Last Revised: September 12, 2020
LenderFriender has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws
INFORMATION LENDERFRIENDER COLLECTS
a. Personal Information that LenderFriender collects includes, but is not limited to:
Registered User Account profile information, including name, e-mail address, address, date of birth, usernames, passwords, phone numbers, and mailing address;
Billing and payment information, including credit card information and bank account details;
Shipping and return information, including mailing address;
Device information, including the type of mobile device to which You have downloaded LenderFriender’s App;
Any other Personal Information that You may provide when You set-up a Registered User Account with LenderFriender, use the Services, or when you contact LenderFriender with questions and/or inquiries;
Technical support records;
Service requests and inquiries; and
Any information that LenderFriender collects from You that is intended to improve and personalize LenderFriender’s Services.
b. Non-Personal Information
LenderFriender collects non-Personal Information (“NPI”) about Users when they interact with the Services.
Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any of other Users. Such information by itself or together cannot be tracked to a specific individual’s Personal Information.
HOW DOES LENDERFRIENDER USE PERSONAL INFORMATION?
LenderFriender collects Personal Information for the following purposes:
to provide Services to You and other Users;
to facilitate transactions between You and other Users via the Services;
to create and administer Your Registered User Account, including to authenticate You on log-in;
to verify Registered Users;
to establish and maintain responsible commercial relations and to communicate with You in order to provide the Services. This includes, but is not limited to, communications relating to advertising, promotion, and Registered User Account verification;
to respond to any correspondence You may direct to LenderFriender;
to understand LenderFriender’s Users’ needs and preferences;
to enforce LenderFriender’s Terms of Service;
to provide You with Service or administrative messages;
to meet legal and regulatory requirements;
to prevent, detect and mitigate illegal, fraudulent, or counterfeit activities;
to improve the Services; and
for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.
LenderFriender uses NPI in an ongoing effort to better understand and serve the Users of LenderFriender’s Services, to provide the Services and to improve the content and functionality of the Services.
For instance, LenderFriender uses NPI to provide relevant, targeted advertising to Users of the Services, to monitor traffic, and to collect statistical data.
The NPI collected is used to monitor traffic, provide the Services, and conduct internal research on LenderFriender’s Users’ to better understand and serve them, including Users’ size, usage patterns, demographics, interests and behaviors.
The Services may automatically receive and store certain types of NPI about Users’ use of the Services and their devices, including IP address, browser type, web pages viewed, date and time, device unique identifier, mobile network information, mobile stored information and files, and device phone number, as well as how users interact with LenderFriender. In addition, LenderFriender uses different types of technology to collect this information, such as log files, embedded scripts, cookies, web beacons, and pixel tags.
The App also may access metadata and other information associated with other files stored on Your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
You may disable cookies using Your browser’s settings. Please consult Your browser’s help function for information on how to disable cookies. Note that if You disable cookies, certain features of LenderFriender’s Services may not function to their fullest potential.
LenderFriender respects Your privacy and, unless otherwise required by law, LenderFriender will not collect, use or disclose Your Personal Information without Your prior consent. Your consent may be expressed or implied. You may expressly give Your consent in writing, verbally or through any electronic means. In certain circumstances, Your consent may be implied by Your actions. For example, providing LenderFriender Personal Information to register for LenderFriender’s Services is implied consent to use such information to provide You the associated Services.
Where appropriate, LenderFriender will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when LenderFriender wants to use information for a purpose other than those identified above). In obtaining consent, LenderFriender will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by LenderFriender may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, LenderFriender shall take into account the sensitivity of the Personal Information and the reasonable expectations of LenderFriender’s Users. LenderFriender will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to LenderFriender in writing.
Important Information About Platform Permissions
Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without Your consent. And these platforms have different permission systems for obtaining Your consent. The iOS platform will alert You the first time the App wants permission to access certain types of data and will let You consent (or not consent) to that request. Android devices will notify You of the permissions that the App seeks before you first use the App, and Your use of the App constitutes your consent.
LIMITING USE, DISCLOSURE AND RETENTION
When You Lend or Borrow an item via the Services, the Lender or Borrower (as applicable) may receive Your Personal Information for item delivery and return purposes. Lenders and Borrowers are strictly prohibited from using Your information for anything other than such purposes.
In the event Your Personal Information is disclosed to a third party pursuant to a business transaction, LenderFriender will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.
Subject to the foregoing, only LenderFriender’s and LenderFriender’s Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about LenderFriender’s Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of LenderFriender’s Users’ Personal Information.
LenderFriender will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by LenderFriender.
LenderFriender will disclose Personal Information without Your knowledge or consent if LenderFriender receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If LenderFriender receives a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, LenderFriender’s policy is to provide the requested information.
LINKS TO OTHER SERVICES
You may be able to access third-party websites and services through links available on LenderFriender’s Services.
You may create links between LenderFriender’s Services and social media online services. If You do so, LenderFriender may be able to publish updates about LenderFriender’s Services to Your social media service accounts through the links that You establish. You may terminate those links at any time by modifying Your social network account.
CHILDREN AND MINORS
LenderFriender’s Services are not directed to children under the age of 13 years. LenderFriender will not knowingly collect Personal Information about a child under the age of 13. LenderFriender allows minors (persons who are under the age of majority in their place of residence) to create accounts, and lend or borrow items via the Services.
HOW CAN I ACCESS MY PERSONAL INFORMATION?
Upon request, LenderFriender will provide You information regarding the existence, use and disclosure of Your Personal Information and You will be given access to that information. LenderFriender will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. You may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, LenderFriender may not be able to provide access to all of Your Personal Information that it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. LenderFriender will provide the reasons for denying access upon request.
LenderFriender protects Your Personal Information by security safeguards appropriate to the sensitivity of the information. LenderFriender will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
LenderFriender’s methods of protection include:
Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to LenderFriender ‘s place of business in general and to internal offices as well;
Organization measures, such as security clearances and limited access on a need to know basis; and
Technological measures, such as the use of passwords, firewalls and encryption.
INQUIRIES; CHALLENGING COMPLIANCE
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If LenderFriender finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.
For more information, please contact LenderFriender’s Privacy Office as follows: