Updated: April, 2017

Cash 4 You Corp. is committed to keeping your personal information confidential and secure. We are publishing this Privacy Policy to provide a comprehensive overview of our practices and procedures relating to the protection of personal information as well as its use, collection and disclosure.

This Privacy Policy outlines our commitment to you, and is designed to comply with applicable Privacy legislation in Canada, which incorporates the following ten principles. These guidelines have been customized to meet the specific needs and expectations of Cash 4 You customers:

1. Accountability
2. Identifying Purpose
3. Obtain Consent
4. Limit Collection
5. Limit Use, Disclosure and Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging compliance

Cash 4 You Corp. will continue to review this Privacy Policy to ensure it remains current with applicable Privacy legislation in Canada. In the event there are any changes to this Privacy Policy, a notice will be posted on www.cash4you.ca or at each Cash 4 You branch.

1. Accountability

Each and every one of our employees is responsible for maintaining and protecting the personal information to which they have access. We have strict policies and procedures for protecting personal information and designated individuals who are responsible for monitoring our compliance.

Cash 4 You Corp. has appointed an individual to be the Privacy Officer, who oversees privacy governance. On a day to day basis, the collection and processing of personal information is delegated to other employees within Cash 4 You Corp.

Cash 4 You Corp. is responsible for personal information in its possession or control and will use reasonable means to provide a proper level of protection for personal information, including when personal information is being processed by a third party.

Cash 4 You Corp. will disclose the title of the person(s) designated to oversee compliance with the Privacy Policy upon request.

Cash 4 You Corp. continues to develop and refine policies and procedures to protect personal information, receive and respond to complaints and inquiries, train employees and communication this information to customers.

2. Identifying Purposes

Cash 4 You Corp will identify the purposes for which personal information is collected at or before the time the information is collected.This information may be communicated orally, electronically or in writing.

When you become a Cash 4 You Corp. customer, or apply for additional products and services, we ask you for your personal information for the following purposes:

• To provide financial services to customers
• To verify your identity and protect against fraud
• To assess credit histories of customers
• To confirm details of customer employment
• To understand your financial service requirements
• To develop, manage and market products and services to meet the needs of customers
• To determine suitability of products and services for you
• To determine your eligibility for certain of our products and services, or those of others, and offer them to you
• To contact customers for products and services that may be of interest
• To collect a debt that may become owed to Cash 4 You Corp.
• To set up and manage products and services you have requested
• To comply with federal and provincial legal or regulatory requirements
• To record, track, and respond to customer feedback and complaints

Your personal information may be verified with credit bureau, credit insurers, registries, your employer, personal references and other lenders.

Cash 4 You will identify any new purpose(s) for which personal information is being collected, used or disclosed. Customers will be informed by posting a notice on the Cash 4 You website (www.cash4you.ca), written notification or direct communication.

3. Obtain Consent

When you apply for a new product or service, we ask you for your consent to collect, use or disclose your personal information. Cash 4 You Corp. will make a reasonable effort to ensure that all customers have an understanding of the purpose(s) for which personal information is collected, used or disclosed. Cash 4 You Corp. may also obtain consent to use and disclose your personal information after it has been collected, but prior to the personal information being used or disclosed for a new purpose. You may, at any time, withdraw your consent as long as:

• You provide reasonable notice
• We are not legally required to collect, use or disclose your information
• Withdrawing your consent does not impede our ability to fulfill your contract with us
• It does not relate to a credit product we have granted you where we are required to collect and exchange your personal information on an ongoing basis with credit bureaus, credit insurers and other lenders

Consent shall not be obtained through deception. An individual’s consent may be explicit or implied. Consent can be given either orally, electronically or in writing. Use of products and services offered by Cash 4 You Corp. constitutes implied consent for the collection, use and disclosure of personal information for all identified purposes.

Cash 4 You may collect, use or disclose personal information without the individual’s knowledge and consent in certain circumstances. For example:

• When the collection, use, and disclosure is permitted or required by law;
• When the collection, use, and disclosure are clearly in the interests of the individual and consent cannot be obtained in a timely manner;
• When seeking the consent of the individual may defeat the purpose of collecting the information;
• When use of the information is for an emergency that threatens the life, health or security of an individual;
• When needed to collect a debt, to comply with a subpoena, warrant or other court order, or as otherwise required or authorized by law;
• When the information is solely for Journalistic, Artistic, or Literary Intent; or
• The information is publicly available.

An individual may withdraw consent at any time subject to legal or contractual restrictions and reasonable notice. Refusal or withdrawal of consent by a customer may prevent Cash 4 You from providing a product or service to that customer. Cash 4 You will not unreasonably withhold products or services from a customer who refuses or withdraws consent, but if the personal information is required to offer the product or service, Cash 4 You may decline to deal with the customer who will not consent to the use of such personal information. Cash 4 You may be contacted for more information regarding the method by which consent can be withdrawn.

4. Limiting Collection

The collection of personal information is limited to that which is related to the identified purposes. Personal information will be collected by fair and lawful means. Most personal information will be collected directly from customers. Cash 4 You Corp. may collect personal information from sources such as credit bureaus, employers, personal references, or other third parties that represent they have the right to disclose such personal information.

5. Limiting use, disclosure and retention

Cash 4 You Corp. will only use or disclose your personal information for the reason(s) it was collected, except with the consent of the customer or as required by law.

Cash 4 You Corp. may use and disclose personal information to third parties. The purpose for using or disclosing the personal information is for:

• A Cash 4 You Corp. affiliate seeking information as an agent of the customer
• A Cash 4 You Corp. agent that will evaluate the customer’s creditworthiness or to collect a potential debt
• A credit reporting agency
• The issuer and or/or payer of negotiable items to confirm identity
• A third party (ies) where customer consents to disclosure
• A third party (ies) where disclosure is required by law
• A public authority or agent of a public authority where there is imminent danger to the life or property of a customer which could be avoided or minimized by disclosure; and
• Conduct surveys in order to enhance our products and services to meet customer needs.

Where we disclose your information to a third party they will be given only the information needed to perform the required services. We have contracts in place holding these companies to the same high standards of confidentiality by which we are governed.

Cash 4 You Corp. has policies in place that govern the retention of your personal information so it will be kept only for as long as it fulfills its intended purpose or as legally required.

6. Accuracy

We are committed to maintaining the accuracy of your personal information and ensuring that it is complete and up-to-date as is necessary for the purposes for which it is used. If you discover inaccuracies in our data, or your personal information changes, please notify the branch where you do business immediately, so that we can make the necessary changes.

7. Safeguards

Your personal information is secure, regardless of the format in which it is held. We have comprehensive security controls to protect against lost, theft, unauthorized access, duplication and disclosure of your personal information.

We have agreements and controls in place with third party service providers requiring that any information provided by us must be safeguarded and used only for the sole purpose of providing the service we have requested the company to perform.

The protection of personal information is an ongoing process, and Cash 4 You Corp. will update and review the reasonableness of the security safeguards as needed.

Cash 4 You Corp. will use reasonable security measures in the disposal of personal information.

Cash 4 You Corp’s Privacy Policy is available in our branches as a printed brochure. Our Privacy Policy outlines why we ask for your personal information, how it is used and who it may be shared or disclosed to. Contact information is also provided, so that you know who and where to address your questions or concerns.

8. Openness

Information is available to individuals regarding Cash 4 You’s policies and procedures relating to the management of personal information. Efforts have been made to make these policies and procedures understandable and easily available, either in written or electronic format. Cash 4 You will make the following information available:

• Means of gaining access to personal information held by Cash 4 You;
• A brief description of the type of personal information retained by Cash 4 You and a general account of its use; and
• A copy of any brochure or other information that explains Cash 4 You’s privacy policies and procedure

9. Individual Access

Upon written request, and within a reasonable period of time, a customer will be informed of the existence, use, and disclosure of his or her personal information and will be given access to that information. An individual is entitled to comment on the accuracy and completeness of his or her personal information, and have that information amended where appropriate. Cash 4 You will respond to an individual request within a reasonable time period and at a minimal cost to the customer. The information will be made available within 30 days of the request and the cost will vary with the type and amount of information requested. Individuals can seek access to their personal information by submitting a written request to the Privacy Officer as follows:

Privacy Officer
Cash 4 You Corp.
250 Dundas. St. S. Unit #10
Cambridge, ON, N1R 8A8
privacyofficer@cash4you.ca
www.cash4you.ca

We may need specific information from you to enable us to search for, and provide you with, the personal information we hold about you. The information will be made available within 30 days of the request. We may charge you a nominal fee depending on the nature of your request. However, we will advise you of the fee prior to proceeding with your request. Cash 4 You Corp. may not be able to provide access to any or all of an individual’s personal information. If a request for personal information is denied, Cash 4 You Corp. will notify the individual in writing, documenting reasons for refusal and resources available for redress.

• The personal information is unreasonably costly to provide
• The release of the personal information may threaten the life or security of a third party
• The personal information is subject to or generated in a formal dispute resolution process
• The personal information cannot be disclosed for legal, security or commercial proprietary reasons; or
• The personal information is subject to solicitor-client or litigation privilege

Cookies and Pixel Tags (www.cash4you.ca)

Cookies are small data files placed on a user’s computer by a website. They may store and transmit information to websites that users visit. www.cash4you.ca uses cookies on our website to:

• Help provide our on-line products and services to users
• Market those products and services
• Analyze the flow of traffic to our website
• Analyze and track the traffic of website users from page to page within our website

Third party vendors, including Google, may:

• Show our ads on websites on the internet
• Use cookies to serve ads based on a user’s prior visits to our website

Users may accept or decline cookies through the configuration settings of their web-browser. Users may also opt out of Google’s use of cookies by visiting the Google advertising opt-out page.

Pixel tags (or clear gifs) are small, transparent graphic images placed on a website or in an email that are not normally visible to the user. They provide non-identifiable information about your usage of the website. www.cash4you.ca uses pixel tags to:

• Note pages visited on our website
• Assist in the administration of affiliate accounts

10. Challenging Compliance

Individuals can address any challenge concerning compliance with the Privacy Policy to Cash 4 You’s designated Privacy Officer.

To contact the Privacy Officer at Cash 4 You:

Privacy Officer
Cash 4 You Corp.
250 Dundas. St. S. Unit #10,
Cambridge, ON, N1R 8A8.
privacyofficer@cash4you.ca
www.cash4you.ca

Cash 4 You will investigate all complaints. The customer will be informed of the outcome of the investigation regarding his or her complaint.

If the Privacy Officer is unable to satisfy the customer’s concerns, the customer may then refer to the Privacy Commissioner of Canada at 1-800-282-1376 or info@privcom.gc.ca and, if appropriate, file a written complaint with that office. However, the customer is encouraged to use Cash 4 You’s internal information and complaint procedures first.