Privacy Policy

"Personal Information" is any information about an identifiable individual. It may include, without limitation, an individual's name, age, date of birth, home address, social insurance number, marital status, income, account number, client identification number, personal email address and messages, and Internet Protocol (IP) address.

Personal Information doesn't include the business contact information of an individual which is collected, used, or disclosed solely for the purposes of communicating or facilitating communications with the individual in relation to their employment, business, or profession.

Personal Information also doesn't include any information that is aggregated or anonymized.

We collect and use several types of information from and about you to better provide products and services to you. Depending on the products or services you use, this may include:

• Personal Information (such as your name, address, contact information, date of birth, occupation and any other type of identification including your driver's license);
• Financial and bank information including your credit score and information about your assets, liabilities, income and expenses (for example, when applying for a rental property);
• Tax information (including Social Insurance Number (SIN) if provided for identity verification or credit checks);
• Employment information; and
• Information about your transactions with us and our interactions with you (including call recordings and chat transcripts).

We also collect technical information. This may include your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our website, and usage details as well as non-personal details about your online interactions, including the Uniform Resource Locators (URLs), clickstream to, through and from our website (including date and time), products you viewed or searched, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, email response and interactions, and any phone number used to call our customer service number.

Collection of Social Insurance Number (SIN) for Identity Verification (Optional)

Depending on the product or service you use (such as a rental application), we may request (with your consent) your SIN to verify your identity through an established credit reporting agency. Providing us with your SIN is optional and you can refuse our request for this information, though it may affect our ability to verify your identity or process specific applications efficiently.

Biometric Information

While we do not collect, use, access, disclose, or retain any biometric data directly, our apps may be supported by third parties such as Apple or Google. Through the use of third party technology, users may enable technology which uses biometrics for authentication (e.g., FaceID). When such technology is enabled, we will be notified if the authentication is successful but will not have access to any of the data associated with the authentication.

The Personal Information we have about you may be collected directly from you (or anyone authorized by you to act on your behalf). In addition, we may employ technologies that identify, locate, or profile you. This information may be collected from sources within or outside of our Company including from:

• our interactions with you (including email, instant messaging/chat, telephone and video calls);
• your landlord, property manager, or real estate agent (where applicable);
• government bodies, agencies, registries; regulatory bodies, and law enforcement authorities;
• public records;
• third party service providers (including financial data aggregators) and professional advisors;
• financial or lending institutions;
• credit reporting agencies including Equifax Canada Inc. and Trans Union of Canada, Inc.;
• our affiliates, partners, and related entities; and
• organizations with whom you have arrangements or any other sources we deem appropriate (where the information obtained will help us serve you).

Call Recordings

We may record telephone or video calls made or received by our agents and employees for quality assurance and security purposes. If you do not want your call to be recorded, please notify the agent on the call. We keep recordings of calls only for as long as permitted by law.

The Personal Information collected is used to ensure we can provide products and services to you and fulfill our obligations to you.

We may use your Personal Information for purposes including to:

• verify your identity and determine your eligibility for products or services (such as rental applications);
• administer your account and product and services you may have with us;
• Complete an application or communicate with you (including responding to any inquiries you may make);
• Pre-populate forms with Personal Information previously provided when applying for or making a request for any additional product(s) or service(s);
• evaluate and process your application, accounts, transactions, and reports;
• help analyze and understand your needs in order to serve you better and personalize your experience with us;
• help us assess your eligibility for other products or services;
• help manage and assess our risks including risk of default, operations and relationship with you;
• help us collect a debt or enforce an obligation owed by you;
• comply with applicable laws and requirements of regulators; and
• best serve you and your interests.

We may use artificial intelligence (AI), machine learning, and automated decision making technologies to evaluate and assess Personal Information.

Additional Collection, Uses, and Disclosures

Marketing and Sales Purposes

Your Personal information may be used for marketing and sales purposes such as:

• informing you about products and services that may be of interest to you (including any new products or services, or the products and services of our affiliates and third party partners);
• using your Personal Information to determine your eligibility to participate in promotions, including contests;
• contacting you by email, telephone, fax, text message, or any other electronic means; and
• using your Personal Information to conduct research, analysis, modeling, and surveys to improve your experience with us and for product/service development.

Where you do not wish for your Personal Information to be used for such marketing and sales purposes, you may withdraw your consent (subject to certain restrictions).

For Rental Applications and Credit Checks

For services involving credit checks, such as rental applications, we will exchange Personal Information and reports about you with credit reporting agencies and potential landlords at the time of the application. This is to review and verify your creditworthiness, manage and assess risks, and support the application process. We may obtain Information and reports about you from a credit reporting agency such as Equifax Canada Inc. and Trans Union of Canada, Inc.

Using Your SIN for Non-Tax Purposes

With your consent, and where SIN has been collected, we may also use your Social Insurance Number (SIN) as a unique identifier. There are situation(s) where it is necessary to keep your Personal Information separate from that of other customers or individuals with similar names, for internal matching of your personal records against records received from authorized third parties, and to help maintain the accuracy of your Personal Information. You can withdraw your consent for the non-tax use of SIN at anytime by contacting privacy@frently.ca and putting “Withdraw Non-Tax Use of SIN” in the subject line or in the body of the message.

Fraud Management

Your Personal Information may be used to help protect you and us against fraud risk and errors. This includes for the purposes of preventing, detecting, suppression of any financial abuse, fraud, criminal activity, and improving security measures. To protect both your and our assets and interests we may collect, use, and disclose your Personal Information to assist with both external and internal fraud investigations.

Personal information will not be used, disclosed, or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law. Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In order to provide you with the best products and services, we may need to share your Personal Information with other parties who are under an obligation to protect the confidentiality of that information. The shared information will be limited to such information which is necessary to facilitate the arrangement.

Your Personal Information may be disclosed:

• to carry out a mandate or perform a contract of enterprise or for services;
• as part of a business transaction that we are considering or involved in (including the purchase of a business or the sale of part or all of our business);
• to respond to a court order, search warrant, or any other valid demand or request;
• to satisfy any applicable legal or regulatory requirement;
• to any advisors we may engage which may include financial advisors, consultants, accountants, lawyers, and auditors;
• to suppliers, service providers, agents or other organizations that perform services for you, for us or on our behalf;
• to your real estate agent, landlord, property manager, or creditor/default insurance provider;
• to our active and prospective funding partners for purposes of risk management and to meet our contractual obligations to them;
• to any authorized individual with legal authority including Power of Attorney;
• for study or research purposes or for the production of statistics;
• to help us collect a debt or enforce an obligation owed to us by you; and
• where otherwise permitted by law.

Categories of Service Providers

To provide you with optimal service, we may engage a variety of third party service providers. These service providers may be disclosed or have access to your Personal Information. The types of service providers we engage may include:

• communications service providers;
• compliance and fraud management service providers;
• credit reporting agencies;
• customer management service providers;
• disaster recovery service providers;
• payment processing service providers;
• physical storage service providers;
• professional advisors such as lawyers, accountants, consultants, auditors, and financial advisors;
• technology service providers.

Note that the service providers and other organizations we may use could be located outside of your province of residence or Canada. As such, your Personal Information may be collected, accessed, used, disclosed, and stored outside of your province of residence or Canada.

We may also share your Personal Information internally, including with our affiliates, for the following purposes:

• to manage your relationship with us and our affiliates;
• to better understand the products and services you have with us or our affiliates;
• to provide you with improved customer experience including maintaining consistent information about you;
• to manage and assess our risks; and
• to comply with all applicable legal and regulatory requirements.

Withdrawing Consent

Subject to applicable legal and regulatory requirements, the consent to use your Personal Information given in any Privacy Agreement, Privacy Policy, and any other consent collected will be valid as long as you have a product or service with us or until we have received written notice that you wish to withdraw it. You may withdraw your consent in whole or with respect to certain uses. In certain circumstances, withdrawing your consent will mean we can no longer administer your products and services. You may contact privacy@frently.ca if you wish to withdraw your consent.

Accessing and Correcting Your Personal Information

You have a right to access, update, and correct inaccuracies with your Personal Information that is in our custody and control (subject to certain exceptions prescribed by applicable laws and regulations). For further information or to submit a request, contact privacy@frently.ca.

Protecting your Personal Information

Please note that sharing your Personal Information with us does have certain risks including risk of unauthorised disclosure of Personal Information, identity theft, and fraud. We take the protection of your Personal Information very seriously and deploy various technical, administrative, and physical safeguards to protect your information.

Consent to Communications

By providing us with your contact information (email, phone number, address), you are consenting to us collecting, using, accessing, disclosing and storing your Personal Information for communication purposes including responding to any inquiries you make, helping us better understand your needs, and advising you of other products and services that may be of interest to you.

Please note that while clients may withdraw consent from obtaining promotional communications, this withdrawal will not apply to all communications. There are certain communications that all clients must receive (such as those regarding account-related information). Non clients may withdraw consent from all communications at any time.

Opting Out of Commercial Electronic Messages

If you consent to and receive commercial electronic messages from us and you no longer wish to receive them, you can click on the “unsubscribe” link at the bottom of the message and follow the prompts on your screen. You can also contact unsubscribe@frently.ca.

Some emails may not include an 'unsubscribe' link because the email contains account-related information that all clients must receive.

• If you receive an email in error after you have unsubscribed, please forward it to unsubscribe@frently.ca and your request will be processed immediately.
• You can change, update and opt-out of alerts through the User Settings in the Frently App.

Our website contains links to other sites that we do not own or operate. We are not responsible for the privacy policy and privacy practices of any other websites.

To request the deletion of your Frently user account, please contact privacy@frently.ca, a member of our team will assist you.

Please note that this action will remove and/or anonymize your Frently user related data:

• Email
• Contact Info
• Password
• Settings and Configuration

Updates to Our Privacy Policy

We will post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email using the email address specified in your account or place information banners on our website. We will include the date the Privacy Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our website and this Privacy Policy specifically to check for any changes.

Contact Us

If you have any questions or concerns about this policy or privacy and confidentiality matters, please contact us at:

Attention: Trish Montag, Privacy Officer

Contact the Office of the Privacy Commissioner of Canada

If, after contacting Frently, you feel your Personal Information concerns have not been adequately addressed, you may contact the Office of the Privacy Commissioner of Canada at: