Effective Date: January 1, 2022
This Privacy Policy is to inform you of how Fincentify Inc., operating as Nyble (“Fincentify,” “Nyble,”“we,” “us,”, “our”) on the policies and procedures on the collection, use and disclosure of your information when you use the Services we provide. This Privacy Policy applies to personal information we collect from you and from third parties, both online and offline.
We use your Personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
1. Personal Information We Collect and How We Use Them
Nyble collects and uses personal information for the purposes of providing our services, which includes providing overdraft protection, digital identity protection, financial wellness analysis and alerts, and leasing services for products to our customers. We collect personal information directly from you through your use of our platform, the application you submit, and through our interactions with you.
We collect and use personal information for purposes such as, but not limited to the following:
Nyble Membership, Overdraft Protection, Identity Protection and Financial Wellness Analysis: When you complete an application to access funds for overdraft protection, identity protection, and financial wellness, we use your personal information to determine eligibility and verify identify for products and services. This information may include the following information: name, address, date of birth, phone number, email address, as well as information about your employment status and your banking history.
Lease Application: When you complete an application for a lease purchase transaction either directly with us or with one of our merchant partners. We use your personal information to determine eligibility and verify identify for products and services. We may also request your government issued identification in order to confirm your identity. This information may include the following information: name, address, date of birth, phone number, email address, as well as information about your lease purchase transaction.
Instant Bank Verification: At the time of your application, you may connect you bank account through Flinks, a third-party interface, to connect to your online accounts for financial institutions. We use your bank account information to verify your identity, determine your eligibility and collect information for payments. This information may include the following information: name, address, email address, income information, loan payments and 90-day transactions data.
Payment-Related Information: We may collect payment related information including bank account numbers and payment card numbers that you enter and give us when you use our services.
Information Obtained from Third Parties: We may obtain information from third parties including but not limited to identity verification services, merchants, and others. If you are applying for our service through one of our merchant partners, the merchant you are purchasing from may also share your personal information with us in order to provide our services to you.
Customer Service: When you contact us with general questions or other support inquiries, we may ask for information which identifies you. Information may include name, address, and phone number, along with other information which may be required to promptly answer your questions. We may retain this information to improve our customer service and other offerings to you.
Marketing: We may obtain your consent to send you marketing communications by mail or email which promote products and services offered either by us or our merchant partners. You can opt out of receiving these offers by clicking the unsubscribe link in our marketing email communications or by contacting us.
2. Disclosures and Transfers of Personal Information
We may disclose your personal information in a number of circumstances, including:
Financial Institutions: We may transfer your personal information to financial institutions for payments purposes.
Service Providers: We may also transfer your personal information to our Service Providers used to administer or provide products, services or information on our behalf such as to deliver products ordered, to operate and host our websites and features, and to send marketing communications. Some of the Service Providers that process personal information on our behalf may be located outside of Canada, including the United States. We require the organizations that we use to limit the use of your personal information only to the extent of the services that we have contracted them to provide.
Legal & Compliance: To meet regulatory, legal, industry self-regulatory and security requirements or other purposes identified with your consent or as required by law.
3. Our Website
Personal information that we collect about you when you use our website is what you tell us about yourself, for example, by completing an online application, or information you provide to us through the "Contact Us" section or when you send us an email. As most websites do, we track usage patterns on our website on an anonymous basis. Your identity cannot reasonably be ascertained from this information. Each time you visit our website, our server records your internet service provider, the timestamp of your visit, the pages you visit, the documents downloaded, the searches you performed, and the referring URLs you came from. We use this non-personal information to optimize our website service. For your convenience, we may offer links from our website to other websites. However, we are not responsible for, nor do we accept any liability for, the personal information collection, use, and disclosure practices of other entities to which our website may link. You should consult the privacy policies of these other entities before providing any personal information on their websites.
4. Access, Accuracy and Corrections
We maintain a file of your personal information for the above-mentioned purposes. If you wish to request access to, or correction of, your personal information in custody or control, please make your request in writing to us. We may need to verify your identity before searching for or providing you with personal information. In some circumstances, we may not provide access to your personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information, or if it is otherwise not properly the subject of an access request. It is important that your personal information be accurate and up to date. Please inform us as soon as possible of any changes to your personal information. If you have any questions, requests, or complaints about our personal information practices, please contact us via email.
5. Consent
We collect, use and disclose your personal information with your consent or as permitted or required by law. Your consent may be expressed or implied, depending on the circumstances and the sensitivity of the personal information in question. For example, in most cases, a client's consent to the collection, use, and disclosure of personal information by us may be implied by the fact that the client has engaged us to provide services, where the collection, use, and disclosure of personal information relates to the performance of those services by us. If you provide personal information about another person to us, we assume you have the consent of that individual to enable us to collect, use, or disclose their information as described in this Privacy Policy. If you choose to provide personal information to us, we assume that you consent to the collection, use, and disclosure of your personal information as outlined in this Privacy Policy. If you do not consent, please do not provide your personal information or, where applicable, exercise the opt-in or opt-out options offered. Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use and disclosure of your personal information, or you may withdraw your consent to our further collection, use, and disclosure of information about you, by contacting us via email. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our services. There are instances where we may collect, use, or disclose your personal information without your consent, for example, to collect a debt you owe to us, to comply with a subpoena or court order, or to comply with the rules of court regarding the production of records.
6. Changes to Our Privacy Policy
We update our Privacy Policy regularly and we reserve the right to change this Privacy Policy at anytime without notice to you. We will take reasonable steps to advise affected individuals of any material changes. You may contact us to obtain a current copy of this Privacy Policy.
7. Contact Us
If you wish to make inquiries, access/update the information that we have about you or obtain further information. Please contact us.
