privacy policy marked on rubber stamp

Introduction

Lending Mill Inc. (“Lending Mill”, “we”, ”us”, “our”, which terms include all of Lending Mill Inc’s officers, directors, shareholders, employees, and service providers) is committed to protecting your personally identifiable information “Personal Information,” in order to protect your privacy. As part of this commitment, we maintain the Personal Information that we collect, use and disclose from our website users (“you”) in accordance with the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and Canada’s Personal Information Protection and Electronic Documents Act.

We make the website, www.lendingmill.ca (the “Website”) available together with our Website services as further described in our Terms of Use (the Website, and website services offered by us collectively referred to herein as the “Service”). This Privacy Policy describes how we collect, use and disclose information about our users through the Service.

“Personal Information”

Privacy legislation in Canada defines “Personal Information” broadly as any information about an identifiable individual. We consider Personal Information to include any information, in any form, about an identified individual or an individual whose identity may be inferred or determined from such information. This includes, but is NOT limited to, your name, address, e-mail address, credit card information, financial information, background checks, and birth date. In general, personal information does not include business contact information, including your name, title or position, business, telephone, email and facsimile number.

Accountability

Lending Mill is responsible for maintaining and protecting the Personal Information in our possession or control. This includes personal information we receive directly, such as from individual you or other website users, and personal information we receive indirectly from others. We have established policies and procedures with the objective of protecting Personal Information and have appointed a Privacy Officer to oversee privacy matters that can be reached at privacy@lendingmill.ca.

What Personal Information Do We Collect

The types of Personal Information we may collect about you include your name, and home contact information, phone number, e-mail address, credit card information, financial information, background checks, and birth date. Our collection of your Personal Information will be limited to those details relevant and necessary to providing you with the Service.

We may also collect “Non-Personal Information”. This may include a) business contact information; b) information of an anonymous nature about your online interactions with the Service, such as an Internet Protocol Address (IP Address), the domain used to access the Website, and the type and version of browser or operating system being used by visitors to the website; c) aggregate information, which includes information resulting from the combination and/or aggregation of certain data in a way that no longer personally identifies users, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, average time spent on the Website. We may collect this information for the purposes of (i) tailoring content that we may send or show you, (ii) to authenticate you, enable access to information, and otherwise administer the Service, and (iii) for analytical purposes to better understand digital interactions with Lending Mill. This Policy does not apply to the collection, use or disclosure of Non-Personal Information.

Our Purposes for Collecting, Using or Disclosing Personal Information

General

Lending Mill collects, uses and discloses Personal Information for the primary purpose of providing our users with the Service, including for the following purposes:

 

  • establish a commercial relationship with you
  • manage your account (including helping you to efficiently access your information after you sign in, remember information so you will not have to re-enter it during your visit or the next time you visit the Website)
  • provide the Service to you (including providing personalized content and information to you and our service providers, which could include payment processors, online ads or other forms of marketing)
  • collect and process payments,
  • maintain our customer/visitor lists (including the monitoring metrics such as total number of visitors, traffic, impressions, and demographic patterns)
  • respond to your inquiries or provide feedback,
  • provide you with ongoing client support and customer services,
  • identify and authenticate you,
  • engage in the development of new services and features, as well as to improve, test, and monitor the effectiveness of the Website (including the diagnosis or remediation of technology issues)
  • keep you up to date on our service,
  • meet legal and regulatory requirements,
  • Such other purposes consistent with objectives of the Service.

 

Website

  • Cookies – Cookies are small elements of data placed on your devices when you visit a web site in order to authenticate you for an improved user experience. We may, from time to time, collect personal information about you and your use of the site though the use of cookies as outlined above. Some browsers can be set to reject all cookies; if you choose to modify your browser in this manner, not all features offered through the Service may remain available.
  • Links – Our website may contain content, services, advertising and other materials that link to other websites (“sites”). You should be aware that operators of linked websites may also collect your personal information and information generated through the use of cookies when you link to their websites. Lending Mill is not responsible for how such third parties collect, use or disclose your personal information, and this Privacy Policy does not apply to them. It is important to review the privacy policies of those sites before providing them with your Personal Information.
  • Communications – From time to time, we may send electronic messages (via email or the online messaging function) to users or other individuals to our contact database to keep you up to date on our service or other purposes consistent with the objectives of the service. Each e-mail includes an opt-out feature and instructions on how to unsubscribe if you do not wish to receive future emails from us for these purposes. If you would like to opt out of having your Personal Information used for the online messaging function you can contact the our Privacy Officer.

 

Service Providers

We engage certain trusted third-party business service providers to perform functions and provide services to us in order to operate the Website and our Service. Examples include third-party service providers who manage mailing information, maintain databases, host services and process payments. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to obligations mirroring the protections of this Policy. These third parties may collect information sent by your browser as part of a web page request, such as cookies or your IP request. We do not disclose your Personal Information to third parties for their direct marketing purposes.

 

Consent

We will obtain a user’s consent to the collection, use and disclosure of Personal Information about the User, and the consent of other individuals where required by applicable privacy legislation. We assume that by using the Service, you consent to the collection, use and disclosure of your Personal Information as defined in this Privacy Policy. In addition, where appropriate, specific authorizations, or consents may be obtained from time to time. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent unless authorized or required by law to do so, such as in the following circumstances:

 

  • where required by law or by order or requirement of a court, administrative agency or governmental tribunal
  • if we believe that it is necessary to protect the rights, privacy, safety, or property of an identifiable person or group
  • where it is necessary to establish or collect monies owing to us or to pursue available remedies or limit any damages that we may sustain
  • where we believe that a breach of an agreement or contravention of a law has been, or is about to be committed and that it is reasonable to expect that disclosure with the knowledge or consent of the individual would compromise the investigation
  • where we believe that fraud is likely to be committed and it is necessary to use the Personal Information to detect, suppress, or prevent fraud, and that it is reasonable to expect that disclosure with the knowledge or consent of the individual would compromise the investigation
  • if we believe that it is reasonably necessary to comply with a law, regulation, or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect the Website’s rights or property.
  • in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.
  • where it is necessary to assess, process, or settle an insurance claim

You may withdraw your consent to our use or disclosure of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Service.

Use of Non-Personal Information

Although certain Non-Personal Information collected, used or disclosed through the use of the Service as described herein is not restricted (and to the extent that such is the case, the obligations under this Privacy Policy do not apply to such information), we provide information in this Privacy Policy about the collection of such information in the interest of transparency with respect to the provision of the Service. Such Non-Personal Information is collected or derived by us in the course of providing the Service. For example, we may automatically collect Non-Personal Information related to your usage of the Website (e.g. browsing habits: date, time and duration of individual page, section and Website and browsing, operating system, IP addresses, browser / device type and language, referring and exit pages and URLs, keywords and similar information related to use of the Service) that is provided through your browser or stored in a cookie when you choose to visit the Website.

We collect this Usage Information, by using cookies and device identifiers. Cookies, as described above, help your computer “remember” information about your visit. When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” A device identifier may be data-stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to your device.

We may use or disclose non-identifiable aggregated usage and statistical information, or otherwise Non-Personal Information, such as your public bio or the number of users who clicked on a particular link, to improve the quality the Service provided or for other purposes that we may deem appropriate.

Limiting Collection, Use and Disclosure

We collect personal information by fair and lawful means and, wherever appropriate, directly from you. Wherever possible, we limit the amount of personal information we collect, use or disclose to that necessary and appropriate for the purposes described herein unless you have otherwise consented, or when it is required or permitted by law. We do not otherwise sell, trade, barter, exchange, or disclose for consideration any Personal Information that we have collected.

Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints. We take care in disposing of or destroying Personal Information to prevent unauthorized parties from gaining access to the information.

Accuracy of Information

We will make every reasonable effort to keep your Personal Information accurate and up-to-date as is necessary to fulfill the purposes for which it is to be used. We will provide you with mechanisms to update, correct, delete or add to your Personal Information. As appropriate, this amended Personal Information will be transmitted to those third-parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to provide you with a high-quality of service.

Safeguards

The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment, this includes using industry standard Secure Sockets Layer (SSL) encryption technology. We endeavor to maintain appropriate physical, procedural, and technical security with respect to our offices and information storage facilities, so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. We further protect Your Personal Information and any financial or payment information by restricting its access to those employees who need to have knowledge of that information in order for us to provide our Services, as determined by us and our service providers.

 

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your account information for the Service. We do not have control over and are not responsible for, Personal Information that users voluntarily disclose about themselves to via the Service, nor for Personal Information that a user may disclose about another user via the Service. Please exercise caution before disclosing Personal Information about yourself to other users through the Service.

Openness About Privacy Practices

We make information available to our users concerning the policies that apply to the management of their Personal Information. The most up-to-date version of our Privacy Policy is available in its entirety at https://www.lendingmill.ca/lending-services-privacy-policy or by contacting our Privacy Officer at privacy@lendingmill.ca.

Access to Your Personal Information

You may access the Personal Information we hold about you in order to verify the accuracy and completeness of the Personal Information we have collected with respect to you and to have a general account of our uses of that information. You may contact us directly to access Personal information we hold about you. We provide registered users of the Website with tools to access or modify the Personal Information you provided to us and that is associated with your account.

In certain limited circumstances, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavour to deal with all requests for access and modifications in a timely manner. To guard against fraudulent requests for access, we may request additional information to allow us to confirm that the person making the request is authorized to do so before granting access or modifying any Personal Information.

Challenging Compliance with this Privacy Policy

We welcome your questions, comments or suggestions about security and privacy. If you have a question about the privacy policies stated on this website, please contact us at via contact form on the Lending Mill Website.

If you have a concern or complaint about privacy, confidentiality or the personal information handling practices of Lending Mill, our employees or service providers, please contact:

Mailing Address:

Privacy Officer

208 – 18 Wynford Drive

North York, Ontario

M3C 3S2

Phone: 416-474-7788

Email: privacy@lendingmill.ca

Before Lending Mill is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavour to respond within an appropriate timeframe.

If you have questions or concerns regarding our organization’s privacy policy and practices, you should first contact us directly.

 

If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact the Privacy Commissioner’s Office at https://www.priv.gc.ca (or 30 Victoria Street, Gatineau, Quebec, K1A 1H3), who will then serve as a liaison with Lending Mill to resolve your concerns.

Changes to this Policy

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will provide and appropriate notice on the Website directing you to the updated Privacy Policy, and may inform you of changes via the email associated with your account or by the online messaging function through your account on the Website. Unless stated otherwise, our current version of the Privacy Policy accessible at www.lendingmill.ca will govern how we handle the Personal Information that we have about you. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Website signifies your acceptance of any changes to the Privacy Policy.