e-mail at firstname.lastname@example.org.
- When you register for a General Account, you will be asked to consent to communications from Loop, including promotional emails and advertising. Please note that you may unsubscribe from Loop’s contact list at any time by following the procedure provided at the bottom of such email.
Deletion of Account Information
- Lending Loop is required by Section 19(1) of the Securities Act (Ontario) and subsection 11.5(1) of National Instrument 31-103 Registration Requirements and Ongoing Registrant Obligations (NI 31-103) to maintain records to accurately record its business activities, financial affairs and client transactions and to demonstrate its compliance with applicable requirements of securities legislation. Under subsection 11.6(1)(a) of NI 31-103, a registered firm must keep a record that is required under securities legislation for 7 years from the date the record is created.
- If you are a client of Lending Loop and have conducted business activities then Lending Loop is required to maintain these records for 7 years from the date the record was created in order to comply with securities regulations.
- If a Lender or Borrower has signed up for the Platform but did not conduct any business activities, you may submit a written request by e-mail to email@example.com to have your personal information details deleted from our systems.
For more information on how to file a complaint, please visit the answer to the question “Who Can I Contact If I Have A Complaint?” in Lending Loop’s FAQ.