Effective Date: 15-02-2021

Last Updated: 27-01-2025

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Introduction

This Privacy Policy governs the manner in which Purocredit Inc. ("we," "our," or "us"), as a financial institution, collects, uses, maintains, and discloses information collected from users (each, a "User" or "you") of the www.purocorp.com website ("Site") and through our financial services. This privacy policy applies to the Site, our financial services, and all related products offered by Purocredit Inc.

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1. Information Collection

1.1 Personal Identification Information

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We may collect personal identification information from Users in various ways, including, but not limited to:

• When Users visit our Site
• Register for an account
• Apply for financial products or services
• Conduct transactions
• Fill out forms
• Engage with other activities, services, features, or resources on our Site

The personal information we may collect, specifically for a financial institution, includes:

• Name
• Email address
• Mailing address
• Phone number
• Date of birth
• Social Security Number (SSN) or equivalent national identification number
• Financial information such as income, credit history, bank account details, transaction history, and investment portfolio details
• Employment information
• Government-issued identification (e.g., driver's license, passport)
• Beneficiary information
• Source of funds information

Users may visit our Site anonymously, but please note that using our financial services requires the submission of personal identification information. We will collect personal identification information only if Users voluntarily submit such information for the purposes of using our services. Users can always refuse to supply personal identification information, though this may prevent access to certain financial services and Site-related activities.

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1.2 Non-Personal Identification Information

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We collect non-personal identification information about Users whenever they interact with our Site, including:

• Browser name
• Computer type
• Technical information about Users' connection to our Site
• Operating system
• Internet service providers
• IP address
• Browsing history on our Site
• Device information
• Aggregated demographic information
• Other similar information

1.3 Web Browser Cookies

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Our Site uses "cookies" to enhance User experience. Users' web browsers place cookies on their hard drives for record-keeping purposes and sometimes to track information. We use cookies for:

• Essential cookies: To make our website function correctly.
• Performance cookies: To understand how you use our website and to improve user experience.
• Functionality cookies: To remember your preferences.
• Advertising cookies: To deliver targeted advertisements (if applicable).

Users may choose to set their web browsers to refuse cookies or to provide alerts when cookies are being sent. Please note that some parts of the Site may not function properly if cookies are disabled.

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2. Use of Collected Information

Purocredit Inc., as a financial institution, uses Users' information for the following purposes:

• Service Provision: To provide and manage financial products and services, including processing applications, transactions, and account management.
• Customer Service Improvement: To respond effectively to customer service requests and support needs, including resolving disputes and providing assistance.
• User Experience Personalization: To understand how our Users as a group use our services and to personalize user experience, including offering tailored financial advice or products.
• Site and Service Enhancement: To improve our website, financial services, and security measures based on feedback and information received and to develop new features and services.
• Transaction Processing: To process financial transactions, including deposits, withdrawals, transfers, and payments. This may involve sharing information with necessary outside parties, such as payment processors, banks, and other financial institutions, to facilitate service provision and as required by law.
• Compliance and Legal Obligations: To comply with applicable laws, regulations, and legal processes, including anti-money laundering (AML) and know your customer (KYC) obligations, fraud prevention, and responding to requests from regulatory authorities.
• Risk Management: To assess and manage financial and operational risks, including credit risk, fraud risk, and security risks.
• Content Administration: To manage content, promotions, surveys, and other Site features, including providing relevant financial news and updates.
• Communication: To send information Users have agreed to receive, including service updates, policy changes, marketing communications (where permitted by law and with consent), and important account notifications.
• Analytics and Research: To conduct data analysis, research, and develop insights to improve our services and understand market trends

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2.1 Email Communications

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The email address Users provide for account registration and transaction processing will be used to:

• Send information and updates about accounts and transactions.
• Respond to inquiries, requests, or questions.
• Send important service announcements and policy updates.
• Send company news, updates, and related financial information (if opted-in, where applicable).
• Send marketing communications about financial products and services (if opted-in, where applicable and compliant with marketing regulations).

Users can unsubscribe from marketing emails at any time using the instructions at the bottom of each email or by contacting us. Please note that you may still receive essential service-related communications even if you unsubscribe from marketing emails.

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3. Data Protection

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We implement robust data collection, storage, and processing practices and security measures specifically designed for a financial institution to protect against:

• Unauthorized access
• Alteration
• Disclosure
• Destruction of personal and financial information, username, password, transaction data, and other sensitive stored data

Our security measures include, but are not limited to:

• Encryption: Using strong encryption for data in transit and at rest, including SSL/TLS secured communication channels and encryption of sensitive data like passwords and financial details.
• Firewalls and Intrusion Detection Systems: Implementing firewalls and intrusion detection systems to prevent unauthorized access to our systems.
• Access Controls: Restricting access to personal and financial information to authorized personnel only, based on the principle of least privilege.
• Regular Security Audits and Vulnerability Assessments: Conducting regular security audits and vulnerability assessments to identify and address potential security weaknesses.
• Employee Training: Providing regular training to employees on data protection best practices and security protocols.
• Physical Security: Implementing physical security measures to protect our data centers and systems.
• Digital Signature Encryption: Utilizing digital signature encryption for transaction verification and data integrity.
• PCI DSS Compliance: Maintaining compliance with the Payment Card Industry Data Security Standard (PCI DSS) if we process credit card information.
• Multi-Factor Authentication (MFA): Implementing MFA for user account access to enhance security.
• Data Minimization and Retention Policies: Retaining personal and financial information only for as long as necessary for the purposes outlined in this policy and in accordance with legal and regulatory requirements.
• Incident Response Plan: Having a documented incident response plan to address data breaches or security incidents effectively.

4. Third-Party Websites and Services

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4.1 Third-Party Links

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Our Site may contain links to third-party websites, including financial service providers and partners. We are not responsible for the content or privacy practices of these sites. We encourage Users to review the privacy policies of any third-party sites they visit.

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4.2 Advertising

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We may use third-party advertising partners to deliver targeted advertisements on our Site or other platforms. These partners may use cookies and similar technologies to collect information about your interactions with our Site and other websites to provide you with relevant advertisements. This privacy policy does not cover advertisers' use of cookies and other tracking technologies. Users should review the privacy policies of these advertising partners for more information about their practices.

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4.3 Third-Party Service Providers

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We may engage third-party service providers to perform various functions on our behalf, such as payment processing, data analytics, customer service, and marketing. These service providers may have access to personal information necessary to perform their functions, but they are contractually obligated to protect the confidentiality and security of the information and to use it only for the purposes for which we disclose it to them.

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5. Sharing of Personal and Financial Information

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In addition to the uses described above, we may share personal and financial information with the following categories of recipients:

• Affiliates and Subsidiaries: We may share information with our affiliates and subsidiaries for business purposes, including providing integrated services and for marketing purposes (where permitted by law and with consent).
• Regulatory Authorities and Law Enforcement: We may disclose information to regulatory authorities, government agencies, and law enforcement officials as required by law or legal process, including to comply with AML and KYC regulations, respond to subpoenas, or cooperate with investigations.
• Financial Institutions and Payment Processors: We may share information with banks, payment processors, and other financial institutions to facilitate transactions and provide our financial services.
• Credit Bureaus and Reporting Agencies: We may share information with credit bureaus and reporting agencies as permitted or required by law, including for credit reporting and fraud prevention purposes.
• Debt Collection Agencies: In case of defaults or outstanding debts, we may share necessary information with debt collection agencies to recover amounts owed to us.
• Professional Advisors: We may share information with our professional advisors, such as lawyers, accountants, and auditors, for legal, financial, and compliance purposes.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, personal information may be transferred as part of the transaction, subject to applicable legal requirements.
• With User Consent: We may share information with third parties with your explicit consent.

We will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.

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6. Children's Privacy

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We comply with the Children's Online Privacy Protection Act (COPPA) and other applicable child protection laws:

• We do not knowingly collect or solicit personal information from children under the age of 13.
• Our website and financial services are not designed to attract children under 13.
• If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us at the contact information provided below.

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7. Data Retention

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We will retain your personal and financial information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including:

• To provide you with our financial services.
• To comply with applicable legal and regulatory obligations, such as record-keeping requirements for financial transactions.
• To resolve disputes and enforce our agreements.
• For fraud prevention and security purposes.
• For audit and compliance purposes.

Retention periods may vary depending on the type of information and the applicable legal and regulatory requirements. After the retention period expires, we will securely delete or anonymize your personal information in accordance with our data retention policies and applicable laws.

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8. Your Rights

Users have certain rights regarding their personal information, which may vary depending on your jurisdiction. These rights may include:

• Right to Access: You have the right to request access to the personal information we hold about you and to receive a copy of that information.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.
• Right to Erasure (Right to be Forgotten): In certain circumstances, you have the right to request that we delete your personal information.
• Right to Restriction of Processing: In certain circumstances, you have the right to request that we restrict the processing of your personal information.
• Right to Data Portability: In certain circumstances, you have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another controller.
• Right to Object: You have the right to object to the processing of your personal information in certain circumstances, such as for direct marketing purposes.
• Right to Withdraw Consent: If we process your personal information based on your consent, you have the right to withdraw your consent at any time.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a relevant data protection supervisory authority if you believe that we have infringed your data protection rights.

To exercise any of these rights, please contact us using the contact information provided below. We may require you to verify your identity before processing your request. Please note that there may be limitations to these rights, and we may not be able to fulfill your request in all circumstances, particularly when we are legally required to retain or process your information.

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9. Policy Updates

Purocredit Inc. may update this privacy policy at any time to reflect changes in our information practices, legal requirements, or service offerings. When we make changes, we will:

• Post a notification on the Site's main page or within your account dashboard.
• Update the policy's "Last Updated" date at the top of this policy.
• Send email notifications to registered users when significant changes are made, where appropriate.

We encourage Users to frequently check this page for any changes to stay informed about how we are protecting the personal information we collect. Your continued use of the Site and our financial services after the posting of changes constitutes your acceptance of the updated Privacy Policy.

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10. Your Acceptance

By using this Site and our financial services, you signify your acceptance of this policy. If you do not agree with this policy, please do not use our Site or financial services.

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11. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact our Data Protection Officer or Privacy Team at:

Purocredit Inc.
2135 de la Montagne
Montréal, Québec H3G 1Z8
Canada

Phone: 1-888-312-2843 / 514-388-9696
Email: privacy@purocorp.com (For privacy-related inquiries) or accounting@purocorp.com (General inquiries)
Website: www.purocorp.com

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