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Privacy Policy - Canada

Last updated: August 4, 2023

You trust Multipli Inc (“Multipli”, “we”, “us” or “our”) for your business financing solutions. To offer you these business financing solutions, we may need to collect, use and disclose certain personal information about you.

It is our goal to develop and maintain your trust with respect to that Personal Information by being transparent in terms of:

  • What Personal Information we may collect,
  • How we may use that Personal Information,
  • To whom we may share or disclose that Personal Information in connection with our business activities, as well as why we need to make these disclosures, and
  • What safeguards we implement to protect the security of that Personal Information.

This privacy policy is our way of providing that transparency to you. 

For purposes of this privacy policy “Personal Information” means any information relating to a specific individual person or which can be used to identify a specific individual. This may include things such as personal identification information (e.g., name, physical address, IP address, social insurance number, driver’s license number or other personal identification numbers, email address and mobile phone number), internet or similar network activity, information on your credit history and past transactions, financial account information and geolocation data.  Personal Information does not include, however, information that does not identify a specific individual person such as information that has been permanently and irreversibly been aggregated or anonymized such that it no longer identifies or capable of identifying a specific individual.

This privacy policy applies to all personal information within our possession or under our control. For clarity, this privacy policy does not apply to information other than Personal Information.

Changes to this privacy policy

We reserve the right to modify or supplement this privacy policy at any time.  If we make a change to this privacy policy, we will post such changes on our websites. It is your sole responsibility to verify if changes have been made to this privacy policy.  We will provide to you such revised privacy policy upon written request to our Privacy Officer. Upon written request, our Privacy Officer can also provide details of the changes made to the last version of this privacy policy. 

Personal Information that we Collect, Use or Share

In connection with our business activities, we may collect, use, or share Personal Information about you.

Collection of Personal Information

We collect Personal Information for the Internal Uses and the Disclosure Purposes described in the sections below titled “Use of Personal Information” and “Disclosure of Personal Information”. We may collect your Personal Information from the following sources (“Sources”).

  • You: You may supply us with Personal Information directly when you inquire about, or seek your, business financing from us, including in connection with your application for business financing, the preparation and processing of your financing agreements and the ongoing administration of your financing transaction or when subscribing to e-newsletters and business resources including but not limited to white papers, case studies and e-booklets. You may also supply us with Personal Information directly when you inquire about or apply for employment with Multipli.  We may monitor and record communications with you (such as telephone conversations and emails).
  • Credit Reporting Agencies and Other Data and Analytics Providers: We use credit reporting agencies and other providers of business and consumer data and analytics to supply us with information that we use for a number of the business and commercial purposes described in “Use of Personal Information” below, including the determination of eligibility for business financing, the administration and servicing of the financing and for marketing purposes. We may receive Personal Information from those credit reporting agencies and other business and consumer data and analytics providers.
  • Unaffiliated Service Providers: We use unaffiliated service providers to assist us in performing a number of different functions related to the business and commercial purposes described in “Use of Personal Information” below. In the course of our dealings with these service providers, we may receive Personal Information on or about you that they have collected, either directly or indirectly.
  • Vendors and Equipment Suppliers: The business supplying the assets or services which you are interested in financing or have financed may provide us with your Personal Information.
  • Unaffiliated Referral and Sales Relationships: You may have supplied Personal Information to brokers or other financing sources in connection with a business financing you are seeking or have received. Those brokers or other financing sources may provide us with your Personal Information that they have collected to enable us to determine your eligibility for financing from us and the terms and conditions thereof or whether we wish to purchase your financing transaction from them.
  • Websites, Online Tools and Applications: When you visit our websites, use our mobile applications or visit or post information on our social media pages, our systems may automatically collect Personal Information including your IP address, domain name, ISP, general geographic location, the link that you clicked to get the websites and your activity when navigating the websites. This may also include internet and browsing history website analytics and application or ad clicks.
  • Our Affiliates: Our affiliates may have collected Personal Information in one or more of the manners described above. We may collect that Personal Information from those affiliates.

We may ask you to provide sensitive Personal Information as part of your request to receive business financing from us. If we request such information, we will explain why we are requesting it and how we intend to use it. Sensitive Personal Information includes:

  • information relating to your physical or mental health;
  • your genetic data;
  • your biometric data;
  • your social insurance number;
  • your credit card number, CVV number and expiration date; and
  • information relating to your criminal record (if any).

We will only collect your sensitive Personal Information with your explicit consent, or where We are required to do so in order to process your request to receive business financing from us.

Our websites may contain hyperlinks to websites and other online platforms or portals owned and operated by third parties and over which we have no control. By accessing such hyperlinks you acknowledge and agree that we are not responsible for the collection and use of your Personal Information by such third parties through such third party websites and other online platforms or portals. You are strongly encouraged to review the privacy policies of each website or other online platform or portal that you visit.

Use of Personal Information

It is our goal to provide our customers and potential customers with customized financing options for their specific business needs, fast credit decisioning and a simplified documentation process. After the initial transaction, our goal is to provide customer-centric service and offer new or enhanced finance products. We use Personal Information a number of different business and commercial purposes in order to achieve this goal, including:

  • To provide financing to your business. When you inquire about, or seek your, business financing from us, we use Personal Information to provide you with information, products and services that you request from us. In addition, we use Personal Information to determine your business’ eligibility for such financing and the terms and conditions thereof. Without use of this Personal Information, we would not be able to offer your business financing.
  • To perform services for you or in connection with your transaction and to improve the quality of those services. If we have approved your business financing, we use Personal Information to complete the financing transaction, including preparation of the financing documents, due diligence matters to prevent fraud, confirmation of required insurance, and payment information. In addition, we use Personal Information to provide on-going customer service, on our behalf and on behalf of others, including billing and collection, matters relating to taxes and insurance, location of the property financed and, if necessary, enforcement of the contract. Without use of this Personal Information, we would not be able to enter into financing transactions with your business, perform these services for your business, improve the level of service we provide to your business or protect ourselves against fraudulent activity.
  • For fraud-prevention purposes.
  • For marketing purposes. We use Personal Information to develop, promote and provide a comprehensive line of finance products to customers and potential customers, to extend personalized and customized messaging, quality content and finance offers tailored to the specific needs of businesses, as well as to enhance our product and service offering to meet the changing needs of our customers, potential customers and the industries which they and we operate. Without use of your Personal Information, we would not be able to provide you with these tools.
  • For training purposes.  We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of training.
  • To improve online and system functionality. We strive to provide visitors and users of our websites, mobile applications, and social media sites with a secure and informative experience including content and page components that are well-optimized for the user experience and search engine indexing with the ability to capture leads into a marketing database that includes activity data, and shared with sales when determined to be qualified as sales-ready user experience. As such, we are constantly evaluating ways to improve that experience, and may use your Personal Information to improve the functionality and utility of our websites, mobile applications and social media sites. In that regard, we may use Personal Information for purposes of internal research for technological development and demonstration, to assist us in debugging to maintain and identify and repair errors in our systems, and to audit current interactions with you and concurrent transactions, including counting ad impressions to unique visitors, verifying position and quality of ad impressions and auditing compliance with this specification and other standards. We also use Personal Information to audit and improve the security of our websites and mobile applications, including detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity and prosecuting those responsible for that activity.
  • To comply with Applicable Laws. We are subject to provincial and federal rules, laws and regulations (“Applicable Laws”). We may use Personal Information to ensure our compliance with these Applicable Laws.
  • Other Purposes.  For other purposes pursuant to your direction, instruction or consent, whether express or implied, or for other purposes permitted by Applicable Laws.

Disclosure of Personal Information

We may disclose Personal Information to others for many of the same reasons that we use the Personal Information for our own internal purposes. Below is a description of the third parties we may disclose Personal Information and the reasons why we do so.

  • Our Unaffiliated Service Providers: We use unaffiliated service providers to assist us in performing a number of different functions relating to the business and commercial purposes described in “Use of Personal Information” above. In the course of our dealings with these service providers, we may disclose your Personal Information that we have collected.
  • Vendors and Equipment Suppliers: In connection with processing your request for business financing, processing that transaction and administering that transaction following closing, we may disclose your Personal Information to the business supplying the assets which you are financing or leasing in order to confirm the assets being financed, prevent fraud, complete the document package for the financing and provide customer service and other information to you or the vendor or equipment supplier.
  • Our Affiliates: We use affiliated companies to enhance our ability to provide financing to businesses, as well as to hold, service and administer those financings once in place. We may disclose your Personal Information to those affiliates in connection with those and similar activities that they may perform related to your financing.
  • Governmental Authorities: We are subject to Applicable Laws, and pursuant to those Applicable Laws, we may be requested or required to provide Personal Information to state or federal governmental agencies or by a court or other judicial or legislative body (“Governmental Authorities”). We may also disclose personal information to courts and other judicial bodies as necessary to enforce our rights and remedies under our financing contracts
  • Purchasers or Prospective Purchasers. A third party assuming or exploring the possibility of assuming control of us if the Personal Information is part of a merger, acquisition, bankruptcy or other transaction.
  • Third-party funding and financing sources. For example, we actively manage our portfolio of business financings and, like most companies who provide business financing, we use a number of different tools to do so. We may disclose Personal Information to our third-party referral and purchaser relationships, as well as parties who provide us with financing, their respective service providers and other participants in those transactions.
  • Other Third Parties. To other third parties pursuant to your direction, instruction or consent, whether express or implied, or where otherwise permitted by Applicable Laws.

Pixel Tags, Cookies, Tracking and Third-Party Advertisers

Multipli using its own tools or via its use of a third-party's tools, may display advertisements for Multipli and its products and services that may be of interest to you, based on information relating to your access to and use of our websites, our mobile applications and other online services. To do so, Multipli or these third-party advertising companies may place or recognize a unique cookie on your browser (this may include through the use of pixel tags). Please visit www.networkadvertising.org/ if you would like more information about this practice and to learn about your choices in connection with it. We may not respond to browser do-not-track signals. We may use analytics providers that use cookies, pixel tags and other, similar technologies to collect information about your use of our websites, mobile applications and your use of other websites or online services. To be clear, we do not receive any monetary or other consideration from these third-party advertising companies or analytics providers.

How we Protect Your Personal Information

We maintain safeguards to protect your Personal Information. We use EVSSL to secure information and firewalls in addition to keeping applications and critical equipment patched with the latest security updates. Personal Information is restricted to employees who need access to that Personal Information to perform their jobs. All employees are instructed to respect customer privacy and receive training on Multipli’s privacy and security policies, including updated training on a periodic basis (not less than annually) which includes up-to-date information and instruction on fraud techniques being used by third parties, including “phishing”, “spearfishing”, “spoofing” and social engineering.

Notwithstanding these safeguards, when Personal Information is being communicated by you to us (including via email and other electronic communications) that Personal Information could be accessed or intercepted by unauthorized third parties. By transmitting Personal Information to us, you assume this risk and agree that neither Multipli Inc, its subsidiaries or affiliates, nor any of their respective officers, directors, employees or contractors is liable for any such unauthorized third-party access or interception.

Where your Personal Information is Stored

Personal Information is kept at secure facilities and on secure servers owned and operated by Multipli and/or third-party service providers retained by Multipli that are located in Canada. Where required by law or our disaster recovery/business continuity policies, older records may be stored in a secure, offsite location.  We may need to transfer your Personal Information to Australia, the United States, and/or the United Kingdom for the purpose of credit processing and contract management.

Personal information about other individuals

If you give Us information on behalf of someone else (including any fellow colleagues or partners), you confirm that the other person has appointed you to act on his or her behalf and has agreed that you can:

  • give consent on his or her behalf to the processing of his or her Personal Information in accordance with this privacy policy;
  • receive on his or her behalf any notices relating his or her Personal Information that we may be required to provide pursuant to Applicable Laws;
  • give consent to the transfer of his or her Personal Information abroad; and
  • give consent to the processing of his or her sensitive Personal Information.

Your Rights in terms of your Personal Information under our control

You have the following rights with respect to your Personal Information under Applicable Laws:

  • ‍the right of access to Personal Information relating to you;
  • the right to correct any mistakes in your Personal Information;
  • the right to ask us to stop contacting you with direct marketing;
  • the right to restrict or prevent your Personal Information being processed;
  • the right to have your Personal Information ported to another service provider (e.g. if you decide to contract with a different service provider);
  • the right to erasure; and
  • the right to complain to the Privacy Commissioner of Canada or, if you reside in a province which has adopted private sector privacy legislation, the privacy commissioner of the province in which you reside, if you believe we have not handled your Personal Information in accordance with Applicable Laws.

These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your Personal Information, please contact us (see the section below titled “How to contact us”). We will respond to any request within a month of receiving such request, unless the request is particularly complex, in which case we will respond within three (3) months.

Right to access to Personal Information relating to you

You may ask to see what Personal Information we hold about you and be provided with:

  • a copy;
  • details of the purpose for which it is being or is to be processed;
  • details of the recipients or classes of recipients to whom it is or may be disclosed;
  • the period for which it is held (or the criteria we use to determine how long it is held); and
  • any information available about the source of that Personal Information.

Requests for your Personal Information must be made to us in writing (see the section below titled “How to contact us”), and a copy will be retained on your personnel file. Prior to processing your request, we may require that you provide us with such information or documentation as we may reasonably require for verification purposes or to otherwise validate your identity.

To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.

If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person if possible. If we cannot obtain consent, we may need to withhold that information or edit the information to remove the identity of that person if possible.

There are certain types of information which we are not obliged to disclose to you under Applicable Laws, which include Personal Information which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We reserve the right not to provide requested information where the foregoing is permitted by Applicable Laws.

Third Party Processors

Our carefully selected partners and service providers may process Personal Information about you on our behalf as described below:

  • Digital Marketing Service Providers.  We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  These providers may be located in Canada, the United States, United Kingdom, or Australia.  Any such service provider’s access, receipt, processing, use, safeguarding and retention of your personal information will be subject to the confidentiality and privacy requirements set forth in our agreement with such third party and will otherwise conform with Applicable Laws.

Right to correct any mistakes in your information

You can require us to correct any mistakes in your Personal Information which we hold free of charge. If you would like to do this, please:

  • email, call or write to us (see the section below titled “How to contact us”)
  • let us have enough information to identify you, verify your identity and otherwise validate your request; and
  • let us know the information that is incorrect and what it should be replaced with (we may require that you provide us with documents that validate the accuracy, completeness and currency of the information that you provide).

Right to ask us to stop contacting you with direct marketing

You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:

  • email, call or write to us (see the section below titled “How to contact us”); and
  • let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).

Right to prevent processing of Personal Information

You may request that we stop processing your Personal Information temporarily if:

  • you do not think that such Personal Information is accurate (but we will start processing again once we have checked and confirmed that it is accurate or, if it is not accurate, we once we have made necessary corrections);
  • the processing is unlawful;

Right to erasure

You can ask us to erase your Personal Information where:

  • you do not believe that we need such Personal Information in order to process it for the purposes set out in this privacy policy;
  • if you had given us consent to process your Personal Information, you withdraw that consent and we cannot otherwise legally process your Personal Information;
  • you object to our processing and we do not have any legitimate interests in continuing continue to process your Personal Information; or
  • your Personal Information has been processed unlawfully or has not been erased when it should have been.

There may be exemptions which mean we may retain and continue to process your Personal Information, including:

  • we need the information to establish, exercise or defend actual or potential legal claims;
  • we are required to do so pursuant to Applicable Laws; or
  • we are permitted to do so pursuant to Applicable Laws.

Complaints to a Privacy Commissioner

If you do not think that we have not respected our commitments under this privacy policy or have otherwise not complied with our privacy obligations under Applicable Laws, please contact us in the first instance.

If you are not satisfied, you can complain to the privacy commissioner’s office in the province in which you reside or, if such province has not adopted private sector privacy legislation, to the Office of the Privacy Commissioner of Canada.

How to Contact Us

If you have any questions regarding our privacy policies or the ways in which we collect, use, and disclose your Personal Information please do not hesitate to contact us at:

Multipli Inc,
Attn: Privacy Officer
Multipli Canada Limited
1801 Hollis Street

Suite 2100
Halifax
Nova Scotia B3J 3N4