CREDIQUE LLC PRIVACY FACTS NOTICE

(Last Updated April 2020)

---

CREDIQUE LLC PRIVACY POLICY

(Last Updated April 2020)

---

Credique LLC ("we," "us," or "our") respects your privacy and knows that you care about protecting your personal information. This privacy policy identifies what information we collect from you when you use www.creditverify.ca (the "Site," including all subdomains) and the services made available on it (the "Services") and explains how we may use or share that information. We will only use and share your information as described in this privacy policy.

This Site primarily operates as a for-profit business website. This privacy policy applies to information we collect from you on the Site; through the Services; in email, text, and other electronic correspondence; and through any mobile or desktop application through which we may communicate. This privacy policy does not apply to information we collect offline or that any third party collects from you after following links on the Site, including any advertising and affiliate links.

PLEASE READ THIS PRIVACY POLICY AND OUR TERMS OF USE CAREFULLY. THE TERMS STATED IN THIS PRIVACY POLICY CONSTITUTE A BINDING LEGAL AGREEMENT BETWEEN YOU AND CREDIQUE LLC. BY USING THIS SITE AND THE RELATED SERVICES, YOU UNCONDITIONALLY AGREE TO BE BOUND BY THE TERMS STATED IN THIS PRIVACY POLICY AND OUR TERMS OF USE, INCLUDING ALL EXCLUSIONS AND LIMITATIONS OF LIABILITY, AND WARRANT THAT YOU HAVE FULL AUTHORITY AND CAPACITY, LEGAL AND OTHERWISE, TO USE THE SERVICES. YOU MAY NOT ACCESS OR USE THIS SITE OR THE SERVICES IF YOU DO NOT AGREE TO ANY PART OF THESE TERMS. WE RESERVE THE RIGHT TO PERIODICALLY MAKE UPDATES TO THIS PRIVACY POLICY AS OUR PRACTICES CHANGE. YOUR CONTINUED USE OF THE SITE AFTER SUCH CHANGES CONSTITUTES YOUR ACCEPTANCE OF THE CHANGES, SO PLEASE CHECK BACK PERIODICALLY FOR UPDATES.

1. Information We Collect

   We may collect and use the following types of information from those who use the Site and the Services:

   • Information by which you may be personally identified, such as your name, address, email address, phone number, billing and credit card information, and other information that may not be publicly available ("personal information").
   • Reports about you that are provided to us by credit grantors or other institutions that are responsible for obtaining your consent to provide the information to us.
   • Personal information from collection agencies.
   • Public records, federal and provincial government offices, public registries, and other sources permitted by law.
   • Information about you that does not identify you personally, including, but not limited to, your personal interests, online interactions, viewing data, requests for Services, communications with us and third parties, advertisement interactions, and any other activities when using the Site or the Services.
   • Information you provide when you register with the Site and the Services, when adding or updating account preferences, and when subscribing for any Services.
   • Information about your transactions using the Site and the Services, including, but not limited to, your purchases and order history.

   We may combine information you provide us with other information about you that we obtain from your past use of the Site and Services, from our business partners, and from other companies. We may access other information about you collected from third parties, such as social media and marketing companies. We will treat any non-personal information that is combined with personal information as if it were all personal information.

   We limit our collection of personal information to include only what is necessary to supply our clients with accurate and up-to-date information they need to make meaningful decisions and in order to provide our customers or you with the other services described in this Privacy Policy. We periodically review the data in our credit-reporting system to ensure that it only contains information relevant to the services we provide. Furthermore, we ensure that our retention policies comply with the requirements of privacy laws and provincial consumer reporting legislation.

   If you call us, we may record and retain the recording to ensure the accuracy of our discussions and for quality control and record keeping purposes.

   We may use video surveillance in and around our walk-in locations for the safety of our customers and employees, and to protect against theft, property damage and fraud.

   1. What is Included in Your Credit Reports

      Consumer Credit Reports: Consumer credit reports may contain the following personal information:

      • Identifying information: Consumer name, previous name(s), date of birth, Social Insurance Number (including temporary and/or previous Social Insurance Numbers), current and previous addresses and telephone numbers, and current and previous employers
      • Credit history: Record of payment history on current and previous bills/debt obligations, including payments on loans, credit cards, lines of credit and mortgages owing to organizations such as retail stores, banks, finance companies and telecommunications companies. 
      • Public records: Information that may affect creditworthiness, such as judgments, bankruptcies, consumer proposals and registered items;
      • Inquiries: A list of credit grantors and other parties authorized by the consumer and/or by law that have received all or part of a consumer’s credit information.  Also lists organizations that have received a service from Credique LLC where consumer credit information was used but not necessarily disclosed, such as authentication;
      • Collections: Information about collection matters. This segment may include information about outstanding collections on business accounts if you are personally liable for the debt.  It may also include information about outstanding family maintenance support obligations, if permitted by law; 
      • Banking: Information about bank accounts that were closed by an institution for reasons such as empty envelope deposit, NSF cheques or uncollected overdraft charges; and
      • Remarks:  All remarks that have been added to your file, such as a fraud alert or a consumer statement.

   2. Other Information we may also collect:

      • Contact information, such as your email address, telephone number and postal address, for the purposes of responding to your inquiries or requests;
      • Information necessary to process payments for services that you have purchased from us, such as your credit card number and expiry date;
      • Death records; and
      • Information you have reported to us as lost, stolen and/or misused, such as your Social Insurance Number.

2. How We Use Your Information

   We limit our use of personal information to those purposes which have been disclosed to the individual by us or our customers and for which appropriate consents have been obtained, or for purposes which are otherwise permitted by law. In connection with our credit reporting services, we do not have direct relationships with individual consumers or principals.  Accordingly, we require our credit-granting and other customers to inform individuals of the purposes for which they are providing personal information to Credique LLC, or accessing personal information from Credique LLC, and to obtain appropriate consent at the time the information is collected from the individual and/or prior to its use or disclosure by Credique LLC.  We also require our customers to limit the use of personal information obtained from Credique LLC to purposes that are permitted by law.

   Credique LLC uses and discloses personal information in the following circumstances:

   • To provide our consumer credit reporting services, and other related services to our customers;
   • To provide fraud detection and monitoring, authentication, ID verification and/or credit monitoring services to customers purchasing your credit file;
   • To deliver data and products to direct-to-consumer resellers with which you have contracted directly;
   • To provide consumer credit information directly to consumers who have dealings with us (i.e., who have requested a copy of their credit report), or to provide services to consumers, such as placing a potential fraud alert on a consumer’s file;
   • To communicate with you regarding services that may be of interest to you;
   • To manage, administer, collect or otherwise enforce accounts;
   • If Credique LLC was ever sold, or if we merged with another company, or transferred part or all of our shares or assets, we may disclose and/or transfer personal information to our successor or assign who may collect, use and disclose the personal information for substantially the same purposes as described in this Privacy Policy;
   • To assist in the investigation of a contravention of a law and/or fraudulent activities;
   • To fulfill our obligations under consumer reporting and privacy legislation (such as, a request to initiate an investigation); and
   • To act in respect of an emergency that threatens the life, health or security of an individual or for other purposes as permitted or required by law.

   In addition, we may provide anonymous information (i.e., information that does not identify individual consumers or principals) in the form of aggregate or demographic data to our clients or service providers.  We may also generate and use anonymous information to develop, enhance or validate our products, processes or services. Personal information will necessarily be used to generate anonymous information and, when required, to research, validate and test the use of anonymous information in such processes, products, services and enhancements.

   Credique LLC may share personal information with third parties engaged to assist us in providing services and information to our customers and to individual consumers. In addition, we may engage third parties to assist us with infrastructure maintenance and support.  These service providers are prohibited from using your personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed by Credique LLC and to comply with the general privacy principles described in this Privacy Policy. Some of these service providers are located outside of Canada.  As a result, your personal information may be subject to local laws, which may permit local law enforcement, government or national security authorities to have access to your personal information in certain circumstances.

   We also provide a suite of authentication services to assist our customers in identifying potentially fraudulent transactions. In the course of providing these services, we may use personal information contained in our credit files to see if it matches the information that has been provided by an applicant, typically to credit granting institutions or merchants. When we provide our authentication services, we typically do not disclose credit information; instead we use the consumer’s credit file to check the information internally. While preventing fraud is in everybody’s best interest, these services may directly benefit consumers if someone is attempting to pose as the consumer by misappropriating the consumer’s identity and personal credit information.

   We are the sole owners of information collected from visitors on this Site. We will not sell or rent your information to third parties. We use information collected from you or about you, including personal information, for the following purposes:

   • To administer the Site and enforce our rules and policies.
   • To provide access to Site content and Services to you.
   • To customize Site content and Services according to your preferences.
   • To improve the Site and Services.
   • To research and analyze the usage data, preferences, and trends of our visitors.
   • To diagnose technical or Service-related problems.
   • To maintain security over your information, the Site, and its contents.
   • To fulfill any requests for information, products, or Services.
   • To facilitate transactions you make on the Site or Services, which may include sending payment statements or receipts, or assisting with payment collection.
   • To provide targeted advertising.
   • To send you marketing communications, such as information about new products, Services, or specials.
   • To contact you regarding Services we provide you.
   • To contact you regarding third-party services you may be interested in.
   • To contact you regarding your account or profile.
   • To contact you regarding changes to this privacy policy.
   • To carry out our responsibilities and enforce any contracts between you and us, including billing and collection rights.
   • For any other use as we may indicate at the time you provide the information.
   • To fulfill any other purpose with your consent.

   All information collected from visitors of the Site belongs to us, whether or not such information is personal information, information you volunteer, or information passively collected about you. As such, such information may be subject to transfer to a new owner in the event of our bankruptcy, sale, or liquidation.

3. How We Share Your Information

   We may share personal information and other information that we collect as follows:

   • With our affiliates, including any subsidiaries we now own or later acquire.
   • With our trusted employees, contractors, business partners, service providers, suppliers, vendors, and other third parties that support us, which may include sending you emails on our behalf; analyzing your activities and interactions on the Site in order to make improvements to the Site, Services, and experiences of our visitors; and providing support to the Site, the Services, our operations, or fulfilling your requests. These third parties may only use personal information in order to provide such support and are contractually required to maintain the confidentiality of your information. For example, we may share personal information with credit card processing companies in order to bill visitors for goods or services.
   • With a buyer, successor, or other third party due to a merger, restructuring, reorganization, or other transfer or disposition of Credique LLC or our operations, including, but not limited to, in the event of a sale, bankruptcy, dissolution, or similar proceeding. In such event, we will provide you with prior notification if your information will become subject to a different privacy policy.
   • In response to court orders, subpoenas, or legal processes, such as requests from government regulatory or law enforcement agencies; to defend, pursue, or participate in legal actions or proceedings or exercise a legal right; to take precautions against actual or potential liabilities; to investigate or respond to potential or suspected illegal activities, fraud, or threats to the Site, its visitors, or the property or physical safety of any person; to enforce or investigate violations of our rules or terms of use; or as otherwise permitted or required by law.
   • With affiliates, licensors, merchants, partners, and other third parties for their own marketing purposes, such as to provide you with information regarding their programs, activities, new offers, special promotions, contests, products, services, and similar important purposes if you have consented to such sharing or not opted out. Such marketers are contractually prohibited from disclosing personal information and may only use personal information for providing support in accordance with this privacy policy. For more information about how to opt out of this sharing, see Opt-Out Procedures below.
   • With those that we so indicate at the time you provide the information.
   • To third parties when we have your consent.

   We may store personal information in locations outside of our direct control; for instance, on servers or databases where the hosting provider is located. Additionally, we may share or sell aggregate information about our visitors that does not personally identify individuals with our partners, affiliates, advertisers, and other third parties without restriction. This information may include personal information that we have changed so that individuals are no longer personally identifiable. We may also share this information with third parties in order to analyze visitor data, activities, and usage of the Site or Services in order to make improvements to the Site, Services, and experiences of our visitors.

   We display targeted advertisements using third-party ad servers, also known as ad networks. Targeted advertisements are ads that specifically target consumers that fall into certain demographics or that otherwise display characteristics that make them desirable for advertisers. Ad servers automatically communicate with your browser and receive your IP address. They may also use other technologies, including cookies and web beacons, to collect data and analyze the performance of their advertisements. This allows the ads we display to be more relevant and interesting to you. We do not provide personal information to advertisers when you view, click, or interact with a targeted ad. However, if you view, click, or interact with a targeted ad, the responsible advertisers and ad servers may assume that you have certain characteristics that match their intended audience. By viewing, clicking, or interacting with a targeted ad, you acknowledge and consent to ad servers recording such assumptions about you. Our privacy policy does not apply to the ad servers that display advertisements on our Site. Please consult their respective privacy policies for more information.

   If you choose to participate in any promotions or similar events through the Site or Services, the rules or terms and conditions for such events may change the way we share your information with third parties. Please review the applicable rules or terms and conditions for all such events in which you participate.

4. Links to Other Websites

   This Site may contain links to or from other websites. This privacy policy only applies to information collected on this Site, and we are not responsible for other website's privacy practices. Please be aware of when you exit our Site using such links. We encourage you to review the privacy practices of all other websites you reach through links on our Site.

5. Third-Party Tracking on Our Site

   We may place content, including advertisements, on our site from advertisers, ad servers, and other third parties. These third parties may use cookies, web beacons, or other tracking technologies associated with their content on the Site to collect information, including personal information, about your activities over time and across different websites. They may send you targeted ads or other content based on this information. We have no control over how these third parties use your information, and you should contact the responsible party with any related questions or concerns. For more information about how to opt out of this tracking, see Opt-Out Procedures below.

6. Opt-Out Procedures

   As your privacy is important to us, we provide you with the following procedure(s) for opting out of future communications from us:

   • Email.

     Send an email to help@identityprotect.ca explaining the specific communications or privacy practices you want to opt out of. You may also opt out by clicking "unsubscribe," or a similar button, at the bottom of any emails we may send you and then following the online instructions. However, please note that it may not be possible to opt out of certain emails (for example, confirmation emails related to services you have requested).

   • Third-Party Advertisers.

     You may use the procedure(s) above to opt out of us sharing personal information with advertisers and other third parties that will use your information for promotional purposes, such as marketing their goods and services to you.

   • Targeted Advertising.

     You may use the procedure(s) above to opt out of us using your information to provide you with targeted ads using third-party ad servers.

   • Third-Party Tracking.

     We cannot control the privacy practices of third parties that use cookies, web beacons, or other tracking technologies associated with their content on the Site to collect information about your activities over time and across different websites. These third parties are subject to their own privacy policies, not this one. However, these third parties may provide procedures for opting out. Please review their privacy policies for more information.

   • Cookies.

     The Website makes use of "per-session" cookies. Unlike "persistent" cookies, which are stored on a user's hard drive and can last indefinitely, per-session cookies are stored only in a browser's temporary memory and are deleted when the browser is shut down.

     When users visit our Website, our web server offers the user's browser a per-session cookie. As the Website is navigated, this cookie is read back to our web server, allowing us to generate an anonymous "click trail" profile of the visit. From the aggregated information about visits, Credique LLC learns how visitors interact with its Website, how the Website design and content can be improved, and how visitors' experiences can be improved.

     Credique LLC does not link, share or associate the contents of the per-session cookie with any other information in a way that would enable the identification of visitors to our Website. Nor do we track or link together multiple visits by any single user over time. Our per-session cookies cannot be "read" by any other web servers, so users cannot be tracked or profiled using Credique LLC’s cookies if they visit multiple sites on the Internet.

     Some browsers can be set to reject all cookies. If a user chooses to modify a browser in this manner, some pages of our Website may not function properly.

   • Third-Party Accounts.

     In the event that you have chosen to connect your account to another account you have on a third-party website, YOU ACKNOWLEDGE AND AGREE THAT PERSONAL INFORMATION MAY BE PROVIDED TO THE RELEVANT THIRD-PARTY WEBSITES HOSTING UNTIL SUCH TIME AS YOU DISCONNECT YOUR TWO ACCOUNTS. You acknowledge that such third-party websites are not subject to this privacy policy. Do not connect your accounts if you do not want personal information shared in this manner. You may disconnect your accounts by either 1) signing in, visiting your account page, and configuring the relevant settings, if available, or 2) emailing us at info@creditverify.ca with your request.

7. How to Access and Change Your Information

   You are responsible for keeping any personal information you provide on the Site current. Please email us at help@identityprotect.ca to request access to view, correct, or delete information you have provided to us. We will make reasonable efforts to comply with your requests, if possible. If you provided personal information in connection with a specific Service we provide, you may have to update or delete that information by returning to that Service page. Any requests to delete your information are subject to our internal reporting and retention policies as well as any legal obligations that we may have. You can also update or delete some or all of your personal information in your account by signing in, visiting your account page, and configuring the relevant settings.

8. Security

   We take the security of your information seriously and have electronic, physical, and administrative safeguards in place that comply with federal regulations for your protection. These security measures seek to protect your information both online and offline from disclosure, alteration, or unauthorized use. However, please keep in mind that no transmission of data over the internet is guaranteed to be completely secure. Third parties may be able to access private communications illegally; for instance, through the use of hacking and viruses. As such, all information you transmit on the Site or Services is at your own risk. We are not responsible for instances where third parties circumvent our security measures without authorization, illegally or otherwise.

   The information you submit to us is encrypted using Secure Sockets Layer (SSL) data encryption technology and is transmitted securely. You may verify this by locating "https" at the beginning of the address of the webpage or an icon of a closed lock in your browser. The computers and servers we use are also kept in a secure environment behind firewalls. We limit access to your information to those people that need to view it to perform necessary support tasks, including fulfilling your requests. We also require you to create a unique password to help secure your account. It is your responsibility to maintain the secrecy of your password and other login information. We will promptly notify you in the event that personal information becomes compromised according to our notification procedures outlined below or as otherwise required by applicable law. In addition, Rijndael will be used for sensitive user data.

   Unique Internet Protocol (IP) addresses are assigned to all Internet users by their Internet Service Providers (ISPs). IP addresses do not directly identify Internet users; however, through an ISP, an IP address may be linked to a particular user.

   During a visit to a website, certain information about a user's traffic patterns, linked with the user's IP address, is passively and automatically collected in the normal course of establishing and maintaining a website connection. This information is logged by the web server of the website that is visited.

   The following information is logged by Credique LLC’s web servers during visits to our Website: IP addresses, type of operating system, time and duration of visit, web pages visited and browser type. We do not link server log information to any other information in a way that would enable the identification of visitors to our Website. Server log information is analyzed by us in order to improve our Website and to customize the Website for users. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on our Website. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

9. Changes to This Privacy Policy

   We may update this privacy policy at any time. We will post any changes in our privacy practices on this page with the date of the most recent revision indicated next to "Last updated" near the top of the page. If we make significant changes to the way we manage our visitors' personal information, we will notify you by email or by posting prominent notice on our Site. It is your responsibility to ensure we have your current email address and to periodically check this page for any updates.

10. Notification Procedures

    We reserve the right to determine the most appropriate means of providing you with any notice required or advisable, in our sole discretion, under the terms of this privacy policy or as required by law. We may choose to provide notification by email, physical written notice, posting prominently on the Site, or through other conspicuous means.

11. Cross-Border Data Transfers

    Your personal information may be processed and transferred to countries other than your own, including, but not limited to, any country in which we operate. Some of these countries may have different laws and practices regarding data protection than your country. By using the Site, you agree to such cross-border transfers of your personal information.

12. Contact Information

    Please contact our Consumer Relations Centre using the contact information below. Our Consumer Relations Centre is staffed by trained personnel who can assist with your inquiries. You may also direct your inquiry to our Chief Technology Officer. We may require that you put any request for access or correction in writing.