Privacy Policy

INTRODUCTION

This privacy policy (The ‘Policy’) describes how Lenditt Technologies Inc. ("Lenditt", "we", "us", or "our") collects, uses, secures, and shares Personal Information in connection with all products and services we offer. It is our intention to manage and handle your Personal Information in a manner consistent with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA, as amended from time to time, and all other applicable Canadian federal and provincial privacy legislation.

This Policy applies when you:

1. Visit our website (https://www.lenditt.ca/ ), and mobile applications (Lenditt: Instant Personal Loan) owned and operated by us, all subdomains provided through such other site or the website, and all downloadable applications, features, functionality, content or information that is made available or provided by us (the "Platform")

2. Engage with us in other related ways, including marketing

3. Direct interactions with you, for example, by filling in forms, corresponding with us, or entering a contest or promotion sponsored by us.

4. Acquire, apply for or use the services we provide.
   
   ​​Reading this Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our services. If you have any questions or concerns, please contact us at the details provided in Section 17 of this Policy.
   
   This Policy is designed to comply with applicable privacy legislation in Canada, which incorporates the following ten principles: (i) Accountability (ii) Identifying Purpose (iii) Obtain Consent (iv) Limit Collection (v) Limit Use, Disclosure and Retention (vi) Accuracy (vii) Safeguards (viii) Openness (ix) Individual Access (x) Challenging compliance
    

WHAT IS PERSONAL INFORMATION
“Personal Information” means any information about an identifiable individual, which may include your name, age, date of birth, home address, Social Insurance Number (SIN), income, account number, client identification number, telephone number, email address, and Internet Protocol (IP) address. Personal Information does not include business contact information used solely for work-related communication, or data that has been aggregated or anonymized in accordance with applicable Canadian regulatory standards such that it can no longer be used to identify an individual.
 

ELIGIBILITY AND EXCLUSIONS
Our products and services are intended solely for individuals who have reached the age of majority in their applicable province of residence. This Policy applies to Canadian residents only. Lenditt does not offer services to residents of Quebec or the Canadian Territories and does not knowingly collect Personal Information from individuals residing in those jurisdictions. Not all of our products are available in every province; products availability depends on your province of residence. This Policy applies both to individuals applying for products and services and to existing customers whose accounts are maintained or serviced by us.

We do not knowingly collect Personal Information from individuals who have not reached the applicable age of majority in their province of residence. If we become aware that we have collected Personal Information from an individual who has not reached the applicable age of majority, we will take reasonable steps to delete such information, unless retention is required or permitted by applicable law.
 

WHAT PERSONAL INFORMATION DO WE COLLECT?
The Personal Information we collect depends on the service you request. We may collect Personal Information about you from the following sources:
a) Information we receive from you on the Platform, such as your name, address, phone number, email address, SIN, income and employment  details  (current and previous employer, role, and contact information).
b) Confirmation of employment information from your employer.
c) Information we receive from other third parties, such as credit reporting agencies and other financial institutions, relating to your initial and  ongoing creditworthiness.
d) Financial and Banking Information, including bank account details (transit, institution, and account numbers) for loan funding and repayments,  and bank transaction history/statements accessed via secure third-party bank verification providers (such as Flinks) to verify your income and employment.
e) Device, technical and usage data automatically collected when you visit the Platform, including IP address, device identifiers, browser type,  operating system, location data, and usage logs. Under applicable Canadian privacy laws (including PIPEDA, BC PIPA, and Alberta PIPA), , IP  addresses and device identifiers constitute personal information when they can identify an individual.
f) Biometric information (selfie image) collected during the identity verification process. This is sensitive personal information and is subject to  enhanced protections described in Section 6 (Facial Scan & Data Policy) below.
g) We may also use cookies and other technologies to collect information (including location information) when you use our Platform.
h) Signatures or electronic signatures provided by you when completing applications or signing loan agreements.
i) Voice and audio recordings of your telephone calls with our customer service, collections, or operations representatives.
 

WHY DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect, use and disclose your Personal Information for the following reasons:
a) To communicate with or contact you (e.g., address, mobile number, email or other electronic mode of communication). We may communicate with  you electronically regarding your application, loan account, servicing matters, disclosures, notices, statements, collections, privacy matters, and  other information relating to our products and services;
b) To verify client identity (e.g., date of birth, government-issued identification, occupation), prevent fraud, and comply with our obligations as a  licensed lender under applicable provincial consumer lending and consumer protection legislation; To meet legal and regulatory requirements;
c) To provide financial services to you, and to authorize and process your transactions;
d) To detect and prevent fraud and help safeguard the financial interests of Lenditt and clients (e.g., reviewing and analyzing your transactions and  other information to help us identify various types of threats and risks, such as credit, fraud and money laundering);
e) To develop, offer, and manage the various services provided by our company in order to meet users’ needs (e.g., loan, payment history,  communication preferences and location);
f) To maintain adequate accounting, tax and business records; 
g) Where applicable, to confirm details of your employment; 
h) To assess the quality and quantity of our services (e.g., call monitoring, record and respond to client feedback);
i) To record, store, and monitor telephone conversations with our customer representatives for quality assurance, training, and dispute resolution  purposes (you will be notified of this recording via an automated message at the outset of any inbound or outbound telephone call)
j) To collect and process your signatures or electronic signature to execute legally binding loan agreements.
k) To collect a debt that is owed to Lenditt. 
l) To make credit decisions using automated and algorithmic processes that assess information such as your financial history, income, existing  credit  obligations, identity verification results, fraud indicators, and other information relevant to the assessment of your application and ongoing  eligibility for our products and services.
m) We may report information relating to your loan account to credit reporting agencies on an ongoing basis. This may include  information  regarding your account status, payment history, outstanding balance, and repayment activity.
n) To send you marketing communications about our products and services by email, SMS, or other electronic means, only where you have provided  express consent as required by Canada’s Anti-Spam Legislation (CASL). You may withdraw your consent to receive marketing communications at  any time by using the unsubscribe mechanism included in the communication or by contacting our Privacy Officer.

Note: Transactional messages (loan approval/decline notices, payment reminders, account statements, OTP codes) do not require CASL marketing consent and will continue regardless of your marketing preferences.

o) To verify your bank account details, analyze your transaction history to assess creditworthiness and verify income (such as through third-party  instant bank verification), disburse loan funds directly to your account, and process pre-authorized debit payments for loan repayments.

We collect, use and disclose Information only for the purposes described in this Policy or for other purposes that are disclosed to you at or before the time the information is collected and as permitted or required by applicable law. We collect, use and disclose Personal Information as required to comply with applicable consumer protection, payday lending, instalment lending, reporting and regulatory requirements in the provinces in which we operate.
 

FACIAL SCAN & DATA POLICY

6.1 FACE DATA WE COLLECT & PURPOSE
To complete your identity verification, you are asked to capture a single static photo of your face using your device’s camera. This image is used to verify your identity by comparing it against the photo on your government-issued identification and/or your credit bureau file and to perform a liveness check to confirm that the photo represents a live person present at the time of capture and is not a photograph, video, mask, or other spoofing attempt.

6.2 CONSENT TO FACIAL VERIFICATION
By proceeding with the facial verification process, you expressly consent to the collection, use, and processing of your facial image for identity verification, liveness detection, fraud prevention, know-your-customer (KYC) verification, and compliance with applicable legal and regulatory requirements. If you choose not to provide such consent, we may be unable to complete identity verification or provide certain products and services. Such information will not be used for behavioural profiling, targeted advertising, marketing purposes, or the development of unrelated products or services.

6.3 FACE DATA SHARING AND STORAGE
​We will not share your selfie image with any third parties for marketing or commercial purposes. The selfie image is stored in our systems for identity verification, fraud prevention, compliance purposes, record-keeping, and/or the performance of our contractual obligations to you, except where disclosure is required or permitted by applicable law.
 

​INFORMATION AUTOMATICALLY COLLECTED
We automatically collect certain information when you use, visit or navigate our Services. This information does not reveal your specific identity, but may include device and usage information, such as your IP address, browser and device characteristics, referring URLs, location and other technical information.

This kind of information is needed to maintain the security and operation of our Services and for analytics and reporting purposes.

The data collected includes:
a) Log and usage data. Depending on how you interact with us, this log data may include IP address, device information, browser type, information about your activity (such as date/time stamps associated with usage, pages and files viewed, searches and other actions such as what features you use)
b) Device data. We collect information about your computer, phone, tablet, or other device you use to access our services. Depending on the device used, the data collected may include IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, operating system and system configuration information.
c) Location data. We collect information such as information about your device's location, but the information precision depends on the type and settings of the device used.
 

LIMITING COLLECTION
The collection of Personal Information is limited to that which is related to the identified purposes. Personal Information will be collected by fair and lawful means. Most Personal Information will be collected directly from customers. Lenditt may collect Personal Information from sources such as public databases, affiliate programs, data providers, credit bureaus, employers, personal references, or other third parties that represent they have the right to disclose such Personal Information.
 

LIMITING USE, DISCLOSURE AND RETENTION
We may disclose Personal Information to third-party service providers engaged by us to perform identity verification, document authentication, fraud prevention, know-your-customer (KYC) verification, risk assessment, payment processing, customer support, information technology services, and related operational functions. Such service providers are contractually required to protect Personal Information and may only use such information for the purposes for which it was disclosed.

Lenditt will only use or disclose your Personal Information for the reason(s) it was collected, except with the consent of the customer or as required by law. We obtain your express consent before collecting, using, or disclosing sensitive personal information (such as financial history, credit reports, bank statements, and biometric data). In very limited circumstances involving non-sensitive information, we may rely on implied consent or opt-out mechanisms where permitted by applicable privacy laws. By submitting Personal Information to us or our service providers and agents, you consent to the collection, use, processing and disclosure of such Personal Information as described in this Policy or otherwise at the time of collection. Should you provide us and our service providers and agents with Personal Information of another individual, it is your responsibility to obtain consent from such person to enable us to collect, use and disclose such information for the purposes set forth in this Policy. Subject to legal or contractual requirements and reasonable notice, you may withdraw your consent at any time by contacting our Privacy Officer at the contact information set out at the end of this Policy. If you withdraw your consent, we may be limited or unable to provide you with certain services or information.

Notwithstanding the above, your consent to ongoing credit bureau reporting in respect of an active loan cannot be withdrawn while the loan remains outstanding, as such reporting forms part of your Loan Agreement and is necessary for the performance of that agreement.

In certain circumstances, as permitted or required by law, we may collect, use or disclose Personal Information without the knowledge or consent of the individual. These circumstances include but are not limited to: Personal Information that is publicly available as defined by regulation; where collection is clearly in the interests of the individual and consent cannot be obtained in a timely way; where disclosure is made for the purposes of collecting a debt owed to us; or to comply with a subpoena, warrant or court order.

Also, to the abovementioned, Personal Information may be shared between our affiliates or subsidiaries (including those that may be located outside Canada) for internal audit, billing, management or administrative purposes including actions related to legal actions. For the purposes mentioned above, we may transfer your Personal Information to service providers, including affiliates or other third-party organizations to perform actions, such as data processing, marketing, customer service, security, collections, financial and taxation services. Should your Personal Information be transferred, we use contractual or other means that ensure that a comparable level of protection is provided. Where Personal Information is transferred to, or accessed by, service providers located outside Canada, (Currently in India), including affiliated technology support entities, such transfers or access are made solely in connection with providing technical support, system maintenance, software development, cybersecurity monitoring, or other IT infrastructure and operational services on our behalf. Personal Information is not transferred for storage outside Canada it remains hosted on servers located within Canada. Where our service providers or affiliated entities outside Canada require incidental access to Canadian systems for the purposes described above, such access is subject to written contractual safeguards that require a standard of protection comparable to that provided under Canadian privacy law. For residents of Alberta: To obtain further information regarding our policies and practices with respect to service providers outside of Canada, or to ask questions about the collection, use, disclosure, or storage of personal information by such service providers, please contact our Privacy Officer (whose title and contact details are set out in Section 18 below).

We may disclose Personal Information to collection agencies, legal counsel, loan servicers, payment processors, assignees, purchasers of loan portfolios, and other professional advisors where reasonably necessary for the administration, servicing, enforcement, collection, sale, assignment, securitization, or management of loans and related obligations. Such third parties are required to protect Personal Information in accordance with applicable privacy laws, may process Personal Information in accordance with their own privacy policies.

We may disclose your Personal Information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law.
 

HOW LONG DO WE KEEP YOUR INFORMATION AND HOW DO WE DISPOSE OF IT?
The length of time we retain your Information varies depending on the services you have requested and your relationship with us. We keep Information for so long as it is reasonably required by us or legally necessary for us to retain such information. Your information is confidentially destroyed, deleted, erased or converted to an anonymous form when reasonably appropriate.
 

HOW DO YOU GAIN ACCESS AND VERIFY YOUR PERSONAL INFORMATION?
We will provide you access to the Personal Information we have about you. If you require information, simply contact our Privacy Officer. We will respond to your request within 30 days of receipt (extendable to 60 days with written notice), as permitted under PIPEDA and applicable provincial privacy legislation.

Having accurate Information about you enables us to give you the best possible service. You are responsible for ensuring that the Personal Information you provide to us is accurate, complete, and up to date, and for notifying us promptly of any material changes. If you find any errors in our information about you, let us know and we will make the corrections promptly. For information that remains in dispute, we will note your objection in our records.
 

HOW IS YOUR PRIVACY TREATED BY OUR PLATFORM?
In general, you may visit Lenditt through the Platform without telling us who you are or revealing any Information about yourself.

We may, however, collect non-personally identifiable information from you when you visit our website or download or use our mobile app. For our website, this includes your domain name, the IP address of the web page from which you enter the site, the pages you visit on our site and the amount of time you spend there. For our mobile app, this includes device ID and model number. This information is used to improve and customize the content and layout of our website or app.

From time to time, we may utilize cookies or scripts on our website. You may disable these features, but by doing so, you may not be able to utilize the services we provide on our website.

We collect the email addresses of those who communicate with us by email and information volunteered by our visitors. The information we collect is used to improve our content and contact these visitors, if they have requested to be contacted.

From time to time, we may advertise our services on another company's website. If you access one of these ads, we may track the response rate and the website activity associated with each ad. The response rate data is used to help us plan future online advertising campaigns. From time to time, we may provide links (from our website or mobile app) to other websites that may be of interest to our visitors. However, we cannot and do not guarantee that their privacy policies are adequate or equivalent to ours. In order to protect your privacy, we recommend that you read each webpage's privacy policy carefully before making the decision to share information and only share information with companies that you trust will protect your privacy.
 

COOKIES
Lenditt’s Platform uses cookies and similar technologies to help personalize your online experience, improve website functionality, and analyze site traffic. For detailed information on what cookies are, the specific categories of cookies we use, and how you can manage or disable your cookie preferences, please read our full Cookie Policy.
 

SECURITY OF YOUR PERSONAL INFORMATION
Lenditt protects your Personal Information through: (a) Technical safeguards encryption of personal data in transit and at rest, firewall protection, multi-factor authentication for system access, role-based access controls, and regular vulnerability assessments; (b) Physical safeguards Canadian-based servers in access-controlled, monitored data centre facilities; (c) Organisational safeguards mandatory privacy and security training for all staff with access to personal information, written privacy policies and procedures, and contractual data protection obligations imposed on all third-party service providers. Despite these measures, no method of internet transmission or electronic storage is 100% secure, and we cannot guarantee absolute security.

Your safety and privacy are a priority for us. While we use various tools and technologies to protect your information, security is a shared responsibility, and we encourage you to follow the precautions below.

Some of the steps you can take to help protect your personal information include:
a) Use strong, unique passwords for your accounts and devices and keep them confidential.
b) Verify the sender before clicking links, opening attachments, or responding to emails, text messages, or other electronic communications.
c) Do not disclose your personal information, account details, passwords, or login credentials in response to unsolicited or suspicious  communications.
d) Ensure your devices are protected with up-to-date security software and secured with a strong passcode or password.
e) Regularly review and delete personal information stored on your devices where appropriate.
f) If you are unsure whether a communication comes from Lenditt or if you notice suspicious activity, including fraudulent emails purporting to come  from Lenditt, please contact us immediately at +12894992293 or by email at support@lenditt.ca.

Also, consider contacting your local law enforcement.

How we will notify you: If you are affected by a reportable breach, we will contact you directly by email, phone, or mail using the contact information we hold for you, as soon as feasible after we determine the breach has occurred. The notification will describe the breach, the information affected, the steps we have taken to mitigate harm, and the steps you can take to protect yourself.

Record-keeping: PIPEDA requires us to keep a record of every breach of security safeguards whether or not it meets the RROSH reporting threshold for a minimum of 24 months from the date we became aware of the breach. These records must contain sufficient detail to enable the OPC to verify compliance.

Our obligations: Under PIPEDA and other applicable privacy laws, we may be required to report certain privacy breaches to the relevant privacy regulator and notify affected individuals where a breach creates a risk of harm or otherwise meets the applicable legal reporting threshold. Significant harm may include financial loss, identity theft, damage to reputation, loss of employment or business opportunities, and negative effects on a credit record.

What constitutes a breach: A privacy breach is the loss of, unauthorized access to, or unauthorized disclosure of Personal Information resulting from a failure of our security safeguards.
 

YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM
Under applicable Canadian private-sector privacy legislation, you have the following explicit legal rights regarding your personal information:
a) Right of Access: You have the right to request access to the Personal Information we hold about you, and to receive information about how it has  been used and disclosed. We will respond to access requests within 30 days of receipt (extendable to 60 days with written notice). We may charge a  reasonable fee for large or complex requests and will advise you in advance.

b) Right to Correction: If you believe any Personal Information we hold is inaccurate or incomplete, you have the right to request a correction. Where we cannot make the correction, we will permanently note your objection in your file.

c) Right to Withdraw Consent: You may withdraw your consent to the collection, use, or disclosure of your Personal Information at any time, subject  to legal or contractual restrictions (such as an active, outstanding loan agreement). Withdrawal of consent may limit our ability to provide  continued loan services to you.

To exercise any of your rights, please submit a written request to our Privacy Officer at the contact details in Section 18 below. We will provide a substantive response within thirty (30) days of receipt (extendable to 60 days with written notice), as permitted under PIPEDA and applicable provincial privacy legislation.

d) Right to File a Complaint: If you are not satisfied with our response or data handling practices, you have the legal right to escalate your  complaint to the relevant federal or provincial privacy commissioner or regulatory authority responsible for privacy compliance in your jurisdiction.
 

PROVINCIAL REQUIREMENTS
This Policy is intended to comply with applicable Canadian privacy legislation. Certain provinces or territories may provide additional privacy rights or impose specific requirements regarding the collection, use, disclosure, retention, access, correction, or protection of Personal Information. Where such laws apply, Lenditt will comply with those requirements and any additional rights or protections afforded to individuals under the applicable laws of their jurisdiction.
 

CHANGES TO THE PRIVACY POLICY AGREEMENT

Lenditt reserves the right to update and/or change the terms of this Policy from time to time. Any changes will be posted on our Platform and the "Last Updated" date at the top of this Policy will be revised accordingly. Where required by applicable law, or where we determine that the changes are material, we may also notify you by email, through the Platform, mobile application notifications, or other appropriate communication channels.Thus, it is the visitors' and users' responsibility to keep up to date. The last revised date will be posted on the top of this page. For material changes to how we handle your Personal Information, we will notify you in advance (e.g., via email or a prominent notice on our Platform) and obtain your consent where required by law. For all other changes, your continued use of our Platform constitutes acceptance of the updated terms. If you do not agree with the terms of this Privacy Agreement, please do not continue using our Sites.
 

CONTACT INFORMATION
Lenditt welcomes your questions or comments regarding this Privacy Policy. If you believe that Lenditt has not adhered to this Policy, please contact Lenditt at:

Privacy Officer
Lenditt Technologies Inc.
5955, JEANNE D'ARC BLVD S ORLEANS ON K1C 2N1
Phone:  +12894992293
Email:   support@lenditt.ca