Bloom Finance Company Ltd.
Licensed in ON #13338, BC #MBX600455, and AB
Bloom Finance Company Ltd. (variously referred to as "Bloom", "we", "us" or "our") is committed to protecting your personal information. This Privacy Policy (the “Policy”) has been designed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) as well as other substantially similar provincial legislation, and describes how we collect, use, protect, share, and retain your information. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. This Policy applies to www.bloomfin.ca (the “Site”), owned and operated by Bloom, and to your application for, access to or receipt of products and services from Bloom. This Policy applies to any individual who has made an application to us for any financial product or service offered by us, including any co-applicants, powers of attorney, guarantors or personal representatives (“you”, “your”). Personal information means any factual or subjective information in recorded form, that identifies or could be used to identify an individual.
We ask you for your personal information for the following purposes:
To verify your identity and protect against fraud
To understand your product and service requirements
To determine the suitability of our products and services for your needs
To determine your eligibility for our products and services
To initiate and manage products and services we offer you
To comply with legal, regulatory and contractual requirements
To assist in the collection of debts that you may incur with us
Other purposes for collection, use and disclosure indicated in the Policy
Subject to legal, regulatory and contractual requirements, you may refuse to consent to our collection, use or disclosure of information about you. Depending on the circumstances, however, withdrawal of your consent may prevent us from providing or continuing to provide services or information to you.
We observe the following 10 principles when dealing with your personal information:
Be accountable: We are responsible for all personal information in our possession, including any personal information disclosed to third parties for processing, administrative, financing or other required functions. Our President oversees the management of our privacy program. To contact the President please refer to the Contact Us section below.
Identify the purpose: We will identify to you and document the purpose for which we collect your personal information.
Obtain valid, informed consent: We will make a reasonable effort to ensure you understand how your personal information will be used and will obtain your consent before or at the time we collect or use the personal information. Your consent can be express, implied, or given through an authorized representative.
Limit collection: We will only collect personal information that is necessary for the purposes we have identified to you.
Limit use, disclosure and retention: We will only use or disclose personal information for the purposes it was collected, unless you give consent to use or disclose it for another reason, or it is permitted or required by law. We will only keep your personal information as long as necessary for the purposes identified at the time of collection or as required by law.
Be accurate: We will make a reasonable effort to keep your personal information up to date and accurate. We will rely on you to tell us when your information changes.
Use appropriate safeguards: We will use safeguards appropriate to the sensitivity of the information to protect your personal information against loss, theft, or any unauthorized access, disclosure, copying, use or modification.
Be open: You may request access to more information about our privacy practices, and we will make it available to you in a manner that is easy to understand.
Give individuals access: You may request access to your personal information. After verifying your identity, we will, within a reasonable timeframe and always within 30 days barring exceptional circumstances as outlined in PIPEDA and other substantially similar provincial legislation, tell you what personal information we have, what it is being used for, and to whom it has been disclosed. If we aren’t able to give you access to all your personal information, we will, except where prohibited by law, explain the reasons for this lack of access and advise you of any recourse you may have.
Challenging compliance: We will respond to your questions or concerns about the protection of your personal information in a timely manner, typically within 30 days. If we need to extend the time, or if we refuse your request, we will tell you why.
We may collect your personal information from you directly, and from other sources outside our organization including from government sources, law enforcement agencies, public records, credit reporting agencies, other financial institutions, data aggregation services, service providers, agents and other organizations with whom you have arrangements or in accordance with their respective terms and conditions and/or privacy policies, or any other source, with your consent or as permitted or required by law. This information may be obtained by telephone, in writing or electronically.
We may collect personal information at various times, including: (1) before we have a business relationship, such as when you send us correspondence, make an inquiry about our products and services, submit an application, or after an application has been declined by us or withdrawn by you; (2) during our business relationship, such as when your application and eligibility is being assessed, and during the term of any products, services or other agreement between you and us; and (3) after our business relationship, including to assess your eligibility for new or additional products or services, maintain internal records and communication with you, and to analyze and improve our processes, products and services.
The personal information that we may collect from you includes:
information establishing your identity (such as your name, address, email address, phone number, occupation, date of birth and other identification documents required by law)
information to authenticate your identity such as knowledge-based information (i.e. username, password, and account information), and device information (i.e. device model, browser type and activity, IP address, security cookie and approximate physical location of device)
information about your financial status including your employment history, annual income, assets, liabilities and credit history
information about your bank account(s)
information about your home and property
information about your property taxes, home insurance, condominium fees and property maintenance fees
information reflecting your business dealings, balances and transactions with us
information about your expenses and spending activity
other information that we may need in order to provide you with a product or service
other information with your consent, or as permitted or required by law
Depending on the situation, we may obtain your consent to collect and retain your personal information in different ways. Express consent may be obtained verbally, electronically or in writing. Implied consent may be obtained through your use of a product, or when you approach us to obtain information, inquire about or apply for products or services from us.
Subject to legal, regulatory and contractual requirements, you can refuse or withdraw your consent to our collection, use or disclosure of your personal information at any time by giving us 30 days notice. Depending on the circumstances, however, withdrawal of your consent may prevent us from providing you or continuing to provide you with some products and services or information.
If you have or have provided a guarantee for a credit product with us, you may not, during the term of the facility, withdraw your consent to our ongoing collection, use or disclosure of your personal information in connection with such product. We can continue to disclose your personal information to credit bureaus even after the credit facility has matured and been paid out, in order to facilitate the functioning of the credit reporting system, and you may not withdraw your consent to our doing so.
We use personal information about you to:
verify your identity and to authenticate you when you contact us or we contact you
evaluate your eligibility for our products and services, including by obtaining credit reports
evaluate and process your application, account, transaction and reports
create and administer your accounts and services with us
provide you with products and services you have requested
obtain third party funding for a credit product we provide to you
communicate with you
determine your eligibility and market a product or service, either directly or through a service provider, partner or third party
help manage and assess our risks, operations and relationship with you
prevent, detect or investigate fraud or criminal activity
collect amounts owing to us
maintain the accuracy and integrity of information held by a credit reporting agency
comply with legal, regulatory, governmental and contractual requirements
Use of credit information: The collection and use of credit information is required in order to apply for or maintain our products. In order to ascertain a borrower’s willingness and capacity to meet obligations under our lending agreements, we collect and analyze credit information about applicants and customers before, during and after the term of our business relationship.
Use of your email address or phone number: With your consent, we may periodically send you commercial electronic messages at the e-mail address or phone number you provide, including to solicit your feedback on our products and services, and/or to provide you with marketing offers that may be of interest to you. With each such message you will have the opportunity to opt out of receiving future commercial electronic messages, by clicking an Unsubscribe link in the case of an email to your email address, or by responding STOP in the case of an SMS message to your phone number. If you are a customer, we reserve the right to use the e-mail address and phone number you provide to present you with information about your account. We may track the activity of an e-mail or SMS message (for example, were graphics viewed, was the e-mail opened, were links in the e-mail clicked), to allow us to measure the effectiveness of the e-mail or SMS message, to provide future offers, and for fulfillment of products and services. Additionally, for your convenience, we may pre-fill online forms with your e-mail address or phone number. Upon request, we will provide you with a summary of your consents and allow you to amend those consents at any time upon 1 business day’s notice. Such requests should be made by way of email to privacy@bloomfin.ca or by calling us at 647-548-9055.
We may also use your personal information for other purposes with your consent or as permitted or required by law. If for any reason your information is required to fulfill a different purpose than that of your original intent, we will ask for your consent before we proceed.
We will share your information:
with our affiliates and related companies that agree to treat it in accordance with this Policy
with agents, service providers and any other entities that perform services on our behalf (collectively, 'service providers'). You acknowledge that some of our service providers may be located outside of Canada and as such your personal information may be accessible to governmental, national security and regulatory authorities in accordance with the laws of these jurisdictions. All service providers are contractually obligated to use safeguards to protect your personal information and to use it only for the purposes for which we disclose it to them
with other organizations or agents with whom you have arrangements and to whom you have provided consent directly
with other financial institutions to process payments or to verify information such as your identity, income, and credit history
with credit bureaus, credit insurers, third party verification services, registries, financial service industry databases, investigative bodies, your employer, personal references and other lenders for the purposes of verifying your information
with credit bureaus to facilitate the functioning of the credit reporting system
with residential valuation firms to ascertain estimates of the value of your property
with payment card issuers and card program management partners to facilitate delivery and administration of card products and services
in response to a court order, search warrant or other demand or request we believe to be valid
to meet requests for information from regulators
to satisfy legal, audit, insurance, self-regulatory and regulatory requirements applicable to us
in any negotiations for the sale or assignment or proposed sale or assignment of all or part of our business or assets (including your mortgage, any debt or interest due to us and any of our rights and obligations) and to our successors and assigns who may use and disclose the information for similar purposes as those described in this Policy
with financial institutions and other organizations that provide funding for or invest in mortgages we originate for the purpose of evaluating or performing the transaction
with trust companies and other financial institutions that act as custodian of mortgages originated and serviced by us
with other parties connected with your account, as applicable (e.g. guarantors, powers of attorney and other people named on the application)
with a joint account holder
to help us collect a debt or enforce an obligation owed to us by you, including with debt collectors and other third parties in the event you default on a credit obligation with us
with any person or organization, including an investigative body, in order to prevent, detect or suppress financial abuse, fraud, criminal activity, protect our assets and interests, assist us with any internal or external investigation into potentially illegal or suspicious activity or manage, defend or settle any actual or potential loss
when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request
where permitted or required by law
For greater certainty, we may use and disclose your personal information in connection with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of your mortgage, any debt or interest due to us and any of our rights and obligations for the purposes of evaluating or performing the proposed transaction. Assignees or successors of our business or assets may use and disclose your personal information for similar purposes as those described in this Policy. By purchasing a credit product from Bloom, you hereby consent to the sale, transfer and assignment of all present and future consumer mortgage and related agreements, and the use and disclosure of related personal information, in connection with the proposed and actual securitization of your mortgage.
We have put in place safeguards, including technological, physical, and organizational, to protect your personal information in a manner that is appropriate to its sensitivity. These safeguards are intended to protect the security of personal information against loss, theft, and unauthorized access, disclosure, copying, use or modification. Authorized employees and agents will have access to your personal information in order to perform their functions. We audit our procedures and security measures regularly to help ensure that they are being properly administered and that they remain effective and appropriate to the sensitivity of the information.
Bloom does not retain personal information outside of Canada. Bloom does not offer products or services in the Province of Quebec. We will retain your information for as long as needed to fulfill the purposes for which it was collected and used. In some cases, this may be as long as your account is active or as needed to provide you services. However, in other cases we will retain personal information after the end of our business relationship including to satisfy regulatory requirements, to maintain communications with you, facilitate future applications you may submit, understand customer preferences and behaviors, analyze and improve our processes and develop new products and services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You should not assume that your information will be deleted when you close your account with us or if an application is not approved. When your personal information is no longer required, we will securely destroy it or convert it to an anonymous form within 30 days. If you have any questions about how long your personal information is retained, please contact us.
Subject to contractual and legal restrictions, you may request access to or a correction of the personal information we hold about you by email at privacy@bloomfin.ca or phone at 647-548-9055. Bloom will respond within 20 days of receipt of your request. We may need to confirm your identity before fulfilling your request, such as by requesting a copy of a valid driver’s license, birth certificate, or passport. In certain circumstances we may not be able to provide you with access to your personal information, (e.g., if disclosing the information would reveal confidential commercial information or information about a third party). If this is the case, we will inform you of the reasons that we were unable to provide you access. Bloom relies on individuals to provide updates to their information when things change.
When you visit the Site, Bloom may record your internet protocol (“IP”) address, the pages you visit while on the Site, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data, and store it in log files. We do not use this information to identify any individual but use it to improve the content of the Site and make it more useful.
Bloom does not automatically collect your e-mail address without your consent. However, personal information including email address is collected when you provide it via input or feedback forms. We may ask you to provide us with your e-mail address at several points, including to generate a quote, on applications, and in correspondence or communications with you.
Technologies such as cookies, beacons, scripts and tags are used by Bloom and our marketing partners, affiliates or analytics or service providers. These technologies are used in analyzing trends, administering the Site, tracking users’ movements around the Site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
Cookies are files placed within your browser on your computer’s hard drive when you visit the Site. Bloom may use cookies to verify your identity, remember your personal settings such as your offer preferences, and to monitor your use of the Site to improve our services. We do not use cookies to collect data from your hard drive including your e-mail address or other personal information.
Our Site also uses web analytics services such as Google Analytics. They use cookies to help us analyze how visitors use the Site. For example, with Google Analytics, the information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored on a Google server. Google uses this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for us, and providing us with other services relating to Site activity and internet usage. You can prevent the storage of data relating to your use of the Site (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links:
We may partner with a third party to either display advertising on the Site or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Site and other sites in order to serve you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by writing to us at privacy@bloomfin.ca. Please note this would not opt you out of being served generic ads.
This Policy is effective as of December 22, 2023. This Policy replaces any previous notices from Bloom about personal information collection, protection, use, sharing, retention, and internet privacy practices and applies to the use, sharing and retention of personal information previously collected. However, this Policy does not supersede any application- or account-specific terms and conditions you may have agreed to; those terms must be read together with this Policy.
We may amend this Privacy Policy at any time, and when such a change is made, we will post a revised version and a notice on this Site. In the event of a material change to Bloom’s privacy practices, or if a new purpose is identified for existing information retained by Bloom, such change will be posted prominently on the homepage of the Site and/or affected individuals will be notified directly.
It is your responsibility to review this Policy from time to time to be aware of any changes. Please check back regularly for any changes and to ensure you are always informed of the personal information that we collect about you, how we use it and the circumstances under which we may disclose it.
If you have a questions or concerns about your personal information, please contact the President at:
privacy@bloomfin.ca
647-548-9055
Or in writing at:
Bloom Finance Company Ltd.
147 Liberty Street
Toronto, Ontario
M6K 3G3
If your concern remains unresolved by us, you may contact the Privacy Commissioner of Canada at:
1-800-282-1376
Or in writing at:
Office of the Privacy Commissioner
30 Victoria Street
Gatineau,Quebec
K1A 1H3
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