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Privacy Policy

At LendingHub.ca, we are committed to protecting the privacy of our customers and therefore do not sell or rent our customers’ Personal Information to any third party. For the purposes of this Privacy Policy, we do not share your Personal Information with any third parties for their direct marketing purposes without first providing you the opportunity to opt-in or opt-out of such sharing. You may request information about how we manage your Personal Information consistent with this Privacy Policy by contacting us at [email protected] Attn: Privacy Officer.

The LendingHub.ca web site (the “Site“) is made available by LendingHub.ca Inc., the legal name of LendingHub.ca. We refer to LendingHub/ca Inc. collectively as “LendingHub.ca”, “we”, “us” or “our”.

This page sets forth our policies regarding the collection, use and disclosure of Personal Information we collect from or are able to obtain about the Site’s users. We refer to these policies as our “Privacy Policy.” In addition to the lower case words “we” “us” and “our” defined above, you will notice that we capitalize certain words in this Privacy Policy even though the rules of grammar do not require that they be capitalized. We do this because these words have specific meanings in this Privacy Policy. These specific meanings are found where the capitalized words are placed in bold text and inside quotation marks.

We hope this Privacy Policy will answer your questions regarding how we treat Personal Information gathered from our Site. If you have questions or concerns regarding this Privacy Policy, other than requests related to our managing of your Personal Information, please feel free to contact us at [email protected]; for more information about your choices regarding your Personal Information, please refer to the section titled “How to Unsubscribe,” below. Otherwise please direct all inquiries regarding this Privacy Policy to [email protected] Attn: Privacy Officer.

This Privacy Policy does not apply to Personal Information that you may provide to us or that we may obtain through means other than the Site, such as by phone or postal mail, but please note that Personal Information obtained through such means will be treated in accordance with the first paragraph above and our use of such Personal Information will be consistent with this Privacy Policy. By accessing and using the Site you are agreeing to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you are not authorized to use the Site. Furthermore, by providing us with Personal Information on this Site, you fully understand and unambiguously consent to the collection, use, retention and disclosure of such Personal Information in Canada and/or the United States in accordance with this Privacy Policy.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice to us. If you withdraw your consent, we will inform you of the implications of such withdrawal. To withdraw your consent, simply contact our Privacy Officer at the contact information below and advise us of what Personal Information you no longer wish us to use. All communications with respect to any withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

As we update and diversify our products and services, this Privacy Policy may change. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Please check this page for updates periodically. If we make any material changes to this Privacy Policy, we will notify you here. Unless the law otherwise requires, we do not provide individual notice of changes to this Privacy Policy and your use of the Site following any posted changes will indicate your acceptance of such changes.

This Privacy Policy became effective on December 6, 2018.

What Information Do We Actively Collect and Inactively Gather?

Personal Information

We may periodically conduct surveys of visitors to our Site for internal research purposes that may include marketing. This helps us better understand what our customers would like to see from us. If you respond to such surveys, we may ask you for some Personal Information and/or may contact you for more information, but only if you have given us permission to do so.

Site Usage Information

Site Usage Information We (including through our third party service providers) may inactively collect from you information that is not in the same category as Personal Information. For example, we might track information about the date and time you access the Site, the type of web browser you used, and the web site from which you connect to our Site. We collect and use this and other non-Personal Information (such as demographic data) to analyze and develop our business strategy and to determine how you found out about us, your interests regarding our services and how to further improve our Site. We, or a third party, may also collect information from your activities on the Site as well as other sites for the purpose of providing advertisements and other content that is customized to your interests and preferences. This means that our ads may appear on participating web sites based upon your browsing activity. To accomplish all this, and also to allow us to offer our customers streamlined ordering and other useful features, we, as do many web sites, use and allow our third party advertising companies to use the technologies listed below and other similar technologies (the “

Tracking Technologies

“):

Cookies and Clear GIFs

– Cookies are pieces of information that are stored by your browser on your computer’s hard drive. Cookies make web surfing easier for you by saving your customer identification information (i.e., username, password, shopping cart information, etc.) while you’re at a site. Cookies also track where you travel on a site and what you look at and purchase. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a web page or message.

IP Address Tracking and Clickstream Data

– In addition to cookies and clear GIFs, our servers automatically collect data about your server’s Internet address when you visit our Site. This information, known as an Internet Protocol address, or “IP Address”, is a number that is automatically assigned to your computer by your Internet service provider whenever you are on the Internet. When you view pages from our Site, our servers may record or “log” your IP Address and sometimes your domain name. Our server also may record the page that linked you to us and related information including any ads you may have clicked on. Such information is known as “Clickstream Data“.

Email Interconnectivity

– If you receive email from us, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

In some cases, we may link the non-Personal information collected through the Tracking Technologies with certain of your Personal Information. WE WANT TO BE SURE THAT YOU UNDERSTAND THAT ACCEPTING TRACKING TECHNOLOGIES ONTO YOUR COMPUTER IN NO WAY GIVES US ACCESS TO YOUR COMPUTER. YOU MAY SET YOUR WEB BROWSER SOFTWARE TO REJECT TRACKING TECHNOLOGIES, BUT, IF YOU DO SO, CERTAIN FUNCTIONALITY OF THE SITE MAY BE AFFECTED. Third parties (including, but not limited to, software vendors, advertisers and fulfillment companies) may also use Tracking Technologies by or through the Site. WE HAVE NO CONTROL OVER WHAT INFORMATION SUCH THIRD PARTIES TRACK OR COLLECT, AND HAVE NO RESPONSIBILITY OR LIABILITY FOR ANY TRACKING, DATA COLLECTION OR OTHER ACTIVITIES OF SUCH THIRD PARTIES

Mobile Devices

You may be visiting the Site from your mobile device. Certain mobile service providers uniquely identify mobile devices and we or our third-party service providers may receive such information if you access the Site through mobile devices. Some features of the Site may allow for the collection of mobile phone numbers and we may associate that phone number to mobile device identification information. Furthermore, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service. Depending on the provider, we or our third-party service providers may receive this information.

You understand that your wireless carrier’s standard rates may apply when you visit the Site from a mobile device. You represent that you are the owner or authorized user of the wireless device used to visit the Site, and that you are authorized to approve the applicable charges.

Use of Information in Sweepstakes and Contests

Occasionally, we may run a promotion such as a sweepstakes or a contest (a “Promotion”), and you will be given the opportunity to enter by filling out an entry form. Your entry information may be shared with third parties for the limited purposes of administering the sweepstakes and selecting a winner(s) and may be used to notify you in connection with the sweepstakes or contest and to verify your identity. When you enter such a Promotion, you will have the opportunity to consent to receive future communications from us. Since we value your privacy, you will always have the opportunity to stop such communications as detailed below. In addition, some Promotions may have one or more co-sponsors, and you may also be asked upon entry to consent to receive future communications from such co-sponsors. In the event your consent is indicated, the information from your entry will be shared with the co-sponsors. In those situations, the third parties will have the right to use your information for their own purposes, in accordance with their own policies, and we are not responsible for how co-sponsors may use your information. In all events, we will make it clear to you in the entry, order or registration form, before you submit it, whether you are consenting to receive information from any party, and you will be given the opportunity to confirm or withdraw such consent prior to submitting your entry, order or registration.

In any case, where you elect to have us share your information with third parties, such as in the Promotions discussed above, those elections to have your information shared will supersede anything to the contrary in this Privacy Policy.

How to Unsubscribe

We will only send e-mail for customer service purposes and to those visitors who have indicated that they wish to receive other types of e-mail from us and our subsidiaries.

If at any time you wish to stop receiving e-mail from us, we include an unsubscribe mechanism in all of our e-mails and you can always remove your name from our mailing list by sending an e-mail to [email protected] stating that you wish to unsubscribe and indicating in the subject line of the e-mail “UNSUBSCRIBE E-MAIL”. Although we will promptly remove your name from our e-mail list upon receiving your request, it is possible that you may still receive e-mails from us that had been initiated prior to your name being removed from our list.

THE UNSUBSCRIBE RIGHTS AND PROCEDURES DESCRIBED IN THIS SECTION ARE THE DEFAULT RULES AND PROCEDURES WE USE IN OPERATING THE SITE AND ARE THE STANDARD BY WHICH WE ADHERE TO OUR PRIVACY POLICY.

Please keep in mind that, if you choose not to receive marketing communications, you will continue to receive transactional or account communications related to services or products that you have requested on the Site (e.g. confirmation e-mails, billing reminders).

Release of Information to Protect Our Site and Others

We may release Personal Information as permitted or required by applicable law or regulatory requirements, to comply with valid legal processes such as search warrants, subpoenas or court orders, to seek advice from our legal counsel, as part of our regular reporting activity to related companies, to protect the rights, property or safety of LendingHub.ca, our users or others, to address emergency situations or where necessary to protect the safety of a person or group, to enforce or apply the terms of any of our user agreements, or where the Personal Information is publicly available.

Intended Users; Use by Children under 13

The Site is not purposefully directed at children under the age of 13 and all services available on the Site are intended to be viewed by adults. We do not collect or maintain Personal Information, via the Site or otherwise, from those we actually know are children under 13 years of age. If you notify us that information has been provided by a child under the age of 13, upon verification, we will promptly delete such information.

Inquiries or Concerns

If you have any questions about this Privacy Policy or concerns about how we manage your Personal Information, please contact our Privacy Officer. If you are dissatisfied with our response, you may be entitled to make a written submission to the Office of the Privacy Commissioner of Canada (OPC).

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Privacy Officer

LendingHub.ca Inc.

81 Zenway Blvd., Unit 25

Vaughan, ON Canada, L4H 0S5

1. 1-416-607-7000

2. [email protected]

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy does not create or confer upon any individual any rights, or impose upon LendingHub.ca any rights or obligations in addition to any rights or obligations imposed by Canada’s applicable federal and provincial privacy laws. Should there be any inconsistency between this Privacy Policy and the applicable federal and provincial privacy laws, this Privacy Policy will be interpreted so as to give effect to, and comply with, those privacy laws which are applicable