Factiiv Inc. and its affiliates (“Factiiv,” “we,” “us,” “our”) respect
privacy, and the security of your personal information (“Personal Information”) and business information (“Business Information”) (collectively, “Information”) is important to us. We protect your Information by maintaining physical,
organizational, and technological safeguards appropriate to the sensitivity
of the Information. Except as stated herein, Information may only be accessed
by persons within our organization and other authorized third parties who
require such access to provide you with the Services.
This Privacy Policy describes how Factiiv processes Information that we
collect through the Factiiv Platform.
We collect the Information when you use the Factiiv Platform or when you
provide it to us through other means (such as when you contact us,
register a Factiiv Account or connect a bank account to your Factiiv
Account). Without the Information, we would be unable to provide you
with all the Services provided by the Factiiv Platform. This information
includes
Contact Information, Account, Profile Information such
as your first name, last name, phone number, date of birth, home address,
email address, and residency status, some of which will depend on the services
you use.
Identifiers. Government-issued identifiers, such as an
employee identification number (EIN) and other state-issued identification
numbers, as well as other unique identifiers such as those associated with
your device.
Identity Verification, Background Checks, and Payment Information such as images of your government issued ID (as permitted by applicable
laws), your ID number or other verification information, any
background checks relevant to your use of the Factiiv Platform, occupation,
name of employer, previous addresses, social insurance number, bank account
or payment account information, information regarding your debts, income
and finances, recordings of your communications with us and your transaction
history.
Credit Informationsuch as information from any credit reporting agency, information
about your financial products, financial and credit history, your
credit report and your credit score.
Commercial information. Information regarding products or services you have purchased or
considered purchasing, or other purchasing or spending histories or
tendencies.
Payment information. Information required to process payments directly to Factiiv,
such as your payment card information including its account number
and associated security code.
Inferences drawn from data.
Profiles or scores developed using your data which reflect your
preferences, characteristics, or consumer spending profile.
Public records information. Information about you lawfully made available by federal, state,
or local governments. This includes information about legal
proceedings in court records, business ownership and affiliation
information included in secretaries of state filings.
Internet or other similar network activity.
Information regarding your browsing history, search history,
and information about how you interact with our websites,
applications, advertisements, or emails.
Device information. Information about the devices you
use to access our websites, applications, or advertisements, such as browser,
operating system type, device ID, and IP address. Your IP address may be
used to identify the general geographic location of your device.
Other Information.Such as any other information that
is necessary for our identified purposes set out below and that is
collected hereunder or as permitted by law.
You may choose to provide us with additional information. This
information may include:
Additional Profile Information such as gender or preferred
language, or any other field that is not a required field during your Factiiv
Account setup or for a subscription plan (please see Terms of Service for more information). Please note that none of this information will
be publicly available.
Other Information such as when you fill in any forms,
add information to your Factiiv Account, respond to surveys, participate
in promotions, communicate with us, or share your experience with us. This
may include financial information if required to approve your Plan or if
you choose to share it with us.
When you use the Factiiv Platform and the Services, we automatically
collect the Information that is sent to us by your web browser. We use
this information to better understand how users use the Factiiv
Platform, and to improve the Factiiv Platform to better meet your needs.
The amount of information sent to us by your web browser depends on the
browser and the settings you use. Please refer to the instructions
provided by your browser if you want to learn more about what
information it sends to websites you visit, or how you may change or
restrict this. This information may include:
Geo-location Information such as precise or approximate
location determined from your IP address or mobile device’s GPS depending
on your device settings.
Usage Information such as the pages or content you view,
searches you have performed, and other actions on the Factiiv Platform.
Log Data and Device Information such as details about
how you’ve used the Factiiv Platform (including if you clicked on
links to third party applications or vendors), IP address, access dates
and times, hardware and software information, device information, device
event information, unique identifiers, crash data, cookie data, and the
pages you’ve viewed or engaged with before or after using the Factiiv
Platform. We may collect this information even if you haven’t created
a Factiiv Account or logged in.
Cookies and Similar Technologies
such as text files with small pieces of data, such as your username
and password, that are used to identify your computer as you access
and use the Factiiv Platform. The Factiiv Platform uses
“cookies” and other technologies to enhance your online
experience, including personalizing the content that you see on the
Factiiv Platform. Most web browsers can be set to disable the use of
cookies. However, if you disable cookies, you may not be able to
access certain features on the Factiiv Platform. We never place
Information in any cookies.
Payment Transaction Information such as payment instrument
used, date and time, payment amount, payment instrument expiration date
and billing postcode, banking email address, your home address, and other
related transaction details.
We collect Information from other sources, such as:
Your customers.Your customers provide us with data
when you provide them with products and services.
Third-Party Services. If you link, connect, or login
to the Factiiv Platform with a third-party service, you direct the
service to send us information such as your registration and profile
information as controlled by that service or as authorized by you.
Credit Reporting Agencies.When you register for a
Factiiv Account, we may, with your prior consent, obtain a credit
report and any related information from a credit reporting agency to
process and fulfil our Services. This information may also be used to
update your information on file, and you agree that we have your prior
consent to share this information with our partners and other third
parties in accordance with this Privacy Policy for any legitimate
purpose associated with the provision of Services to you.
Background Information. To the extent permitted by
applicable laws and with your consent where required, we may obtain
the local version of police, background, or other checks. We may use
your information, including your full name and date of birth, to
obtain such reports.
Invited Clients. If you are invited to the Factiiv
Platform by another Client, the Client that invited you can submit
Information about you such as your name, email address or other
contact information.
Other Sources. To the extent permitted by applicable
law, we may receive additional information about you, such
as references, demographic data or information to help detect
fraud and safety issues from third-party service providers and/or
partners and combine it with information we have about you. For
example, we may receive background check results or fraud warnings
from identity verification service providers for use in our fraud
prevention and risk assessment efforts. We may receive information
about you and your activities on and off the Factiiv Platform, or
about your experiences and interactions from our partners.
enable you to access the Factiiv Platform and make and receive
payments,
supply you with requested services,
approve Factiiv Accounts,
enable you to communicate with us and our partners,
perform analytics, debug, and conduct research,
provide customer service and respond to your inquiries,
send you messages, updates, security alerts, and account
notifications,
verify identity and other information submitted by you or any third
parties, for fraud detection and prevention,
facilitate account, billing, credit, and collection,
personalize and customize your experience based on your interactions
with the Factiiv Platform, your usage history, your profile
information and preferences, and other content you submit, and
to carry out any other purposes that are disclosed to you and to which
you consent.
detect and prevent fraud, spam, abuse, security and safety incidents,
and other harmful activity,
provide customer service,
conduct security investigations and risk assessments,
verify or authenticate information provided by you,
conduct checks against databases and other information sources,
including background or police checks,
comply with our legal obligations, protect the health and well-being
of our employees and Clients, and of the public,
resolve disputes,
enforce our agreements with third parties,
comply with law, respond to legal requests, prevent harm, and protect
our rights (see section 4.2),
perform quality assurance checks,
enforce our Terms and other policies, and
conduct profiling based on your interactions with the Factiiv
Platform, your profile information and other content you submit to
Factiiv, and information obtained from third parties, in connection
with the activities above.
send you promotional messages, marketing, advertising, and other
information based on your preferences and social media advertising
through social media platforms,
personalize, measure, and improve our advertising,
administer promotional programs, rewards, surveys, sweepstakes,
contests, or other promotional activities or events sponsored or
managed by Factiiv or its third-party partners,
analyze characteristics and preferences to send you promotional
messages, marketing, advertising, and other information that we think
might be of interest to you, and
invite you to events, and other relevant opportunities.
detect and prevent money laundering, fraud, abuse, identity theft and
security incidents,
conduct security investigations and risk assessments,
comply with legal obligations,
enforce the Terms and other payment policies,
with your consent, send you promotional messages, marketing,
advertising, and other information that may be of interest to you
based on your preferences and,
We may share the Information with third parties, such as our third-party
vendors or when authorizing a third-party application or website to
access your Factiiv Account or participating in promotional activities
by Factiiv partners or third parties.
Where permissible with applicable law, we may use certain information
about you, such as your personal information, transaction data and
credit data, de-identify it (where required by applicable law), and
share it with social media platforms, to generate leads, drive traffic
to Factiiv or otherwise promote our products and services, and
third-party resellers, to deliver data and products or access personal
data and Collective Content.
To help facilitate the provision of our Services, we may need to share
certain information such as when a subscription plan has been approved
and finalized or cancelled, certain information may be shared between
our partners and third-party vendors, including name, home address,
phone number, email address, banking information, credit history, and
other information you choose to share and submit to Factiiv.
We may disclose your information to courts, law enforcement,
governmental or public authorities, tax authorities, or authorized third
parties, if and to the extent we are required or permitted to do so by
law or where disclosure is reasonably necessary: (i) to comply with our
legal obligations, (ii) to comply with a valid legal request or to
respond to claims asserted against Factiiv, (iii) to respond to a valid
legal request relating to a criminal investigation to address alleged or
suspected illegal activity, or to respond to or address any other
activity that may expose us, you, or any other of our users to legal or
regulatory liability, (iv) to enforce and administer
our agreements with Clients, or (v) to protect the rights,
property or personal safety of Factiiv, its employees, its Clients, or
Clients of the public. For example, if permitted due to the forgoing
circumstances, Client tax information may be shared with tax authorities
or other governmental agencies.
Where appropriate, we may notify Clients about legal requests unless:
(i) providing notice is prohibited by the legal process itself, by court
order we receive, or by applicable law, or (ii) we believe that
providing notice would be futile, ineffective, create a risk of injury
or bodily harm to an individual or group, or create or increase a risk
of fraud upon or harm to Factiiv, our Clients, or expose Factiiv to a
claim of obstruction of justice.
For jurisdictions where Factiiv facilitates the collection and
remittance of taxes where legally permissible according to applicable
law, we may disclose Client’s information about transactions,
services provided and taxes to the applicable tax authority, such as
names, addresses, transaction dates and amounts, tax identification
number(s), the amount of taxes received (or due) by Client, and contact
information.
Some or all the Information we collect may be stored or processed in
jurisdictions outside Canada. As a result, this Information may be
subject to access requests from courts, law enforcement, governmental or
public authorities, tax authorities or authorized third parties in those
jurisdictions according to laws in those jurisdictions.
We retain personal information that we collect only as long as necessary
for the purposes for which it was collected or to meet legal
requirements (see Section 6.3). We destroy personal information when it
is no longer needed.
We may share Information with affiliated and unaffiliated service
providers to help us run our business, including service providers that
help us: (i) verify your identity or authenticate your identification
documents, (ii) check information against public databases, (iii)
conduct background or police checks, fraud prevention, and risk
assessment, (iv) perform product development, maintenance and debugging,
(v) allow the provision of the Factiiv Services through third-party
platforms and software tools (e.g., through the integration with our
APIs), (vi) provide customer service, advertising, or payment services,
(vii) process, handle or assess insurance claims or similar claims, or
(viii) otherwise help manage or deliver our Services. These providers
have access to the Information to perform these tasks.
If Factiiv undertakes or is involved in any merger, acquisition,
reorganization, sale of assets, bankruptcy, or insolvency event, then we
may sell, transfer, or share some or all of our assets, including your
information in connection with such transaction or in contemplation of
such transaction (i.e., due diligence). In this event, we will notify
you before your Information is transferred and becomes subject to a
different privacy policy.
We may review, scan, or analyze your communications on the Factiiv
Platform for reasons outlined in Article 3 of this policy, including
fraud prevention, risk assessment, regulatory compliance, investigation,
product development, research, analytics, enforcing our Terms of Service, and customer support purposes. In some cases, we may also scan,
review, or analyze messages to debug, improve, and expand product
offerings. We use automated methods where reasonably possible.
Occasionally we may need to manually review communications, such as for
fraud investigations and customer support, or to assess and improve the
functionality of these automated tools.
Parts of Factiiv may integrate with or link to third-party services, not
owned or controlled by Factiiv, such as TransUnion. Use of these
services is subject to the privacy policies of those providers. Factiiv
does not own or control these third parties and when you interact with
them you are providing the Information to them.
You can exercise any of the rights described in this section consistent
with applicable law. Please note that we may ask you to verify your
identity and request before taking further action on your request.
You can access and update some of your Information through your Factiiv
Account settings. You are responsible for keeping your Information up to
date. You can request a correction to your Information if you believe it
is inaccurate. If you submitted Information and would like to have
access to it, or if you would like to have it corrected, please contact
us using the contact information provided below.
In certain jurisdictions, you can request that your personal information
be deleted, or you may withdraw consent at any time. Please note that if
you withdraw consent or request the erasure of your personal
information:
We may retain your personal information as necessary for our
legitimate business interests, such as prevention of money laundering,
fraud detection and prevention, and enhancing safety. For example, if
we suspend a Factiiv Account for fraud or safety reasons, we may
retain information from that Factiiv Account to prevent that Client
from opening a new Factiiv Account in the future.
We may retain and use your personal information to the extent
necessary to comply with our legal obligations. For example, Factiiv
may keep information for tax, legal reporting, and auditing
obligations.
Information you have shared with others (such as reviews, comments,
and forum postings) may continue to be publicly visible on Factiiv,
even after your Factiiv Account is cancelled. Some copies of your
personal information (such as log records) may remain in our database.
Because we take measures to protect data from accidental or malicious
loss and destruction, residual copies of your personal information may
not be removed from our backup systems for a limited period of time.
While no organization can guarantee perfect security, we are
continuously implementing and updating administrative, technical, and
physical security measures to help protect your information against
unauthorized access, loss, destruction, or alteration.
Factiiv reserves the right to modify this Privacy Policy at any time in
accordance with this provision. If we make changes to this Privacy
Policy, we will post the revised Privacy Policy on the Factiiv Platform.
Changes to this Privacy Policy shall be effective upon posting, and you
understand and agree that if you use the Factiiv Platform after the date
on which the Privacy Policy has changed, Factiiv will treat your access
to or use of the Factiiv Platform as acceptance of the revised Privacy
Policy. If you disagree with the revised Privacy Policy, you may cancel
your Factiiv Account. If you do not cancel your Factiiv Account, your
continued access to or use of the Factiiv Platform will constitute
acceptance of and be subject to the revised Privacy Policy.
If you have any questions regarding this Privacy Policy or
Factiiv’s handling of your Information, please contact our Privacy
Officer at legal@factiiv.io.