Youdge Privacy Policy

Date of Policy: [22/01/2025]
Last Updated: [22/01/2025]

Your privacy is important to us. We are committed to protecting and ensuring the confidentiality of any Personal Information you provide to us.

This Privacy policy ("Privacy policy") addresses how Youdge Projet Canada Inc., including its affiliates, subsidiaries and related entities (“Company,” “we,” “our,” “us,”) handles information it gathers from individuals visiting the Website (defined below) and Users (defined below) of the Company Services (defined below). This Privacy Policy describes the ways the Company collects, uses, discloses, or processes Personal Information.

Please read this Privacy Policy carefully. By using our Services, or otherwise providing us with your Personal Information, you are hereby consenting to Company’s collection, use, disclosure, communication or processing of your Personal Information in accordance with this Privacy Policy. If you do not consent to the practices described in this Privacy Policy, you may not continue to use our Services.

The Company has a separate privacy policy applicable to individuals in European countries. If you reside in Europe, you should refer to the applicable privacy policy for further details on the Company’s privacy policy and practices which is located at https://www.youdge.com/rgpd.

Content

Youdge Privacy Policy
1. Definitions
2. Our Services Are Not Intended for Minors
3. What Personal Information We Collect From You
4. What Personal Information We Get From Third Parties or Other Sources
5. How We Use Your Personal Information
6. How We Share Your Personal Information
7. How We Protect Your Personal Information
8. Automated Decision-Making
9. Our Data Retention Practices
10. Data Location and Data Transfers
11. Third-Party Links
12. Commercial Electronic Messages
13. Your Right to Withdraw Consent
14. Your Data Protection Rights
15. Your Credit Report Information
16. Changes to the Privacy Policy
17. Contact Us

Definitions

For the purposes of this Privacy Policy:

“Personal Information” means any information that relates to you and either identifies you directly or could be used to identify you with other information available.

“Services” means the Company’s credit brokering services simplifying access to loans through its platform and the use of the Website.

“Users,” “you,” “your” means a visitor of the Website or the user of the Company Services.

“Website” means https://cafr.youdge.com/ and https://caen.youdge.com/.

Our Services Are Not Intended for Minors

The Company's Services are intended for individuals who have reached the age of majority in their province of residence in Canada. By accessing or using the Services, you represent and warrant that you are of the age of majority. If you are under the age of majority, you must not access or use the Services. We do not knowingly collect information relating to minors. To the extent we discover that information about a minor was collected, we will take measures to delete such information. If you become aware that information about a minor was provided to the Company, please let us know and we will take steps to remove and delete such information.

What Personal Information We Collect From You

We may collect, use, disclose, communicate, or process your Personal Information when you interact with the Company or use the Services. This includes:

Financial and Credit Information

The Company will collect financial and credit information about you when you apply for credit, when you interact with the Company to obtain information about its products and services or when you become a customer. This Personal Information may include your first name, last name, address, birth date, email address, telephone number, financial information and information related to your credit needs, such as your monthly income, amount of loan required, and credit history.

Additional Information

Each customer’s personal and financial situation is unique. As a result, the Company may need to collect additional information from you to process your credit application and comply with applicable laws. This information may be used to confirm your identity, assess your loan or credit application, provide you with products and services catering to your unique circumstances, comply with applicable laws requiring specific information or documents about our customers, or handle complex cases where telephone calls or face-to-face exchanges may be required.

Log and Activity Information

We collect certain information automatically from Users navigating the Website or using the Services, such as Internet Protocol (IP) address and associated geolocation data, browser type, device model, device operating system, referring domains, timestamps (time a page was accessed as well as time spent on each web page), User clicks, visit duration, as well as the specific pages visited by the User.

Cookies

We collect certain information automatically using third-party cookies and similar technologies, including Bing Ads, ContentSquare, Meta Ads, Google Advertising Products, Google Analytics, Tik Tok, Insider, SalesForce and advertising networks. We will also collect certain User information automatically through the use of web beacons (to track the opening of emails or pages), pixels (for analytical and marketing purposes), and JavaScript tags (for interaction and provision of dynamic content). This information allows us to study navigation patterns on the Services, personalize our Services to you, and also detect and prevent fraudulent activities.

User Information

We store and process Personal Information in the context of providing the Website and Services, which may include login information, browser type and version, location, operating system, and similar information, as well as any Personal Information provided to the Company through the use of the Services.

Marketing and Communications

We collect, store, and process Personal Information that you provide when you communicate with us, including when you email us, call us, or send information to us through the Services. We also store and process your preferences in receiving marketing materials from us and your communication preferences.

Job Application

The Company may collect Personal Information when you apply for a job through the Website. The Personal Information may include, but is not limited to, contact details such as name, email address, mailing address, and phone number, employment-related information, including résumé or CV, cover letter, work history, and references, educational background, certifications, and qualifications, information provided during interviews or assessments, and any other details submitted as part of the application process. Your Personal Information is collected for the purposes of evaluating and processing job applications, communicating with you, and conducting recruitment activities. All Personal Information will be handled in accordance with this Privacy Policy and applicable laws.

Other

We also collect and use certain aggregate and anonymized information, such as statistical data regarding the use of our Services, for lawful purposes. For example, we may aggregate information to calculate the percentage of Users accessing specific Website features or using the Services in a certain way. The aggregated and anonymized information we use does not allow any individual to be identified.

What Personal Information We Get From Third Parties or Other Sources

We receive the following information from third parties and other sources:

Financial Information

The Company may receive your Personal Information from third parties to facilitate the provision of our Services. This may include information received from credit agencies and financial data providers, such as credit scores, payment history, credit history, or banking history to assess credit applications and finalize any credit or loan application.

Third-Party Data Brokers

The Company may receive aggregated information from third-party brokers or service providers to ensure user profiles are compatible with any financial product or service offered.

Public Sources

The Company may collect Personal Information about you from publicly available sources, such as public directories, government registries, publicly accessible websites, or social media networks. This information is used by the Company to provide you with the Services, including verifying your eligibility for credit, handling the credit approval process, verifying the legitimacy or authenticity of information disclosed to us, enhancing your customer profile, detecting inconsistencies in the information disclosed to the Company, to detect and prevent fraud, or other purposes related to the Company’s provision of its products and services. We may also use publicly available information to identify and contact prospective customers (in accordance with applicable law).

How We Use Your Personal Information

We use the Personal Information we collect from you for the following purposes:

Identity Verification

The Company may use your Personal Information to verify your identity as part of our efforts to provide you with the Services, maintain its security and integrity, and comply with various legal obligations. This may include confirming your identity when applying for credit, signing up to use the Services, or for any transactions that require the Company to verify your identity.

Providing Company Services

The Company may collect, use, and process Personal Information relating to Users as necessary to provide the Services. We may use your Personal Information to process credit applications or liaise with our financial partners to find you a suitable financial product or service. Your Personal Information may also be used to provide updates regarding the Services, feedback requests on the Services, security updates, customer support, and other activities related to the Services.

Support Services

The Company may use a User’s Personal Information to provide customer support services, over the phone, by email or through online chats, to assist with inquiries, technical issues, or other matters related to the Services. We may collect your first name, last name, email address, phone number, and any other information you may provide or that may be necessary for the Company to provide you with the necessary support services.

Improvement of Services

The Company may use Personal Information relating to Users to analyze Service usage patterns, gather feedback, and develop insights to improve the functionality, performance, and user experience of the Services. This may include refining existing features, developing new features, improving user experience (such as login and session management), and optimizing the overall operation of the Services.

Marketing and Promotion

Subject to your express consent, the Company may use Personal Information relating to you to further discuss your interest in the Services, or to send you information regarding the Company or its partners, such as information about new features, promotions and events or customized recommendations. We may also use your Personal Information to measure the effectiveness of our advertising campaigns. Please note that any use of your Personal Information for marketing and promotion purposes will be in accordance with your marketing preferences and consent choices. We may also email you with service-related information concerning the Services to the extent allowed by law and in light of the commercial relationship between us. You may opt out of receiving marketing materials at any time through the Services and adjust your marketing preferences or follow the unsubscribe instructions included in each marketing communication.

Security and Fraud Detection

The Company may use your Personal Information to detect, prevent, and respond to fraudulent activities or security threats. This includes monitoring for unauthorized access, mitigating potential risks, and ensuring the integrity and confidentiality of your Personal Information. For instance, some information obtained through cookies or automated tracking technologies allows us to detect unusual behaviours or patterns that could signal fraudulent activities.

Compliance with Our Policies

The Company may use your Personal Information when necessary to investigate any violation or suspected violation of its terms of Service or any policies applicable to the User.

Legal or Regulatory Compliance

Our Services are subject to certain laws and regulations, including those related to the provision of financial products and services such as credits and loans, which may require us to use your Personal Information. For example, we may use your Personal Information for compliance with laws and regulations governing the issuance of credit, tax purposes, to fulfill our business obligations, and as otherwise required by law. Without using your Personal Information for such purposes, we could not perform the Services in accordance with our legal and regulatory requirements.

Anonymization of Information

The Company may use anonymized Personal Information for internal reporting, market studies, analysis of market trends, and identification of business opportunities. The anonymization process ensures that the information cannot be linked back to any individual and is used solely to improve our understanding of the market, enhance our Services, and support strategic decision-making.

How We Share Your Personal Information

General

We share Personal Information, as necessary, in the following ways:

Within the Organization

Within the Company, your Personal Information may be accessible to personnel with a need to know the information in order to perform their duties. Depending on the type of Personal Information handled, this may include personnel in our customer team dealing with customers, customer applications, and after-sale services, customer support team, information technology (IT) and security team, product development and infrastructure maintenance team, legal and compliance team, management and administration, marketing and sales, and finance.

Financial Service Providers

In connection with our processing of credit applications, the Company uses third-party service providers to obtain credit scores, payment history, credit history, or banking history to assess credit applications, finalize any credit or loan application, or propose offers adapted to the unique needs of a customer. The Company may share your Personal Information, including financial information such as your income, desired credit, credit history, or other, with such third-party financial service providers along with any information allowing your identity to be verified.

Third-Party Service Providers

The Company may share your Personal Information with various third-party service providers. These providers include:

• Website hosting providers, who process information collected through the Website, in order to provide and improve the Website and manage website security.
• Data storage providers, who may process all information we collect and store in the course of providing, troubleshooting and managing our data storage solutions.
• Analytics and reporting service providers, who may process User information such as registration, credit and anonymized or aggregated data in order to provide analytical insights to help us understand and develop our business.
• Marketing service providers and campaign managers, who may process your registration, marketing and communications data (including contact information and marketing preferences) in order to help facilitate our marketing campaigns.
• Customer support tool providers, who process your registration data, credit, financial, marketing and communications data in order to help provide customer support to you.

These service providers are subject to confidentiality and security agreements and are required to agree to use the Personal Information of Users for the purpose of providing their services to us, to keep the Personal Information secure, and otherwise to handle Personal Information in the same manner as provided in this Privacy Policy, as required by applicable laws.

Affiliates and Related Companies

From time to time, we may provide your Personal Information (including identity, financial and technical data) to our affiliates, subsidiaries and other entities within the Company group of related entities so that those entities may assist us in providing the Services to you, align business strategies, and develop new products and services.

Potential Acquirers

If the Company is involved in a merger, acquisition or asset sale (each a “Transaction”), some or all of the Company Users' Personal Information may be disclosed or communicated for the purposes of evaluating or carrying out the Transaction. In such a case, the other party will be instructed to handle the Personal Information as required by applicable law and Users will be notified when required by applicable laws.

Law Enforcement

We may be required in certain circumstances to disclose or communicate your Personal Information in response to a lawful request by public authorities, courts, law enforcement, or to comply with national security requirements, or as otherwise required by the applicable law. To the extent allowed by applicable law, we will notify you before a disclosure or communication is made.

Consent

We may disclose or communicate your Personal Information with third parties where we have your consent to do so, except as otherwise prohibited by law.

How We Protect Your Personal Information

We protect your Personal Information with industry-standard administrative, technical, organizational, and physical security measures. These measures are intended to protect our Users' Personal Information against accidental or unlawful destruction, loss, and alteration, as well as against unauthorized disclosure, communication and access. We use standard industry practices to protect Users’ Personal Information, including data encryption of all sensitive information in transit and at rest, multi-factor authentication mandatory for all access to Company systems, continuous monitoring and use of tools to detect and respond to security incidents, restricted access policy where access is granted based on the needs of the Company personnel, staff training to provide awareness of data protection best practices, firewalls, SSL encryption, and system redundancies.

However, perfect security does not exist, and we cannot guarantee the absolute security of your Personal Information. We have procedures in place to address any actual or suspected security breach and will notify you and any applicable regulator of a breach involving your Personal Information, as required by applicable law.

The Company is committed to protecting your Personal Information and has established governance policies and practices to ensure its security and proper management throughout its life cycle. Our governance policies and practices include:

• Framework for Retention and Destruction: Guidelines for the secure retention and destruction of your Personal Information, ensuring that it is kept only for as long as necessary for the purposes for which it was collected or as required by law.
• Roles and Responsibilities: Clearly defined roles and responsibilities for our personnel to safeguard your Personal Information at every stage of its life cycle, from collection to destruction.
• Complaint Process: A transparent process for handling complaints regarding the protection of your Personal Information, ensuring that concerns are addressed promptly and effectively.

Our Privacy Officer has overall responsibility for our compliance with applicable privacy laws, including the responsibility for (i) the day-to-day administration and implementation of our privacy program, such as developing and delivering privacy training to relevant personnel, establishing and publishing relevant policies and procedures, investigating and responding to complaints and potential violations of our privacy policies or relevant laws, responding to requests from individuals to exercise their rights under applicable privacy laws, and (ii) regularly reviewing and identifying opportunities to improve our privacy program, and preparing a written information security program, assisting with breach prevention, response and containment, and evaluating and implementing information security controls.

In addition, all our personnel are responsible for:

• Protecting the confidentiality and security of any Personal Information they handle in connection with their employment or engagement.
• Following our security measures and policies and procedures for handling personal information.
• Refraining from any unauthorized access, use or disclosure of personal information.
• Facilitating data subject requests.
• Reporting security or confidentiality incidents.

These above policies and practices are proportionate to the nature and scope of our activities performed and are reviewed and approved by our designated Privacy Officer, who is responsible for the protection of your Personal Information. As required or deemed appropriate, our Privacy Officer may delegate certain functions to other members of the Company personnel.

Automated Decision-Making

The Company does not render any credit decisions about you or use your Personal Information to make any decisions based exclusively on the automated processing of the same. However, the Company may work with service providers, such as financial services providers, who may use your Personal Information to make decisions based exclusively on automated processing of such information. In the event we are informed that decisions exclusively based on the automated processing of your Personal Information (i.e., without any human intervention) were rendered by our service providers about you and that may affect your rights, we will inform you accordingly.

Upon request, you may obtain:

• Information about the Personal Information we provided to the service providers rendering a decision about you.
• An explanation of the reasons and the principal factors and parameters that led to their decision to the extent we are informed of the same.
• Assistance to correct any Personal Information we provided the service providers rendering a decision, if necessary.

In addition, you have the right to submit your observations to the Company for the review of a service provider’s decision and we shall transmit the same to the relevant service provider. This process ensures that your concerns are taken into account, and a decision made about you may be reviewed as needed. To exercise your rights regarding automated decision-making, please contact us at data@youdge.com.

Our Data Retention Practices

We retain Personal Information to render the Services to you and for as long as we have an ongoing legitimate business need to do so or are required by law. For example, we will retain your Personal Information for the period of time required to provide you with the Services, to comply with applicable legal, contractual, tax or accounting requirements, or to defend ourselves from possible legal actions. To the extent the purpose for which we have collected your Personal Information is achieved and we have no ongoing legitimate business need or legal obligation to retain your Personal Information, we will destroy it or anonymize it in accordance with applicable laws.

Data Location and Data Transfers

The Company will disclose your Personal Information to its service providers that may be located outside of Canada. For example, the Company uses Google Cloud for its web hosting services, and SalesForce and Insider for its customer relationship management services. These entities are located outside of Canada.

Third-Party Links

The Website or Services may contain links to third-party websites, plug-ins and applications. Clicking those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins and applications and are not responsible for their privacy statements and practices. When you leave the Website or our Services, we encourage you to read the privacy policy of every website you visit.

Commercial Electronic Messages

We will ask for your express consent to collect your Personal Information for the purpose of sending you commercial electronic messages. For example, when you sign up for the Services or complete a credit application, we will ask you for such consent. To ensure compliance, we will keep a record of your consent to this effect, including the date, time and method of consent in order to comply with applicable legislation. You have the right to refuse to provide consent or withdraw your consent to receive commercial electronic messages in case you change your mind. To withdraw your consent, you can adjust your account parameters to reflect what is suitable for you, or you can click the "unsubscribe" link in our commercial electronic messages, enabling you to withdraw your consent easily and immediately.

Your Right to Withdraw Consent

You have the right to withdraw your consent at any time for purposes that are unrelated to the provision of the Services, such as commercial electronic communications, marketing and promotion, personalized advertising, or any other purposes that are not essential for the rendering of the Services to you. You may withdraw consent via your account settings or by written request. To withdraw consent to marketing messages, you can unsubscribe by following the link in each message.

Your Data Protection Rights

You can exercise any one of the following privacy rights as may be available to you under applicable law by contacting our Privacy Officer using the contact information listed below. In certain jurisdictions, we may need to verify your identity before responding to your request. Depending on your jurisdiction, you may have the following data protection rights:

• The right to access, correct, update or request deletion of the Personal Information we collect about you.
• The right to opt out of marketing communications, even if you have previously consented to receiving them. You may opt out at any time.
• The right to request a portable copy of your Personal Information.
• The right to de-indexation, re-indexation or cessation of dissemination of your Personal Information.

if we have collected and processed your Personal Information with your consent, then you may have the right to withdraw your consent. See the section on withdrawing consent above.

Your Credit Report Information

Depending on the nature of the Services, the Company may consult your credit reports prepared by third-party credit reporting agencies or may receive credit scores as to your solvency in order to process your credit application. Please note that you have the right to access the information held by the credit reporting agencies and have your information corrected or rectified. You can contact the credit reporting agencies as follows:

Equifax Canada Co.

National Consumer Relations

Box 190
Montreal, Quebec H1S 2Z2

Phone: 1-800-871-3250

Website: https://www.consumer.equifax.ca/personal/

TransUnion

Attention: Consumer Relations Department

P.O. Box 338, LCD1
Hamilton, Ontario L8L 7W2

Phone: 1-800-663-9980

Website: ocs.transunion.ca

Upon request, the Company will communicate to you the content of any credit report it has received or consulted, or any credit scores obtained, for the purpose of processing your credit application, where required. Furthermore, upon your request, the Company will also inform you if the refusal of your credit application by its service providers, the refusal by its service providers to extend additional credit to you, the entering into a credit contract by its service providers with less advantageous conditions, or the increasing of your credit by its service providers with less advantageous conditions were based on the consultation of your credit report, to the extent the said information has been made available to the Company by the relevant service providers.

Changes to the Privacy Policy

This Privacy Policy may change from time to time, as reflected in the revision date above, to reflect changing legal, regulatory or operational requirements.

Where required by law, the Company will provide notification of material changes to this Privacy Policy through the Services at least thirty (30) business days prior to the change taking effect. Where appropriate, we may also email Users who have opted to receive communications from us notifying them of changes to this Privacy Policy. If we are required by applicable laws to obtain your consent to any material changes to this Privacy Policy, we will do so before such changes take effect.

Your continued use of the Services after we make changes constitutes deemed acceptance of these terms.

Contact Us

If you wish to exercise any of your privacy rights, such as access rights, the right to correct or delete your Personal Information, get a portable copy of your Personal Information, exercise any other privacy right, ask any questions, including about this Privacy Policy, or file a complaint regarding the handling of your Personal Information, you can contact our Privacy Officer using the contact information below:

Name: Mr. Frédéric ROY

Company: Youdge Projet Canada Inc.

Address: 14 Place Marie-Jeanne Bassot, 92300 Levallois-Perret

Email: data@youdge.com

We will respond to your request as soon as possible but no later than within thirty (30) days from the receipt of your request. Should we require additional information to be able to respond to your request, we will notify you as soon as possible. Furthermore, in the event we are unable to respond to your request for whatever reason, we will be sure to inform you in writing.

Please note that all requests received by the Company are documented and archived to ensure traceability and to ensure compliance with any applicable law.