Spring Financial Privacy Policy Last Updated February 3, 2023
Your privacy is important to Spring Financial Inc. (“Spring Financial”, “we”, “us” or “our”). This Privacy Policy explains how we collect, use, disclose, retain, and manage your Personal Information, as defined below, in connection with your access and use of our Products and Services. This includes information collected by us through websites and telephone calls and when providing Products or Services.
In this Privacy Policy, “Spring Financial Companies” means collectively our corporate affiliates, if any. Each of the Spring Financial Companies is referred to as a “Spring Financial Company”. Any capitalized terms used, but not defined in this Privacy Policy, will have the same definition ascribed to such capitalized terms as outlined in our General Terms of Service.
In this Privacy Policy, “Personal Information” means information about an identifiable individual, such as an individual’s name and email address, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.
By providing us with your Personal Information, and/or by applying for or obtaining a Product or Service from
us, you consent to the collection, use, disclosure and retention of that information by us in accordance with
this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any
time, subject to legal or contractual restrictions and on reasonable notice to us, by emailing our Privacy
Officer using the contact information noted below. If you do not provide us with certain Personal Information
then you might not be able to proceed with your intended interactions or transactions with us or otherwise
receive the full benefit of our Products and Services. If we want to use your Personal Information for any
purpose that was not disclosed to you at the time you provided your initial consent, we will seek out your
consent at the time of this new purpose.
If you do not agree with any term in this Privacy Policy, do not provide us with any of your Personal
Information or use our Website, Products or Services.
The information we collect may include, but is not limited to:
(a) General
We use your Personal Information for purposes relating to or arising from your relationship
and transactions with us and as otherwise set out in this Privacy Policy or permitted by applicable law,
including to:
(a) General
We disclose your Personal Information for purposes relating to or arising from your relationship and
transactions with us and as otherwise set out in this Privacy Policy or permitted by applicable law.
(b) Specific Consents
We may disclose your Personal Information in accordance with express or implied consents that you give
during your interactions and transactions with us.
(c) Referred Transactions
If we refer you to an independent business (e.g. a lender) for a proposed transaction (e.g. a vehicle loan), then
we may disclose your Personal Information (including your credit score that you provided to us, Bank
Account information, and related information) to the independent business to facilitate the proposed
transaction. We have no responsibility or liability for, the use, disclosure or retention of your Personal
Information by the independent business, and the use, disclosure and retention of the disclosed information
by the independent business is not subject to this Privacy Policy.
(d) Suppliers and Service Providers
We may disclose your Personal Information to our suppliers and service providers (including fraud
prevention services and payment processors) to assist us in the provision of information, Products and
Services to you, to assist us in using your Personal Information as set out in this
Privacy Policy and as otherwise permitted by applicable law.
(e) Law Enforcement/Legal Disclosures
We may disclose your Personal Information as required or authorized by applicable law, including to comply
with a subpoena, warrant court or arbitral order or litigation disclosure obligation. We may disclose your
Personal Information to law enforcement agencies or other independent organizations if we reasonably
believe the disclosure is necessary or appropriate in connection with national security, law enforcement or
other issues of public importance, or if we reasonably believe the disclosure is necessary or appropriate to
protect and enforce our legal rights, interests and remedies or to protect the rights, interests, business,
operations or our customers or other persons (including to detect and prevent fraud and other illegal
activities, enforce any of the terms of use, terms of service or other agreements that govern access to or use of
any of our Products or Services). We have no responsibility or liability for, the use, disclosure or retention of
your Personal Information by the agencies, independent organizations or other persons to whom we disclose
the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed
information by those agencies, independent organizations or other persons is not subject to this Privacy
Policy. We may disclose your Personal Information that we have in our records even if your profile with us
has been closed, to comply with our regulatory and legal requirements. This may include disclosures for tax,
anti-money laundering, and sanctions screening purposes. We may relay this information to our financial
institution partners, relevant third parties and relevant government or regulatory agencies, as permitted or
required by law.
(f) Business Transactions
We may disclose your Personal Information in connection with a proposed or actual business transaction in
which we are involved (such as a corporate amalgamation, reorganization, merger or acquisition, or the sale
or transfer of some or all of our business or assets), but we will require the information recipient agree to
protect the privacy of your Personal Information in a manner that is consistent with this Privacy Policy and
applicable law.
We and Spring Financial Companies, and our and their service providers may process, store and use your Personal Information at facilities in various countries, including Canada, the United States of America and one or more countries in Europe, Asia, or South America. The Personal Information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your Personal Information without notice. By providing your Personal Information to us, you consent to the transfer and access of your Personal Information to facilities located in other countries and the processing and storage of your Personal Information at those facilities.
We retain your Personal Information for the period reasonably necessary for the purposes referenced in this Privacy Policy and to comply with our legal obligations or enforce or protect our legal rights, or a longer period required or permitted by applicable law. We will delete or dispose of your Personal Information when we are no longer reasonably required to retain the information for the purposes referenced in this Privacy Policy.
We use reasonable safeguards – including administrative, physical and technical security, and safety measures – appropriate to the sensitivity of the Personal Information in our possession or under our control to help protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. Nevertheless, security risks cannot be entirely eliminated and we cannot guarantee that your Personal Information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy.
(a) Accuracy
We rely on you to ensure that the Personal Information you provide to us is as accurate, complete and
up to date as necessary for the purposes for which we use the Personal Information. You will promptly notify
us of any changes to your Personal Information using the procedures made available for that purpose by us or
by contacting our customer service.
(b) Access
You may reasonably request access to your Personal Information collected by us and information about our
use, disclosure and retention of that Personal Information by submitting a written request to our Privacy
Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed
by applicable law, you will be given reasonable access to your Personal Information in our control and you will be entitled
to verify the accuracy and completeness of your Personal Information and to have it revised as
appropriate. You may be required to pay a reasonable fee for access to your Personal Information.
(c) Deletion
You may request we delete your Personal Information in our possession by submitting a written request to
our Privacy Officer using the contact information noted below. Subject to applicable exceptions and
limitations prescribed by applicable law, we will delete your Personal Information upon such request.
We will take appropriate steps to verify the identity of anyone requesting changes to, access to or deletion of
your Personal Information. We may decline to process a request to change or access Personal
Information that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or
jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.
We create and collect non-personal information (information that is not about an identifiable individual), including information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. We may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with Personal Information, then we will treat the combined non- personal information as Personal Information for the purposes of this Privacy Policy for as long as the non- personal information is combined with Personal Information.
Our Website and correspondence (including emails and messages) may include advertisements for products and services (e.g. vehicle sales, personal loans and credit cards) offered by independent businesses (that may have a financial relationship with us) or links to websites operated by independent businesses (e.g. car dealers, lenders and credit card providers). We have no responsibility or liability for, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your Personal Information. This Privacy Policy does not directly apply to the collection, use, disclosure and retention of your Personal Information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain Personal Information, please contact the owner or operator of the applicable website, service or business.
(a) Disclaimers, Liability Exclusions/Limitations and Disputes:
The agreements (including any subscription agreement or terms of service or use) that you accept when you
apply, register for, order or use our Products or Services contain important provisions, including provisions
disclaiming, limiting or excluding our liability and other persons (including Spring Financial Companies and
service providers) and provisions determining the applicable law and jurisdiction for the resolution of
disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may
arise in relation to this Privacy Policy or our collection, use, disclosure and retention of your Personal
Information, and are of the same force and effect as if they had been reproduced directly in this Privacy
Policy. Nothing in this Privacy Policy amends any of those other agreements.
(b) Changes to this Policy:
We may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on our
Website. Our collection, use, disclosure and retention of your Personal Information will be governed by the
version of this Privacy Policy in effect at that time. Your continued dealings with us after any change to this
Privacy Policy will signify your consent to the collection, use, disclosure and retention of your Personal
Information as set out in the changed Privacy Policy. Please visit this Website regularly for updates to this
Privacy Policy.
(c) English Language:
You and Spring Financial have each expressly requested and required that this Privacy Policy and all other
related documents be drawn up in the English language. Les parties conviennent et exigent expressement que
cette Politique de Confidentialitéet tous les documents qui s’y rapportent soient rédigés en anglais.
(d) Contacting Spring Financial’s Privacy Officer:
Our Privacy Officer is responsible for our employees being trained in our privacy policies and for ensuring we
fulfill our privacy commitments. If you have any comments or questions about this Privacy Policy or how we
deal with your Personal Information, please contact our Privacy Officer by mail or email at: Spring Financial
Inc. – Privacy Officer, Suite 505, Two Bentall Centre, 555 Burrard Street, Vancouver, British Columbia, Canada,
V7X 1M8 and by email:
[email protected].