Privacy

Effective as of March 13, 2023.

‍Overview

At Fig Financial Inc. (

“Fig”, “we”,

“us”

), we are committed to protecting the privacy and security of any of your personal information. This Privacy Statement best describes the types of personal information we collect, how it is used and the steps we take to ensure that it is handled appropriately. This Privacy Statement also describes how and to whom we disclose your personal information. Personal information refers to information about an identifiable individual, as more particularly described under applicable privacy legislation. Our policies and practices have been put in place to comply with the federal Personal Information Protection and Electronic Documents Act (

PIPEDA

and any applicable provincial privacy legislation. This statement applies to our collection, use and disclosure of personal information in the course of doing business in Canada. This statement does not apply to information about our employees or to information that is not Personal Information. PLEASE READ CAREFULLY, BY ACCESSING FIG OR APPLYING OR USING OUR SERVICES, YOU ACCEPT THIS PRIVACY STATEMENT AND AGREE TO BE BOUND BY ITS TERMS. We may unilaterally amend this Privacy Statement to reflect changes in our practices or legal and regulatory obligations or if we intend to use or disclose personal information for purposes materially different than those described in this statement. In such cases, we will post a new version of this Privacy Statement or notify affected individuals, if necessary. We urge you to review this Privacy Statement frequently to obtain the current version. Your continued provision of Personal Information (as defined below) or use of our products and services following any changes to this Privacy Statement constitutes your acceptance of any such changes. Before using our products, we require collection of certain Personal Information.

By applying for Fig Products, you acknowledge and are providing express consent for Fig to collect, use, process and disclose your personal information.

We collect Personal Information primarily from you, for instance through account applications and supporting information and documentation you provide. In connection with our account opening process, we may collect Personal Information from references, employers and other financial institutions you have identified in your application as well as credit bureaus and other third party sources. If we obtain credit reports or recommendations as to your solvency from third parties, you may request to access such report and rectify it as required by contacting us at our address below.

Data Collection

As part of Fig’s application process and throughout the lifetime of your Fig loan, you may be asked to provide banking details which will allow Fig, or a third party mandated by Fig, to confirm your identity, pre-fill your application and complete certain forms and contracts. It is your responsibility to review documents between you and your financial institution to ensure that you are entitled to provide us with login information and that you understand the consequences of such disclosure and liability that may result therefrom.

Credit Reporting

You expressly authorize Fig to obtain consumer credit reports when you apply for a Fig Product and for other servicing purposes periodically throughout the term of your Fig loan. You expressly authorize us to use the information that we obtain from such reports to make decisions related to providing you with credit and the servicing and collection of your account, statistical analysis, and share information with you about your credit profile. Your authorization is dated as of the date you accept these Terms of Service and continues throughout the use of Fig Products. You agree that Fig may report information to consumer reporting agencies in accordance with applicable law.

Personal information (“Personal Information”) we collect may include:

your name, address, telephone number, cell phone, email, and other contact information;
additional identity matching and credit check information, such as your occupation, name of your employer, rent or mortgage details, assets, income, previous address, social insurance number (optional), date of birth, biometric characteristics and data or government issued identification document details;
information about your credit card or financial account(s), including your current and historical account information, balance and indebtedness, account transaction history and similar information, and records relating to the handling of any inquiries or complaints you make;
your payment-related and bank account information;
the types of products and services that you purchase from our partner retail stores and online;
how often and under what circumstances you make purchases using your credit card;
information from any interactions when accessing/visiting our services or contacting our teams (example: surveys); and
such other information we may collect with your consent or as permitted or required by law.

When communicating with us through social media, or speaking with a live-chat agent, we or our service providers may monitor or record our discussions for mutual protection and to enhance your customer experience. When you visit, use or interact with our online services (websites, mobile applications, and other digital channels), we or our service providers may also collect information from your computer(s), smartphone(s), tablet(s), or other mobile device(s) (collectively,

“mobile devices”

), such as:

The mobile device make and model, unique device identifier, browser type, hardware, Internet Protocol (IP) address and related information, such as your internet service provider and physical location of the mobile device, operating system and MAC address;
Your mobile device-related information such information about the screen size of your mobile device(s) and the date and time of your use;
The precise location of your mobile device(s), if enabled on your device(s);
Photos taken with your mobile device(s) through one of our mobile apps to complete a mobile remote loan application (when enabled in your mobile device settings);
our websites, what websites and pages you visit, how long you stay and what actions you take;
Search terms that directed you to our websites and mobile apps, which websites you came from, and which websites you visit right after leaving one of our websites;
Which of our ads or other online content you view, access or click on; and
Any actions you take in response to electronic communications that we send to you, such as opening the message or clicking an embedded link.

We may associate the above information from your mobile devices through various means, including a unique identifier (such as IP address) by using cookies (files containing a unique identification number that a website sends to your computer’s web browser) and other tracking technologies. If you are one of our customers, we may associate the above information with your personal Fig profile and use it for the purposes described in the section Purposes of our collection below. We are not collecting any sensitive information from our affiliates or third parties, such as medical information, detailed information regarding specific purchases of goods or services, or information concerning customer preferences, needs or interests where a reasonable person would expect the subject matter to cause offence or embarrassment. We have established policies and procedures pertaining to the retention and destruction of the personal information that we hold about you.

Purpose of our collection

We may use your Personal Information that we collect directly and/or that is collected by our partners and service providers and then provided to us, for a variety of purposes (the

“Purposes”

), including:

to verify your identity and the accuracy and completeness of other information you provide us and update such information as required;
to evaluate your application, assess your eligibility and ongoing creditworthiness, behavioural characteristics (including your browsing history on partner websites, information of which is collected automatically, such as via cookies) and to determine your suitability for products or services offered by us, our affiliates, our partners or other selected third parties;
to open, administer and service your account and any requested products or services, including for the collection or payment of debt owed to us, our affiliates, our partners or other selected third parties;
to detect and prevent fraud and unauthorized or illegal activities;
to obtain services from agents, professionals, insurers, or service providers;
to manage complaints, feedback, queries and measure the quality of customer service;
to extend contest offers or for the administration of contest you may have entered into or were automatically qualified for;
unless you have opted out, to provide you with information about products or services offered by us, our affiliates, our partners or other selected third parties, which may be offered by way of relevant/targeted advertising;
to analyze business results, compile statistics and conduct marketing research and modeling, and to contact you for related surveys;
in connection with certain business transactions involving our assets or business (and portions thereof), as further described in the “Information we share with third parties” section below; or
to maintain business records for reasonable periods to comply with applicable tax, legal, security or regulatory requirements, and generally manage and administer our business;
to audit and monitor the use of our website and our products;
to enforce or apply the agreements concerning you; and
for any other purpose to which you consent or that is permitted or required by privacy law or any other applicable law.

Information we share with third parties

Fig may disclose your Personal Information in a number of circumstances, including:

to credit bureaus, credit reporting agencies and to your current or future creditors for the purpose of maintaining your credit history and providing credit references;
to financial institutions for payment processing purposes;
to third parties as reasonably necessary:
to accomplish any of the Purposes set forth above including to manage, administer or enforce your contracts with us and otherwise for the collection or payment of a debt owed to us;
for the purposes of detecting and preventing fraud;
in connection with audits;
for the purposes of meeting legal, regulatory, industry self-regulatory, risk management and security requirements;
unless you have opted out, to our affiliates, our partners or other selected third parties marketing purposes including relevant/targeted advertising.

Security

We take the security of your Personal Information very seriously. We take steps to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the Personal Information we have in our custody or control. These steps include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification of your Personal Information. Only Fig and authorized affiliates, partners, representatives, agents and service providers who require access to your Personal Information in order to fulfill their mandate with us will have access to your Personal Information. Please note that your Personal Information may be sent to another jurisdiction for processing or storage, and that while in another jurisdiction it may be accessed by the courts, law enforcement and national security authorities.

Consent

Depending on the nature and sensitivity of your Personal Information, your consent to the collection, use and disclosure of Personal Information can be express (oral or electronic) or implied (responding to offers, using services without removing your Personal Information). Consent may be given by you or your authorized representative. You may withdraw your consent at any time with reasonable notice of your withdrawal. However, if you withdraw or vary your consent, we may not be able to provide you with the products and services you have requested. If we plan to use or disclose your Personal Information for a purpose not previously identified (either in this Privacy Statement or separately), we will use our best efforts to advise you of that purpose before such use or disclosure. Unless you advise us otherwise, through the access and use of our service, you consent to the collection, use and disclosure of your Personal Information as explained in this Privacy Statement.

Contact Fig

If you have any questions about this Privacy Statement or concerns regarding your Personal Information, please contact our Privacy Officer in writing or by e-mail. If you are not satisfied, you may be entitled to make a submission to the Privacy Commissioner in your jurisdiction. Fig has appointed a Privacy Officer to oversee compliance of our privacy program. The contact information is found below: Fig Financial Inc. Attention: Privacy Officer 630 René-Lévesque West, Suite 1400 Montreal Quebec H3B 4Z9 privacy@fig.ca