Privacy Statement

1. Personal Information We Collect and How

We collect personal information from you directly, automatically from your device(s), from other sources (such as the references you may have provided or provide and third-party advertising partners), and through cookies and other tracking technologies.

Examples of personal information we collect directly from you include:

1. Contact information that you provide when applying for a Fig loan and when setting up a user profile with us, such as your name, address, phone number(s), email, and other contact information.
   
   
2. Identification and application information that you submit with your loan application, such as your occupation, employment status (which may include disability or leave status), name of your employer, rent or mortgage details, assets, income, previous address, social insurance number (optional), date of birth, government-issued identification document details, selfies taken with your mobile device(s) through one of our mobile apps to complete a remote loan application (when enabled in your mobile device settings), and biometric data derived from your identification document photo and selfies (explained in more detail below).
   
   
3. Biometric data that we collect from the photo on your government-issued ID and the selfie (photo or video) you upload when you apply for a loan with us in order to verify your identity, detect and prevent fraud, and meet our legal and regulatory requirements (including compliance with anti-money laundering rules). We generate alphanumeric templates from your facial measurements in both uploads and compare these templates to verify that the individual in the government-issued ID photo and the selfie is the same.
   
   
4. Financial information such as information about your income, employment information, financial account(s), including your current and historical account information, balance and indebtedness, account transaction history and similar information, and your payment-related and bank account information.
   
   As part of Fig’s application process, you will be asked to provide banking details, including your login credentials, to allow Fig’s third-party provider to log into your bank account and collect information across all accounts you hold with the same financial institution (e.g., chequing, savings, credit cards, loans and mortgages). The information our provider collects on our behalf could include account balances, transaction history for up to 365 days (which can include, among other things, details on deposits and payments you receive and your employment information) and any phone number and email address associated with the bank accounts. We collect and use this information throughout the lifetime of your Fig loan to confirm your identity, complete certain forms and contracts, assess your creditworthiness and ability to repay your loan, and otherwise manage our risk as your loan provider. It is your responsibility to review the terms of use between you and your financial institution to ensure that you are authorized to provide our provider with your login credentials, and that you understand the consequences of doing so and any liability that may result.
   
   
5. Correspondence information about your interactions and communications with us, such as information about your customer support queries, reviews of our products or services, survey feedback, and other information you provide to us in the course of our interactions. When communicating with us or speaking with a live-chat agent, we or our service providers may monitor or record our discussions for training, quality assurance and to enhance your customer experience.
   
   

Examples of personal information we collect automatically from your device include:

1. Technical data such as mobile device make and model, unique device identifier, browser type, hardware, Internet Protocol (IP) address, internet service provider, operating system, MAC address and the approximate physical location of the device.
   
   
2. Location data : if enabled on your device, we collect the precise location of your mobile device(s) principally for fraud analysis purposes.
   
   
3. Usage and interactions data about your browsing habits on online services provided by us or third parties such as pages most read, time spent, search terms and other engagement data in order to evaluate and improve the user experience.
   
   

Examples of personal information we collect from other sources include:

1. Eligibility and credit check data collected in connection with your application for a Fig Product, including soft credit check information and records relating to the handling of disputes, inquiries or complaints you initiate with credit bureaus. We collect eligibility and credit check data from credit bureaus (also known as consumer reporting agencies). We 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, for statistical analysis, and to share information with you about your credit profile. Fig may report information to consumer reporting agencies in accordance with applicable law. If we obtain credit reports or recommendations as to your solvency from third parties, you may request to access such a report and rectify it as required by contacting us at our address set out under Contact Fig below.
   
   

We may collect other personal information with your additional consent or as permitted or required by law.

2. Purposes of Our Collection

We may use your personal information that we collect for the following purposes, or as otherwise permitted or required by law:

1. to verify your identity and the accuracy and completeness of other information you provide us and to update such information as required;
2. to evaluate your application, assess your eligibility and ongoing creditworthiness and determine your suitability for products or services you apply for, including by obtaining a credit check from a consumer reporting agency with your consent;
3. to determine your suitability for products or services offered by us, our affiliates, our partners or other selected third parties;
4. to open, administer and service your account and any requested products or services;
5. to communicate with you about the products or services we provide to you;
6. to detect and prevent fraud and unauthorized or illegal activities;
7. to obtain services from agents, professionals, insurers, or service providers;
8. manage complaints, feedback, queries and measure the quality of customer service;
9. to extend contest offers or for the administration of contest you may have entered into or were automatically qualified for and to contact you for surveys that can help us improve how we do business with you;
10. 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 email / SMS marketing or relevant/targeted advertising;
11. to manage and assess our risks associated with providing our services to you;
12. 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;
13. to maintain business records for reasonable periods to comply with applicable tax, legal, security or regulatory requirements, and generally manage and administer our business;
14. to audit and monitor the use of our website and our products;
15. to improve the user experience;
16. to enforce or apply the agreements concerning you; and
17. for any other purpose to which you consent or that is permitted or required by privacy law or any other applicable law.

3. Automated Decision-Making

Fig may make decisions regarding a loan application exclusively through an automated decision-making process. For more details on your rights related to this type of processing, refer to the section below titled Your Rights in Automated Decision-Making.

4. Marketing Communications

We may send you updates, newsletters, offers or other marketing communications using your email address or phone number. We may tailor these communications based on your interests and preferences and your interactions with us. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or by replying “STOP” to any of our text messages. Alternatively, you can opt out of receiving marketing communications by contacting us using the contact information provided in the Contact Fig section below. Please note that you may continue to receive transactional or account-related communications from us.

5. Anonymized Information

We may modify or aggregate your personal information such that it cannot reasonably be associated with you and use it to:

1. protect your privacy and the security of your personal information;
2. conduct internal business analytics with the goal of improving our services and the client experience, develop new offerings, compile statistics and conduct market research.

6. Information We Share with Third Parties

Fig may share your personal information with the following types of third parties:

1. credit bureaus, credit reporting agencies and your current or future creditors for the purpose of obtaining eligibility information, maintaining your credit history and providing credit references;
2. financial institutions for payment processing purposes;
3. references you provide in an application for a loan for the purpose of confirming information submitted in your application;
4. our third-party service providers (including affiliates) that provide services on our behalf, such as hosting our website, verifying your identity and financial information that you provide to us, helping us assess risk, conducting analytics and providing marketing and advertising services;
5. other third parties as required:

6. to accomplish the purposes explained in this Statement, including to manage, administer or enforce your contracts with us and otherwise for the collection or payment of a debt owed to us;
7. for the purposes of detecting and preventing fraud;
8. in connection with audits;
9. as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Fig or as part of a corporate reorganization or other change in corporate control; and
10. for the purposes of meeting legal, regulatory, industry self-regulatory, risk management and security requirements.

7. Information About our Website

1. Visiting Our Website: In general, you can visit our website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our website and other related information such as page requests, browser type, operating system, average time spent on our website and other similar attributes. We use this information to help us understand activity on our website and to monitor and improve our website.
   
   
2. Cookies : Our website uses a technology called 'cookies'. A cookie is a tiny element of data that our website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all of the website’s features.
   
   
3. Analytics : We may use a third-party such as Google Analytics to help us gather and analyze information about the areas visited on the website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:
   
   
1. - https://policies.google.com/technologies/partner-sites
2. - https://support.google.com/analytics/topic/2919631
4. Ad Optimization: We may use services provided by third-party platforms (such as social media and other websites) to serve advertisements on such platforms to you or others and to measure the effectiveness of our ads. To do so, we may provide a hashed version of your email address or other information to the platform provider. To opt out of this use of your personal information, please send a request using the contact information provided in the Contact Fig section below.
   
   
5. Third-Party Links: Our website may contain links to other websites and applications that we do not own or operate. We provide links to third-party websites and applications as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites or applications. The linked websites and applications have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites and applications, and therefore we have no responsibility or liability for the manner in which the organizations that operate such websites and applications may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.
   
   

8. Interest-Based Advertising

We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third-party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.

Opting out of Interest-Based Advertising:

1. For more information about interest-based advertising and to understand your options, including how you can opt out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at https://youradchoices.ca/en/tools.
2. Please note that even if you opt out of interest-based advertising by a third-party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.
3. To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt out of each web browser on each device you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again.
   
   

9. Security and Retention

We take the security of your personal information very seriously. We take steps to protect your personal information using physical, technological or organizational security measures appropriate to the sensitivity of the personal information we have in our custody or control. These steps include safeguards designed to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification of your personal information.
The only Fig personnel and service providers who are authorized to access your personal information are those who require access in order to fulfill their mandate with us.

Please note that your personal information may be sent to or accessed in another jurisdiction (including outside your province) for processing or storage by us or our Canadian, US or other foreign service providers. While being processed or stored in another jurisdiction, your personal information may be accessed by the courts, law enforcement and national security or other government authorities in that jurisdiction.

We have established policies and procedures designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.

10. Your Rights and Choices

Subject to applicable law, you may have the right to access, update, rectify, correct inaccuracies in, port and withdraw consent to our collection, use and disclosure of your personal information in our custody or control. You may make such a request by emailing or writing to us using the contact information set out under Contact Fig below. We may request certain personal information for the purpose of verifying your identity when you make a request. Note that if you withdraw or vary your consent, we may not be able to provide you with the products and services you have requested.

1. Your Rights in Automated-Decision Making: Subject to applicable law, when we provide you with a decision regarding your loan application, you may have the right to request additional information about the personal information used and the reasons and principal factors and parameters that led to the decision. You may also request corrections to the personal information used, to the extent these corrections provide true, accurate and complete information and do not misrepresent your identity or account information. If you disagree with the outcome of a decision, you may submit your observations to support@fig.ca , and a member of our team will review your application.

11. Updates to this Privacy Statement

We may update this Statement to reflect changes in our practices or legal and regulatory obligations. In such cases, we will post an updated version of this Statement here. We encourage you to review this Statement from time to time to ensure you are familiar with those changes.

12. Information About Our Privacy Governance Policies and Practices

We are committed to protecting personal information and have implemented policies and practices that govern our treatment of personal information. These policies and procedures include:

1. a framework governing the retention and destruction of personal information for compliance with our legal obligations, including the destruction of personal information once no longer required;
2. policies and procedures concerning the protection of personal information in our custody and control from unauthorized access, use or disclosure;
3. the designation of a Privacy Officer who is responsible for overseeing Fig’s compliance with applicable privacy legislation;
4. regular privacy training and awareness for our personnel with access to personal information.

13. Contact Fig

If you have any questions about this Statement or wish to contact us regarding your rights and choices or the manner in which we and our service providers (including our service providers outside of Canada) treat your personal information, please contact our Privacy Officer, who oversees compliance with our privacy program, using the contact information below.

1. Fig Financial Inc.
   Attention: Privacy Officer
   630
   René-Lévesque West, Suite 1400
   Montréal (Québec) H3B IS6
   1-888-638-2274
   Privacy@fig.ca