FACE is committed to safeguarding the personal information entrusted to us by our clients, and their representatives. This policy works together with the privacy provisions in the terms of any agreements with us as well.

FACE is responsible for the personal information it gathers and this Privacy Policy details the management of such information. FACE has designated staff members who are responsible for compliance with the mandate of the Privacy Policy as well as obligations under the Personal Information Protection and Electronic Documents Act (commonly known as PIPEDA).

By providing FACE with information, you are consenting to the collection, use and sharing of your information as set out in this Privacy Policy and as permitted or required by law. This Policy will continue to apply for as long as FACE holds your information, including after the termination of any of your product or service agreements with us.

Key Terms:

"Personal Information" constitutes information about an identifiable individual, which includes, but may not be limited to an individual’s name, home address and phone number, age, sex, marital or family status, financial information, and educational history. This information can be in any form including paper, electronic, audio, video or biometric, such as voiceprints, photographs and signatures. This information can also include information collected through digital activities, such as device model, browser type and IP address. Personal information, however, expressly excludes the name, title and business contact of the organization that an individual may be employed with.

“FACE Partners” means companies we have engaged with to provide products or services under, or to participate in, the various programs FACE offers from time to time. Examples of Program partners include chartered banks, credit unions and other financial institutions.

“FACE Programs” means the programs administered and/or offered to clients by FACE under which FACE clients receive specified products or services that are provided by FACE or FACE partners, such as for example, the Government of Canada program referred to as the “Black Entrepreneurship Loan Fund”.

Types of Personal Information we Collect

The type of personal information FACE collects depends on various factors, such as the type of products or services you request or use, and any applicable legal and regulatory obligations. Generally, the personal information FACE collects includes the following:

• Eligibility information to ensure that you qualify for a specific FACE Program such as race, gender, place of birth, citizenship, and language. Due to the sensitive nature of this type of information, eligibility information collected for this purpose will not be shared for marketing or loan assessment purposes and will not be shared with any FACE Partners.
• Contact information such as name, mailing address, telephone number, email, social media account name and fax number.
• Identification information such as government issued identification, date of birth, Social Insurance Number (SIN) and occupation.
• Financial information such as employment and financial payment history, income, net worth, credit reports and details of security provided for existing loans.
• Transactional information such as information on the various programs you participate in, the products or services you use, or how you otherwise do business with us.
• Other information such as location, demographics and interests and health and lifestyle information that we collect to understand our relationship with you by learning more about you, and what types of products, services or offers you may be interested in. Due to the sensitive nature of this type of information, this information will not be shared except on an aggregated and de-identified basis.

How do we collect information?

We may collect information from you directly, indirectly or from other sources, such as:

• information you provide us through our application process for FACE Programs
• communications with us
• credit bureaus
• references you have provided
• FACE Partners
• government institutions or regulatory authorities
• user-generated content on our social media websites such as photographs or comments you post
• public sources such as telephone directories, websites, or government agencies and registries or other public records.

Purpose of Collecting Personal Information

FACE is committed to delivering products and services that meet the specific needs of our clients. In order to do so, we collect personal information, clearly stating the purpose it is required for. The most common reasons for us to seek out your personal information may include:

• Determining eligibility of FACE Programs, products and services.
• Verification of identity and protection against fraud.
• Delivery of products/services.
• Seeking feedback and quality assurance on FACE Programs, products and services.
• Promotional information regarding FACE Programs, products, services and events.
• Surveys for program development / service enhancement.
• Compliance with audit and legal requirements.
• Any other purposes for which we have consent in accordance with applicable laws.

FACE may also be required to share your personal information with third parties, such as credit bureaus, credit insurers, registries and other lenders, for purposes such as verification and approval. As noted above, “eligibility information” will not be shared with FACE Partner lenders or used for marketing or loan assessment purposes.

FACE’s client service representatives may also seek your personal information for purposes such as identity verification, reference to past client interactions, creating a record of ongoing interaction, client service evaluation or to authorize any of the above purposes.

Consent To Procure And Use Information

FACE, upon collecting personal information, shall seek your consent to use and disclose the information. Consent is not mandatory and may be withdrawn at any time. However, please note that the lack of consent or withdrawal of consent may lead to FACE’s inability to provide you with products or services, or provide you these to the best extent possible.

FACE shall assume that consent towards the use and disclosure continues for the purpose for which the information is collected, until there is an express withdrawal of such consent.

Consent may be sought electronically (e.g. on our website/ web application, through checkboxes on web forms or other disclaimer statements), or orally (e.g. telephonically or in person) or in writing (e.g. by signing a form or checking a box on a form).

You are entitled to withdraw consent to the use and disclosure of personal information at any time, except towards the use of such information for the fulfillment of FACE’s legal obligations.

Consent shall be deemed not required in situations authorized by law. These may include instances of ongoing legal proceedings, emergencies threatening life, health and/or safety, or when personal information exists in the public domain.

Extent of Information Collected

FACE shall collect information only to the extent required, i.e. to the extent that ensures efficient delivery of FACE Programs, products and services requested by clients and any other consented purposes.

Extent of Use, Disclosure and Retention

The use, disclosure and retention of personal information is restricted to the purposes you agree to. FACE is required to seek your consent for each new use or disclosure of your personal information that falls outside the agreed purposes.

FACE will not license, assign or sell your personal information except as permitted by this Privacy Policy, or required by law, or with your consent. Third party service providers or contractors will be contractually restricted from using the personal information other than to carry out the contracted-for services.

In addition, FACE may share aggregated information with FACE Partners. The information however, shall not contain personal information, relatable to individual clients.

The length of time we keep your information will vary depending on the program, product or service as well as the type of information we have. We keep your information for as long as we reasonably need it for client service, legal or reasonable business purposes. For these reasons, we keep your information beyond the end of your relationship with us. When your information is no longer required, we securely destroy it or delete personally identifiable information.

Partners and THIRD PARTY PROVIDERS

FACE Program intake information processing is carried out using Mindful Connect API provided by Mindful connect inc. The collection, use and sharing of your information is also subject to their privacy terms which can be viewed by visiting https://getmindful .io/privacy. In addition to FACE, in some cases, information may be accessible to external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) that FACE engages to provide certain administrative services in support of FACE Programs and operations.

FACE may also use service providers to help us in aggregating personal information, which we may then share with third parties such as [research agencies and policy analysts NTD: are these appropriate], but such aggregated information will not contain personal information, relatable to individual clients.

Accuracy of Personal Information

Personal information shall be maintained in as accurate, complete and up-to-date manner as necessary to serve the purpose(s) consented. Any inaccuracies or changes to the information may be corrected by contacting FACE at our 1 (855) 560-FACE (3223) .

Safeguards

FACE shall make every reasonable effort to ensure that your personal information is secure and shall employ feasible physical, technological/electronic and organizational safeguards to fulfill this mandate. Examples of safeguards include: limited access to relevant information by authorized employees only, allowing safeguard through passwords or personal identification numbers (PINs) to your account, and use of firewalls and encryption technology for electronically stored and transmitted information.

FACE shall also prevent misappropriation of personal information by shredding paper records and permanently deleting electronic records, when necessitated.

FACE’s website may contain links to other third-party websites or pop-ups. The provision of links is for your convenience and does not constitute an endorsement, recommendation or approval of these other websites or organizations. You are responsible for the review of the privacy policies of any linked external sites and for making an informed decision as to whether or not you should provide any personal information to the site operators.

Access to Your Personal Information

Client of FACE reserve the right to review and verify their personal information, as well as seek clarification regarding, use, disclosure and protection of their personal information. Such an access to information request may be made in writing to:

Upon such a request, we may require you to provide sufficient information to verify your identity and to minimize the risk of an information breach. No fees are attached to purposes such as correction or change in information. However, in case your enquiry entails a fee, details of the same shall be communicated prior to processing your request.

If you have any concerns regarding compliance with the above principles, please contact us, including dispute resolution, communications activities and reporting to our management team.

Revisions to this Privacy Policy

This Privacy Policy may be revised from time to time, without prior notice, and the most current version shall prevail