Introduction & Scope

Protecting your privacy and the confidentiality of your personal information is important in the way we do business at Prefera Finance Ltd. (“Prefera”, “we”, “us”, “our”). This Privacy Policy describes the personal information that Prefera collects from or about you on or through our website www.preferafinance.com (the “Website”) and in connection with your access to and use of our products and services (collectively, the “Services”). This Privacy Policy also describes how we use and to whom we disclose your personal information. PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING OUR WEBSITE OR SERVICES, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY AND AGREE TO BE BOUND BY ITS TERMS. YOU CAN WITHDRAW YOUR CONSENT AT ANY TIME, HOWEVER, IF YOU CHOOSE TO DO SO, WE MAY NOT BE ABLE TO PROVIDE YOU WITH THE ACCESS TO OR USE OF THE WEBSITE OR SERVICES.

Prefera may amend this Privacy Policy to reflect changes in our legal or regulatory obligations or in the way we deal with your personal information. We will post any revised version of this Privacy Policy on our Website and the revised version of the Privacy Policy will be effective at the time we post it. If we make material changes we will notify you as required by law, but we encourage you to refer to this Privacy Policy on a regular basis. Your continued use of the Website and Services after an update signifies that you consent to the collection, use and disclosure of your personal information as described in the updated Privacy Policy. The revised Privacy Policy will be posted on our Website at: www.preferafinance.com/privacy.

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual.

The Personal Information that Prefera Collects

We collect and maintain different types of personal information in respect of the individuals with whom we interact. Before permitting to use and access the Website and/or the Services, we may require you to provide us with certain personal information. For example, we collect information when you choose to create an account and use our Services, participate in any of our offers, promotions, programs and other initiatives, contact us or otherwise provide your personal information to us for any other purpose. The types of personal information that we collect include: (a) your contact and identification information, such as your name, address, phone number, email address, social insurance number and other similar information; (b) your financial information, such as you credit information, banking information, credit card number, credit score, debit card number, payment history and other similar information; (c) your location and demographic information, such as your date of birth and age; and (d) other additional information concerning the products and services that we provide to, or receive from you, including reviews, comments and feedback that you provide regarding our Website and Services.

Prefera may also collect information related to your visit to our Website, including including the IP address, the device domain used to access our Website, the operating system on your device, your device settings, application IDs the type and version of your browser, crash data, other unique device identifiers, the website you came from to access our Website, the page you entered and exited at, any website page within our Website that is viewed by your IP address and what country you are from. We use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our Website and Services offerings.

We may place a “cookie” on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our Website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the Website so that we can better understand your use of our Website so that we can customize and tailor the Website to better meet your needs. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the Website.

As a general rule, Prefera collects personal information directly from you. In most other circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied from your actions).

From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Why does Prefera Collect Personal Information?

We only collect the necessary information from you to provide you with our Services, access our Website and which enables us to manage, maintain and develop our operations. For example, we collect personal information to:

• establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the Services that have been requested, including the extension, maintenance and/or renewal of credit;
• enable you to register, access and maintain an account with us and otherwise use the Website;
• allow you to participate in, subscribe to or otherwise receive Services from us, including with respect to any merchant through which you have arranged financing;
• determine your eligibility for our Services as well as your creditworthiness;
• keep records of the Services requested by and/or provided to you;
• be able to review the Services that we provide to you so that we may: (a) understand your requirements for our Services; and (b) work to improve our Services;
• be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
• understand your preferences and tailor offers, products and services to you based on these preferences;
• send information to you about promotions, products or services of ours or our marketing partners that we believe may be of interest to you;
• protect Prefera against error, fraud, theft and damage to our goods and property;
• conduct analysis and evaluations to understand usage and trends in order to improve our Services, products, services and marketing communications;
• meet regulatory or contractual requirements relating to the Services provided to you;
• enable us to comply with applicable laws or regulatory processes; and
• any other reasonable purpose to which you consent.

By consenting to our collection of your personal information through your access to and use of the Website and Services, you allow us to fulfill the purposes for which we collect your personal information. When we collect your information for research and development purposes, we ensure that any information used for our analysis and reports will be de-identified and aggregated in a manner that will not identify you.

How Prefera uses your Personal Information

We may use your personal information: (a) as permitted or required by applicable law or regulatory requirements; (b) for the purposes of collection and/or as otherwise described in this Privacy Policy; and (c) for any additional purposes for which we have obtained your consent to the use of your personal information. When requesting your consent, we will make sure you understand why we need the information by using clear, understandable language when we communicate with you and for what purpose the information is used.

We may use your personal information without your knowledge or consent where we are permitted by applicable law.

We do not sell, license, trade or rent personal information to third parties for the purposes of soliciting you for non-Prefera products or services.

We will collect your express consent to our contacting you with any electronic marketing messages. You will have the opportunity to opt out at any time.

When does Prefer Disclose Personal Information?

We share your personal information with employees, affiliates, vendors, partners, merchant partners, marketing providers, and other third parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. For example, Prefera discloses personal information to third parties for the purposes described in this Privacy Policy, including in the following circumstances:

• We share personal information with credit bureaus and credit reporting agencies to provide information to them about your credit obligation with us.
• We may disclose personal information to a third-party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so, including for example, in the event of payment default to collect on our debts and to realize our security interests.
• In the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Prefera or of any of the business or assets or shares of Prefera or a division thereof, we may share personal information in order for you to continue to receive the same products and services from the third party.

Otherwise, we do not disclose your personal information without your consent unless we are permitted or required by applicable law or regulatory requirements to do so.

Since we may share your personal information from time to time with third parties, as described in this Privacy Policy, your personal information may be collected, used, processed, stored or disclosed outside of Canada. As such, your personal information may potentially be accessible to law enforcement and national security authorities of another jurisdiction. If you would like further information about our policies and practices regarding service providers located outside of Canada and further information about how these service providers, collect, use, disclose or store personal information, please contact our Privacy Officer using the contact details below. By providing your personal information to us, you consent to our disclosure of this information to our service providers, merchants and other third parties as described in this Privacy Policy, including those that may be located outside of Canada, for the purpose of processing your requests, marketing to you, providing services to us or to you, to operate our business and for the other purposes of described in this Privacy Policy.

Your Consent is Important to Us

Except as authorized by law, Prefera only collects, uses or discloses your personal information with your permission. Your consent may be expressed in writing or be implied, and you may give it to us verbally, electronically, or through your authorized representative. Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavour to advise you of that purpose before such use or disclosure.

You may withdraw your permission to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions required in respect of fulfilling your obligation under any agreement with us and under the circumstances noted above and by allowing reasonable notice period.

We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified purposes for which the information is being provided.

Unless you advise us otherwise, through the access and use of our Website and Services, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Retaining and Storing Personal Information

We will only keep your personal information as long as it is necessary to fulfill the purposes for which it was collected or as required by law, and your consent to such purposes remains valid after termination of our relationship with you

For the purposes set out in this Privacy Policy, we or one of our affiliates or an unaffiliated service provider may process and store your personal information outside of the province in which you reside and/or outside of Canada, and under the laws of those other jurisdictions, in certain circumstances courts, law enforcement agencies, regulatory agencies or security authorities in those other provinces or foreign jurisdictions may be entitled to access your personal information.

Security of Your Personal Information

Prefera is responsible for all personal information in our possession at our places of business or stored electronically, including information transferred to a third-party service provider or business partner in connection with servicing your account. Prefera will endeavour to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. The steps that Prefera takes to protect your personal information include the following:

• All employees, business partners and authorized service providers of Prefera are required to protect the confidentiality of your personal information and are prohibited from using your personal information for any purpose other than to provide the Prefera services to you.
• Access to your personal information is restricted to those of Prefera’s employees, service providers and business partners who need it to do their jobs and all such individuals are required to protect personal information collected by them on behalf of Prefera or disclosed to them by Prefera and to comply with the general privacy principles described in this Privacy Policy.
• Prefera has developed and are continuing to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, access, use or modification.
• Prefera maintains appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, and sensitivity of the information, organizational measures including security clearances and limiting access on a “need-to-know” basis, and technological measures such as the use of passwords and encryption.
• When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Updates to Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

Links to Third Party Websites

Our Website may contain links to other websites that may be subject to less stringent privacy standards. These links are provided for your convenience only and you assume all risk for clicking these links to other websites. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Prefera is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Questions and Complaints

You may register a privacy-related complaint by contacting Prefera’s privacy officer as described below. We will explain Prefera’s complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right, including changing our policies and practices if necessary. We will also let you know what other complaint procedures may be available to you.

For More Information

For more information about Prefera’s privacy practices or this Privacy Policy, please contact Prefera’s Privacy Officer at privacy@preferafinance.com, or contacting our office by mail or phone at the appropriate contact information found at our Website at www.preferafinance.com.

**If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending any personal or confidential information to us.**