Debtsadhu - Privacy Policy

August 2021

Your privacy is protected

Your privacy is important to us: You have chosen Debtsadhu to provide you financial services. We value the trust and confidence you place in us. At Debtsadhu, protecting the privacy and confidentiality of your personal information is very important to us and an integral part of our commitment to service excellence.

1. Definition:
   
   a. “Personal information” or “information” means information about an identifiable individual such as contact information, account numbers or details, such as age, marital status and financial information. This information can be in any form including paper, electronic, audio, video or biometric, such as voiceprints, photographs and signatures. This information can also include information collected through digital activities, such as device model, browser type and IP address.
   b. Debtsadhu Inc. shall hereinafter referred to as “Debtsadhu”, “we”, “our” or “us” that offer loans, provides credit building tools in partnership with business partners and other products or financial products and services as may be provided to You from time to time.
   c. “Partners” or “Lenders” means companies we are partnered with to provide loans, financial products or services.

2. What’s personal information do we collect?
   
   We collect from you or, with your consent, from third parties, the personal information necessary to provide the services you require. You are free to decline to provide this information, however, in order to provide the services we are obligated to collect the relevant personal information. We collect only the information necessary for the purpose of the file, in compliance with the law. This information includes:
   
   a. Contact information that allows us to communicate with you, such as name, address, telephone
   b. Identity information that allows us to identify your government-issued identification number, photo identification number such as  driving license, date of birth, father’s name, mother’s maiden name.
   c. Financial information that allows us to determine creditworthiness or eligibility for or appropriateness of products or services offered to you, such as employment and financial history with other financial institutions, income, net worth, credit reports, investment knowledge and objectives and details of security provided for loans.
   d. Transactional information about how you use different products or services or otherwise do business with us, such as, purchase and payment history.

3. How do we collect the information?
   
   We may collect information from you directly, indirectly or from other sources, such as:
   
   a. We may also collect information by monitoring or recording your interactions with Debtsadhu through telephone calls, video conferencing, online chats or other interactions with Debtsadhu’s websites and mobile sites
   b. product or service applications and use
   c. communications with us
   d. credit bureaus
   e. partners and lenders
   f. using cookies, when you visit our website (www.debtsadhu.com)
   g. other financial institutions
   h. government institutions or regulatory authorities
   i. user-generated content on our social media websites such as photographs or comments you post
   j. public sources such as telephone directories, newspapers, Internet sites, commercially available marketing lists, or government agencies and registries like land or property registries or driver licensing offices, or public records

4. Retention, use and disclosure of personal information
   
   We apply the necessary and appropriate security measures to protect the confidential nature of the personal information in our possession. This means that only authorized individuals can access the personal information in the files and only when necessary in the course of their duties.
   
   a. We use and share personal information to:
   b. Provide you with products or services –
    a. Establish and authenticate your identity and determine your eligibility for products and services
    b. Help to ensure that the advice, products and services offered to or purchased by you are appropriate for you
    c. Set up, manage, administer and maintain your products and services
   c. Communicate with you:
   
      a. Send communications to you by postal mail, email, text message, telephone, automated dialing-announcing device at the numbers you have provided us, fax, other telecommunication channels, social media or other methods. These communications include marketing or service communications about benefits, features or other details about products or services.
   
   d. Provide you with value
   
    a. Personalize your experience with us through data analytics or otherwise, including by reviewing and analyzing your applications, transactions, and other information, to:
   
   i. understand who you are, your financial needs and activities, and the products, services, promotions, offers and advice that may be of interest to you
   ii. predict or generate insights about your loan requirements and preferences
   iii. determine your eligibility for incentives, such as bonus interest, fee waivers and discounts) to try new products and services or  encourage continued use of your existing products and services
   iv. target or personalize products, services, promotions, offers and advice based on information that we have collected, including information we have collected through your promotional activities.
   
   e. Promote and market products and services offered by Debtsadhu, our partners, lenders or other third parties we are engaged with
   f. Better manage and improve your overall relationship with Debtsadhu, including monitoring, reviewing, analyzing or improving client services and business processes to make it easier to do business with us
   g. We have implemented various security measures, including:
   
   a. All permanent and temporary employees must sign a confidentiality agreement.
   b. Rules concerning the protection of the confidentiality of personal information in the files have been added to our Code of ethics and professional conduct, and the violation of these rules can lead to disciplinary action, up to dismissal
    c. Company representatives and providers of goods and services with access to personal information must sign a confidentiality agreement
   
   h. We do our best to ensure that the information in the file is up to date before it is used to make any decisions concerning you.
   i. Appropriate safeguards have been installed in our computer systems
   j. Unless you consent, or it is required by law, personal information in the files is never used for any purpose other than that for which it was intended. We may also collect and use personal information to protect access to your accounts and confirm your identity.
   k. Our client lists are only used or disclosed as permitted by law. We can use these lists to inform our clients of promotions or to offer a new product. If you would like to update, modify your personal information, you may write to us at [email protected].
   l. We won’t disclose the personal information about you contained in the file to any third party, unless we receive written consent from you, or we are authorized by law to do so (for example, in the case of an inquiry by the officers of the court).

5. Specific ways we may use and share personal information:
   
   Some of the specific ways we collect, use and share your information with lenders, partners and other third parties.
   
   a. Partners or lenders
   We share information with our partners to help determine your eligibility for a loan that you have applied through us. The information is shared with our partners and lenders to analyze, validate your requirements, develop new benefits, products and services and conduct market research. If you withdraw your consent to this sharing, we may not be able to provide you with the product or service where the sharing is necessary to receive the benefits and features of the products and service that we provide.
   
   b. Business transactions
    If we enter into a business transaction involving personal information or are considering one, such as selling or securitizing assets, we may share information with the other parties to the transaction. For example, we may do so as part of due diligence or on completion of the transaction. We require that the other parties keep this information confidential and limit its use to the purposes of the transaction. Where we enter into a business transaction involving the purchase of information by us, this policy will apply to our collection, use and sharing of the purchased information (which may include information we continue to hold beyond the end of your relationship with us). If we sell assets, the purchaser may be permitted or required by law to retain certain information for a period of time. We may also share your information with the beneficial owner of a product or service we provide to you.
   
   c. Credit bureaus
     In order to sell certain products/ services to you, we may exchange information about you with credit bureaus on an ongoing basis for as long as you hold the product and for a reasonable time afterwards. This may include information about your current and past credit accounts such as, type, amount, payment history, collections actions, legal proceedings, or other information that the credit bureau has collected from your other lenders. We may collect, use and share this information to verify your creditworthiness, assess and manage our credit risks, establish credit and hold limits, qualify you for other products and services, and detect and prevent fraud. We may also periodically update your information with credit bureaus to help maintain the integrity of the credit reporting system.
   
   d. De-identification and analytics
   We may de-identify or anonymize your information by removing identifiable information such as your name, address, date of birth and account numbers. Such information may be aggregated with other information, and used for internal business purposes such as analytics and reporting, developing and improving our products and services, understanding and predicting client needs and preferences, preventing and detecting fraud, identifying trends like purchasing patterns, fraud trends, or enhancing our marketing.

6. How do we protect your information?
   
   At Debtsadhu, we take the protection of your personal information seriously. We make reasonable efforts to prevent unauthorized use, sharing, loss and theft of information. We regularly audit our security measures  and assess that they remain effective and appropriate. Our employees who have access to your information are made aware of the importance of keeping it confidential.

   Information may be shared with or accessed by our partners or lenders or service providers so that they can perform services on our behalf. We are careful when selecting our service providers and require them to have privacy and security standards that meet Debtsadhu’s requirements. We use contracts and other measures with our service providers to maintain the confidentiality and security of your information and to prevent it from being used for any other purpose other than that for which it was intended.

7. How long and where the information is stored?
   
   The length of time we keep your information will vary depending on the product or service and the type of information we have. We keep your information for as long as we reasonably need it to provide you the service, to meet the legal requirements or reasonable business purposes. For these reasons, we keep your information beyond the end of your relationship with us for such period as it may be required by the applicable laws. When your information is no longer required, we securely destroy it or delete personally identifiable information. Depending on the nature of the information, your information may be stored in the Debtsadhu’s centralized repository or office, in various computer systems or in the record storage facilities of Debtsadhu or our service providers.

   Information may be stored and processed within Canada where we have our service providers or partners of lenders.

8. Your Privacy choice
   
   We do not collect any information which is not relevant to provide you the products and services.

   Subject to legal, business, or contractual requirements, you can withdraw your consent to our collection, use or sharing of information at any time upon giving us reasonable notice. However, withdrawing your consent may limit or prevent us from providing you with, or being able to continue to provide you with, specific products and services. For example, if you choose not to provide us information about your income which requires us to validate your repayment capacity of loan, we would not be able to process and secure approval on your application for loan. Because, in order to get the approval on your loan application, we have to validate your repayment capacity.

   a. Promotional Communications

   Subject to applicable law, from time to time DebtSadhu may offer you products and services of Debtsadhu or its partners and lenders, including special promotions, which may be of interest to you. Your consent to receive promotional communications is optional and you can decide to withdraw it at any time. However, this will not limit the information provided to you through discussions with a Debtsadhu representative or through general Debtsadhu marketing or servicing communications, such as posters in our centers, social media and electronic messages or our website, or information we send you that is related to your existing products or services or is permitted or required by law. We may also, from time to time, communicate with you to ask whether you wish to update your marketing preferences to help ensure that our records are up-to-date and reflect your current preferences.

   b. If you wish to update your marketing preferences:

   Contact the Debtsadhu office or call us at 1-833-903-3016 or write to us at [email protected]. We will then update your file as quickly as possible. It may take some time for our records to reflect your choice. Also note that your choice may not be captured for a promotion already in progress. You may also opt out of email communications by selecting the “unsubscribe” link included in each of our communications.

   c. Call recording:

   Telephone calls with Debtsadhu representatives may be recorded and monitored for coaching, training, quality and security purposes.

   d. If you do not wish to have your telephone calls recorded:

   You have the option to conduct your business with us through our website.

    In certain circumstances, your consent cannot be withdrawn. For example, you may not withdraw your consent where our collection, use or sharing is permitted or required by law, is required to ensure we have corrected and up-to-date information about you, such as current address or is necessary to manage our business including the sharing of information when we assign our rights to others for business transactions.

   e. Keeping your information updated:

   We make every reasonable effort to keep the information in our records as accurate, complete and up to date as necessary for the purposes in which it is used. However, we also rely on you to tell us when your information changes. Keeping your information accurate and up-to-date allows us to continue to offer you the highest-quality service.

   f. If you want to update or correct any personal information we have about you, contact the Debsadhu office or talk to Debtsadhu representative or you may call us at 1-833-903-3016. If you tell us that we have information about you that is obsolete or incorrect, we will update our records as necessary. When appropriate, we’ll correct any information which we may have given to a third party as may be required.

   g. Accessing your information:

   You have the right to access personal information we hold about you. Much of your information is available to you through email, call or text or through Telephone.

   h. If you want access to additional personal information we may hold about you:
   
    We will require you to put your request in writing (we can give you a form) and provide us with enough specific details to help us understand your request and conduct our search for your information. We will need you to verify your identity before searching for or providing you with access to your information. We will let you know in advance whether there will be a fee to provide access to your information. We may also ask you for additional information to confirm the scope of your request, such as the relevant time period or a specific description of the information you are seeking to access.

   Once we receive your written request, verify your identity and understand the scope of your request, we will provide a written response to your access request in accordance with the time frame prescribed by applicable privacy law.

   i. Addressing any privacy concerns:

   If you have any questions, concerns or complaints about this policy or our privacy practices, let us know in writing. You may contact us:

   a. Telephone: 1-833-903-3016
   b. Fax: 1-833-843-8434
   c. Email: [email protected]
   d. Write to: Debtsadhu, 1 Yonge St, Suite 1801, Toronto, ON, M5E 1W7

   Be sure to include your name and contact information where you prefer to be reached, the nature of your complaint, question or concern, details relevant to the matter and the names of any individuals whom you have already discussed the issue with.