Purposes for Which Enliven Handles Personal Information
Enliven collects and uses personal information for purposes limited to those which are required to fulfil the purposes of collection, which include providing you with mortgage brokerage services and financial services. We collect personal information primarily from you, for instance through applications and supporting documentation you provide. We may also collect personal information about you through your ongoing interactions with us, from references, employers and other financial institutions you have identified in your application as well as credit bureaus and other third party sources. For example, we may collect personal information from credit bureaus for the purpose of locating you to collect outstanding debts. In connection with loan agreements, we may also collect personal information from credit bureaus in order to verify your current and ongoing creditworthiness and other information you may provide to us.
We may collect personal information for purposes such as, but not limited to, the following:
- to manage and promote the business activities of Enliven;
- to verify identity and other information provided by customers and to determine eligibility for products and services;
- to respond to requests and queries you submit to us;
- to open, administer and service accounts and loans and to provide and administer any requested products or services;
- to evaluate current and ongoing creditworthiness and other requirements and to determine their eligibility or suitability for products or services offered by Enliven;
- to advertise, market and promote Enliven’s products and services to customers who have chosen to receive such communication, including by mail, email and telephone including the use of automatic dialers and announcing devices;
- to establish relationships, provide quality service to and communicate with customers;
- to collect outstanding debts;
- to protect the business interests of Enliven and its customers, including to detect and prevent fraud and other unauthorized or illegal activities;
- to maintain business records for reasonable periods to meet legal and regulatory record retention requirements; and for other purposes with your consent obtained at the time of collection or as permitted or required by law.
Personal Information Enliven Collects
Enliven limits the amount and type of personal information collected to that which is necessary for our identified purposes, and we collect personal information by fair and lawful means.
Personal information that we collect includes:
- customer name and contact information, including mailing address, telephone number, fax number and/or email address;
- additional information for identity matching and credit check purposes, such as occupation, name of employer, income information, assets and liabilities, names and contact information for references, assets, liabilities, income, previous address, number of dependents, Social Insurance Number (if provided), date of birth or driver’s license number;
- information about any account, loan or any other obligation that you may have, such as current and historical information, balance and indebtedness, account transaction history and similar information, and records relating to the handling of any inquiries or complaints;
- payment-related information, such as banking information; and such other information we may collect with your consent or as permitted or required by law.
Enliven does not solicit information of any kind from individuals under the majority in their jurisdiction of residence (“Minors”) without the required consent from their parents/guardians. If we become aware of any information we possess that may belong to a Minor, we will immediately obtain parental consent to delete this information from our servers. If you are a parent/guardian and you suspect that your child may have submitted personal information to us, please contact our Privacy Officer.
Transfers and Disclosures of Personal Information
Enliven may disclose 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 provide you with the products and services you request;
- to 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 withdraw consent, to Enliven to offer you additional products and services; to Enliven’s insurance partners or other lenders so that they may offer other products and services that may be of interest to you; and for other purposes with your consent or as permitted or required by law.
In addition to the above, personal information may be shared between our affiliates or subsidiaries (including those located in the United States and elsewhere) for audit, management, marketing, billing or administrative purposes including defending and bringing legal actions, or as required by law.
In the course of fulfilling the purposes described above, Enliven may transfer your personal information to service providers, including affiliates or other third party organizations or individuals retained by Enliven to perform functions on its behalf, such as marketing, data processing, customer service, office, security, collections, insurance, financial and taxation services. When personal information is transferred to service providers, we use contractual or other means to ensure that a comparable level of protection is provided. Some of our service providers may be located outside Canada and will be subject to applicable legal requirements in that country including lawful requirements to disclose personal information to government authorities in certain circumstances. If you have any questions about Enliven’s contracts with such service providers, please contact our Privacy Officer at the details provided below, and we can provide further information about our policies and practices regarding service providers located outside of Canada how these service providers, collect, use, disclose or store personal information on our behalf.
Enliven may disclose your personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law.
Safeguards and Retention
Enliven uses commercially reasonable technical, organizational and physical safeguards and other security standards to ensure that all personal information in its custody and control is protected against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. Safeguards will vary depending on the sensitivity, format, location, and storage of the personal information. Only authorized employees, agents, partners and third parties who require access to personal information to fulfill their job requirements will have access to personal information.
While we strive to ensure your information is safe with us, cybersecurity is nevertheless a challenge. We recommend all of our customers to routinely review their credit, change their passwords, and take all precautions necessary to prevent and minimize loss in the unlikely event of a security breach.
We will retain your personal information as long as reasonably required to complete our dealings with you, or as required to fulfill our record keeping obligations under law, whichever is longer. You can also request that we remove your personal information from our records by contacting our Privacy Officer at the contact information below. Subject to our requirements for continued retention of your information (i.e., auditing purposes) or to fulfill our legal obligations, we will make every reasonable effort to honour your request.
Access and Accuracy
Enliven may establish and maintain a file, in physical or digital format containing an individual’s personal information for the purposes described above, which will be accessible at our offices. Individuals have the right to request access to or correction of their personal information that is held by Enliven. Requests must be made in writing, addressed to Enliven’s Privacy Officer. We will respond to written requests within a reasonable time. Copies of records containing personal information may be subject to a reasonable fee.
We will use our best efforts to ensure that personal information is accurate, complete and up-to-date. If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information as required. If we refuse access to personal information or disagree with an assertion that information held by us is incorrect, we will provide a written explanation for such refusal. An individual’s right to access or correct personal information is subject to applicable legal restrictions. To prevent fraudulent access to the personal information stored by Enliven, we may take reasonable steps to verify your identity before granting access or making corrections. Originals if any, are not released unless as required or requested under appropriate regulations.
Enliven’s Websites and Email Communication
Enliven does not guarantee the confidentiality of any communications made by you via e-mail or otherwise through our websites. If you wish to provide information of a confidential or sensitive nature to Enliven, please contact us directly by telephone to arrange for delivery/transmission of such information by secure means.
In compliance with Google’s advertising policies, we use Google Adwords Search Engine Marketing (Pay Per Click) and Display Advertising (Remarketing and Google Display Network). We use Google AdWords Remarketing in compliance with the Google AdWords Interest-Based Advertising Policy, which means that you may see our advertisements on Google and other third party websites on the internet after visiting our website.
We use Google Analytics for Display Advertising, including Remarketing, Google Analytics Demographics and Interest Reporting, Google Display Network Impression Reporting and the DoubleClick Campaign Manager integration. You have the option to opt out of Google Analytics for Display for Display Advertising and customize Google Display Network ads. For all the currently available opt-outs, please visit https://tools.google.com/dlpage/gaoptout.
We use the data collected through Google Analytics Demographics and Interest Reporting to better understand our website visitors in terms of demographics and interests, to improve our website content in order to cater to our audience, and to customize advertisements based on our audience’s interests and demographics.
In certain circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual. These circumstances include but are not limited to: personal information that is publicly available as defined by regulation; where collection is clearly in the interests of the individual and consent cannot be obtained in a timely way; where disclosure is made for the purposes of collecting a debt owed to us; or to comply with a subpoena, warrant or court order.
Inquiries or Further Information
Privacy Officer, Enliven Financial Inc.
203-8525 Baxter Place,
Burnaby, B.C., Canada V5A 4V7
If you are not satisfied with our response to a privacy-related matter, you may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or at www.priv.gc.ca.
Please check back periodically for updates.
Last Updated: May 15, 2018