Client Privacy Policy

Policies and procedures to protect your privacy are in place.

We, at Cash Money value you as a client and take your personal privacy seriously. As such, we would like to inform you of our policies for collecting, using, securing, and disclosing your personal information. It is our intention to manage and handle your personal information in a manner consistent with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and other relevant privacy legislation to the extent required by law.

In this policy, here are some important terms you should know:

“Personal Information” or “Information” means information about an identifiable individual such as contact information, date of birth, age, information contained in a credit report, and financial information.

“We”, “Our”, or “Us” means CURO Canada Corp. o/a Cash Money

“Third Party” means an individual or organization outside of Cash Money including those located in the United States of America.

“Permitted or required by law” or “legal and regulatory obligations” means actions that we are permitted or required to do under any laws or regulations, or any rules, codes, guidelines, expectations, or requirements of any applicable regulator.

What Personal Information do we collect?

The personal information we collect depends on the service you request. We may collect personal information about you from the following sources:

• Information we receive from you on applications or other forms, such as your name, address, phone number, email address, social insurance number and income.
• Confirmation of employment information from your employer.
• Information we receive from other third parties, such as credit reporting agencies and other financial institutions, relating to your initial and on-going creditworthiness.
• General eligibility for our or related services, such as those provided through Western Union (Money Transfers/Money Orders), Attain Finance (Pre-Paid Card Products), or insurer offering a loan protection program that you elect to enroll.
• We may also use cookies and other technologies to collect information (including location information) when you visit our website or use our mobile app.

Why do we collect your Personal Information?

We collect, use and disclose your personal information for the following reasons:

• To communicate with or contact you (e.g., address, telephone number, email or other electronic address);
• To verify client identity (e.g., date of birth, government-issued identification, occupation);
• To meet legal and regulatory requirements;
• To provide financial services to you, and to authorize and process your transactions;
• To detect and prevent fraud and help safeguard the financial interests of Cash Money and its clients (e.g., reviewing and analyzing your transactions and other information to help us identify various types of threats and risks, such as credit, fraud and money laundering);
• To develop, offer, and manage the various products and services provided by our company in order to meet our clients’ needs (e.g., purchase and payment history, communication preferences and location);
• To maintain adequate accounting, tax and business records;
• Where applicable, to confirm details of your employment;
• To assess the quality and quantity of our products and services (e.g., call monitoring, record and respond to client feedback);
• To collect a debt that may be owed to Cash Money

We will not, as a condition to the supply of a product or service, require you to consent to the collection, use, or disclosure of Personal Information beyond that required to fulfill legitimate purposes outlined in this Privacy Policy. We collect, use and disclose Information that we believe is reasonable for the above purposes or those purposes indicated to you at the time the Information is collected.

Who sees or obtains your Information?

We may provide your Personal Information^* to a third party in the following limited circumstances:

• Where we have your consent (obtained prior to providing your Personal Information to a third party);
• To consumer or credit reporting agencies to verify your current and ongoing creditworthiness, or to maintain your credit history;
• To your financial institution to verify an account;
• Where we are required or permitted by law or our regulators, to do so;
• To service providers (including affiliates acting in this capacity) that perform services on our behalf, such as pre-paid credit card financing, online loan underwriting, data hosting, data processing, information technology, marketing and analytics, call centre, mailing, collections and billing;
• Where we provide credit insurance, we collect Information on behalf of and share Information with the insurance provider in order to help sell and administer the insurance and facilitate claims;
• In the unlikely event of a sale or lease of our business, in whole or in part, or a corporate re-organization; or
• Where such third party assists us in serving you.

In such cases we will make disclosure to the extent that is necessary to accomplish the required purposes or discharge our regulatory, legal or public duty. We will endeavor to obtain from the third party receiving the Information reasonable assurances that it will respect the privacy of Personal Information in accordance with applicable laws. As certain of our operations are conducted in the United States of America and certain of our service providers may have operations in the United States of America, your information may be sent outside of Canada by secure electronic or other means. In the event that your Information is sent outside of Canada, there is a remote possibility that it may be accessed by the courts, law enforcement and national security authorities of the jurisdiction where it is sent.

What are our safeguards for protecting your Information?

Our security safeguards are designed and maintained to protect your Personal Information against loss or theft, as well as unauthorized access, use, copying, modification, disclosure or disposal. Our current methods of protection include:

• Physical measures including restricted access to branches, alarm systems, and secure filing cabinets;
• Technological measures for electronic transfers including our email and point-of-sale systems running on a VPN with a minimum of 128-bit encryption and a firewall, and our point-of-sale system requiring several passwords including a sequel server;
• Organizational security measures including security clearances, limiting access to a 'need to know' basis, staff training, and required confidentiality agreement; and
• Investigative measures, should Cash Money have reasonable grounds to believe that Personal Information is being inappropriately collected, used or disclosed.

Cash Money protects Personal Information regardless of the format in which it is held.

Although we have various security measures in place, we cannot guarantee the absolute security of our website, or the security of Information that you submit or that we send to you over the internet, since no internet transmission is ever fully/completely secure or error-free. Your use of the internet and electronic mail is at your own risk.

Should there be a breach relating to the Personal Information that you have provided to us, we will make an assessment as to whether the privacy breach creates a real risk of significant harm to you (includes financial loss, identity theft, negative effects on a credit record, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, or loss of property). Should we determine that the privacy breach does result in a real risk of significant harm to you, we will provide you with notification at the earliest opportunity. The notification will contain sufficient information to allow you to understand the significance of the breach and to take steps, if any are possible, to reduce the risk of harm that could result from it or to mitigate that harm. It shall also contain any other information required by law. We shall also report any breach of security safeguards to the Privacy Commissioner if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you.

How long do we keep your Information and how do we dispose of it?

The length of time we retain your Information varies depending on the services you have requested and your relationship with us. We keep Information for so long as it is reasonably required by us or legally necessary for us to retain such Information. Your Information is confidentially destroyed, deleted, erased or converted to an anonymous form when reasonably appropriate.

How do you gain access and verify your Personal Information?

We will provide you access to the Personal Information we have about you. If you require information, simply contact our Privacy Officer. We will respond to your request within thirty (30) days. Please note that we may not be able to provide Information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to us, is too costly to retrieve, or cannot be disclosed for other legal reasons.

Having accurate Information about you enables us to give you the best possible service. You can help by keeping us informed of any changes, for instance if you move or change telephone numbers. If you find any errors in our Information about you, let us know and we will make the corrections promptly and make sure they are conveyed to anyone we may have misinformed. For Information that remains in dispute, we will note your opinion in our file. Requests can be made through the client's local branch, website or Cash Money’s Privacy Officer.

How are your choices handled?

Subject to legal or contractual restrictions and reasonable notice, you are free to refuse or withdraw your consent to the collection, use or disclosure of your Personal Information at any time. You may do so by contacting our Privacy Officer. However, once you are using our service you may not be able to withdraw your consent to our collection, use and disclosure of Personal Information as necessary to provide that service. You may also wish to limit the amount of Personal Information we collect, use or disclose about you. However, by doing so, we may not be able to provide our services or related services to you. You may opt out of receiving certain communications, via email, SMS, telephone or direct mail at any time.

Telephone calls made to Cash Money may be recorded for quality assurance and record keeping purposes. If you do not wish to have your telephone calls recorded, you have the option to conduct your business with us through a Cash Money store or by writing to us.

How is your privacy treated by our website and mobile app?

In general, you may visit Cash Money on the web or use our mobile app without telling us who you are or revealing any Information about yourself.

We may, however, collect non-personally identifiable information from you when you visit our website or download or use our mobile app. For our website, this includes your domain name, the IP address of the web page from which you enter the site, the pages you visit on our site and the amount of time you spend there. For our mobile app, this includes device ID and model number. This information is used to improve and customize the content and layout of our website or app.

From time to time, we may utilize cookies or scripts on our website. You may disable these features, but by doing so, you may not be able to utilize the services we provide on our website.

We collect the email addresses of those who communicate with us by email and information volunteered by our visitors. The information we collect is used to improve our content and contact these visitors, if they have requested to be contacted.

From time to time, we may advertise our products and services on another company's website. If you access one of these ads, we may track the response rate and the website activity associated with each ad. The response rate data is used to help us plan future online advertising campaigns. From time to time we may provide links (from our website or mobile app) to other websites that may be of interest to our visitors. However, we cannot and do not guarantee that their privacy policies are adequate or equivalent to ours. In order to protect your privacy, we recommend that you read each page's website privacy policy carefully before making the decision to share Information and only share Information with companies that you trust will protect your privacy.

How will we amend our Client Privacy Policy?

We may amend our Client Privacy Policy from time to time. If it changes at some point in the future, we will publish the changes on the version posted on our website and in our branch lobbies. An up-to-date version of our Client Privacy Policy will be available for handout at our branches.

How do you talk to us?

Our Privacy Officer is your point of contact if you wish to raise any matters regarding our collection, use, storage or disclosure of your Personal Information. For information, questions or concerns on Cash Money privacy practices contact:

Privacy Officer

• Telephone: (877) 293-0311
• Facsimile: 1-416-213-1113
• Email: privacy@cashmoney.ca
  
• Website: www.cashmoney.ca
• Mailing Address:
  • Cash Money
  • 4-2880 Queen Street East, Suite # 316
  • Brampton, ON L6S 6E8

Our Privacy Officer has the decision-making authority to resolve most concerns. If you are not satisfied with our resolution of your privacy matters, you may address your concerns to the Privacy Commissioner of Canada at http://www.priv.gc.ca or call toll-free at 1-800-282-1376.