Privacy Policy & Security Practices

At Crecero we take security seriously and follow industry best practices in the design and implementation of our data security environment. Controls we use to ensure your online data is secure include, but are not limited to:

1. The use of the latest Transport Layer Security (TLS) protocols for encryption to protect customer information
2. Customer passwords and data are protected using the latest encryption technologies to guard against unauthorized access to our systems
3. AWS secure data centers to help protect data in our care
4. Regular third party audits of our security practices
5. Multiple zones and layers on firewalls to protect our internal and external networks
6. Centralized Security Incident and Event Management (SIEM) is used to monitor unauthorized access to our systems
7. The use of many third party tools to confirm the identity of people applying for any of Crecero’s products
8. Third party vendors are thoroughly vetted for their security practices

At Crecero, we’re committed to protecting your privacy and maintaining strong practices in the handling of personal information in our care.

CreceroI nc., including its subsidiaries and affiliates (collectively, “Crecero”), referred to in this Privacy Policy as “Crecero”, “we”, “us” or “our”, has developed this Privacy Policy (this “Policy”) in accordance with applicable privacy legislation.

Definition of Personal Information

This Policy applies to the personal information of Crecero’s members and other individuals we deal with. This Policy does not apply to personal information of our employees or employee applicants, or to information that is not personal information.

When we say “Information” we are referring to information that is about you that applicable law classifies as personal information. It does not include information that is anonymous, aggregated, or is no longer identifiable to a specific person.

Why?

Let’s start with why we collect your Information.

We collect Information for the purposes of managing and administering our business. This includes enabling us to verify and approve you for our awesome products. We may collect Information directly from you or from third parties with your consent or as permitted or required by law.

What?

• Information we collect includes, but is not limited to: Name, address, email address, telephone number, mobile phone number and other contact particulars;
• Bank account information, including bank account, transit and branch numbers;
• Credit history and financial and identity information from consumer and credit reporting agencies, or financial institutions or businesses that you currently have, or have had, financial dealings with;
• Income information, including the name and contact information of your employer or other source of income;
• Name and contact information of personal references;
  Banking information collected from your physical or online bank statements;
• Information you provided to us in connection with a loan (“Partner Loan”) originated by a third party partner lender (“Partner Lender”);
  Information relating to ongoing interactions with Crecero, including payment history, current and historical loan amounts or balances, inquiries or complaints, and similar information;
• Social Insurance Number, date of birth, and other personal identifiers (if you choose to provide them to us). If you give us your Social Insurance Number, we may use it to identify you with consumer reporting agencies and other parties, and we may keep it in our records with your other information, even after your account is closed;
• Contact and credit information from other providers of financial products and services where you have agreed to the sharing of your Information with entities like Crecero;
• Information we collect automatically when you visit our website (see “Cookies and Similar Technologies” below);
  Information we collect from public sources and third parties in order to locate you where a debt is owed to us and we are unable to contact you using the information we have on file; and
  Other information with your consent or as permitted or required by law.

How?

We’re transparent about how we collect, use, disclose, and safeguard Information in connection with our business in Canada.

We may use your Information:

• to open, maintain, service, process, analyze, audit, and collect on an account;
• to communicate with you in respect of your Crecero Account or other Crecero product or service;
• to enforce the terms of the products or services you have obtained from us;
• to verify your current and ongoing credit worthiness;
• to verify the information you provided to us in connection with a Partner Loan;
• to protect you and us from theft, fraud, and unauthorized access to your account; to assess your ongoing needs for products or services;
• to inform you of special promotions or products (see “How We Use and Share Information for Marketing Purposes” below);
• to enter you in and administer promotional contests that we may offer from time
• to time, and if you win, to identify you
• for promotion and advertising purposes; and
• for other purposes with your consent or as permitted or required by law.

We may also exchange personal information with our affiliates as necessary for the purposes described above.

When?

The following are examples of when we may use your Information:

• We may exchange Information on an ongoing basis with consumer and credit reporting agencies so they can verify your Information, ensure the completeness of the Information they and we have on file about you, maintain the integrity of the credit granting system, and cooperate with local, provincial and national authorities in order to protect you and us from fraudulent transactions.
• We may disclose Information to our affiliates for internal audit, management, billing or administrative purposes including defending and bringing legal actions.
• We may disclose Information to companies with whom we have agreements for the purposes of offering and administering a product or service offered by them and/or us. If you use a Crecero product or service to finance the purchase of goods from a supplier, whether directly or through a third party provider, we may disclose Information to the supplier and/or third party provider as necessary to facilitate that transaction.
• If you request insurance in connection with a product or service offered by us, we will share your Information with the insurance provider for the purposes of establishing and administering and your insurance coverage.
• Crecero may use and disclose Information in connection with the proposed or actual financing, securitization, insuring, sale, assignment, transfer or other disposal of all or part of Crecero or our business or assets, including your account, any debt or interest due to us, and any of our rights and obligations, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of Crecero or our business or assets may use and disclose your information for similar purposes as those described in this Policy.
• We may disclose your Information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit, and security requirements, and otherwise with your consent or as permitted or required by applicable law (including foreign law applicable to our service providers)

We may use your Information in order to identify your preferences, determine your eligibility for special offers and discounts, and to contact you in regard to such offers and discounts, or to provide other information about our products, services, promotions and events.

We may share your Information, including contact information and credit and financial information, with our affiliates and/or partners for the purposes of developing and promoting new or joint products, improving existing products and services, and contacting you to offer products and services that may be of interest to you.

If you no longer want us to use or share your Information for marketing purposes, as described above, please contact us by mail:

Crecero Technologies – Attn: Privacy Officer
100 King Street West, Suite 5700, Toronto, Ontario, M5H 2L3 Canada

To opt out of our e-mail communications, you may click the unsubscribe link at the bottom of the email message or email info@crecerotechnologies.com with the word “Unsubscribe” in the subject line. Please note that if you opt-out of marketing communications, we may still send you account-based information relating to your Crecero Account or related Crecero product(s) or service(s).

We may transfer Information to outside agents or service providers (including our affiliates acting in this capacity) that perform services on our behalf, for example mailing, call center, billing, collections, skip-tracing, marketing, analytics, information technology and/or data hosting or processing services or similar services, or otherwise to collect, use, disclose, store or process Information on our behalf for the purposes described in this Policy. Some of these service providers may be located outside of Canada, including in the United States, and as a result your Information may be processed and stored on servers outside of Canada for the purposes described in this Policy.

Reasonable contractual and other measures we may take to protect your Information while processed, stored or handled by these service providers are subject to applicable Canadian and foreign legal requirements, including lawful requirements to disclose personal information to government and national security authorities in certain circumstances.

When you visit the Crecero website, we may collect and use your internet protocol address to help diagnose problems with our server and to administer the website, to identify users and their activities on the Crecero website, and to gather broad demographic information.

We may also use “cookies”, a technology that installs a small amount of information on a website user’s computer to permit our website to recognize future visits using that computer. Cookies enhance the convenience and use of our website. For example, the information provided through cookies is used to recognize you as a previous user of our website, to track your activity on our website, to respond to your needs, and to otherwise facilitate your experience on our website. You may choose to decline cookies if your browser permits, but doing so may affect your use of our website and your ability to access certain features of our website or engage in transactions through our website.

Crecero also uses web cookies and pixel tags to track user behavior on our websites and to compile reports regarding user demographics, website traffic patterns, and website purchases. We may then provide these reports to advertisers and others.

Within our applications, we may also use analytic tools and automated tracking technology or methods. We use these tools to analyze and enhance the user experience. Crecero may use third party advertising networks to display advertising on our websites or other websites. These advertising networks use cookies or similar technologies to track your navigation habits on our websites and third party websites in order to serve you advertising that is customized to your inferred interests and preferences. For example, a cookie may be placed on your computer when you visit a Crecero website, which is recognized and used by third party advertising networks to serve you with a Crecero ad when you visit other websites within their advertising network. As described above, you may be able to set your browser to decline cookies. If you decline cookies you may still receive online advertising; however, it may be less personalized. Some advertising networks participate in industry programs that include web pages to visit to opt out.

We may provide links to other websites that are not operated or controlled by Crecero. These websites are not governed by this Policy. We recommend reviewing the privacy statement or privacy policy associated with any linked website prior to visiting the site or providing any Information.

Crecero collects, uses and discloses your Information with your consent, or as permitted or required by law. Generally, by ,providing us with your Information, we will assume that you consent to our collection, use and disclosure of such Information for the purposes identified or described in this Policy, if applicable, or otherwise at the time of collection. We may be required or permitted under statute or regulation to collect, use or disclose Information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.

You may withdraw your consent to our collection, use and disclosure of your Information at any time, subject to contractual and legal restrictions and reasonable notice. We will let you know the consequences of refusing or withdrawing consent. Note that if you withdraw your consent to certain uses of your Information, we may no longer be able to provide certain of our products or services.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. We take reasonable measures to protect personal information in our care. On an ongoing basis, we assess the risks associated with the collection, use and disclosure of personal information and we update our privacy and security practices as necessary. Should an unforeseen event occur, such as a data breach or harm caused by bad actors, we have procedures in place to identify, assess and minimize any further risks and determine if there is a real risk of significant harm to individuals.

As part of delivering an optimal service experience, the accuracy of your Information is important to us.

If you wish to request access to or correction of your Information you may write to:

Crecero Technologies – Attn: Privacy Officer
100 King Street West, Suite 5700, Toronto, Ontario, M5H 2L3 Canada

Your right to access or correct your Information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections. If you wish to make inquiries or complaints or have other concerns about our personal information practices, you may write to us as described above or use the Live Chat option on our website.

This Policy may be revised from time to time. If we intend to use or disclose personal Information for purposes materially different than those described in this Policy, we will make reasonable efforts to notify affected individuals, if necessary, including by posting the revised Policy on our website at Crecero.ca. We encourage you to visit this website frequently to obtain the current version. Your continued provision of personal Information or use of our services following any changes to this Policy constitutes your acceptance of any such changes. This Policy is effective as of January, 2020.