The fine print

We know the fine print can be painful, but we believe it's important you have all the facts!

easyfinancial offers a variety of financial services including personal loans, and mortgages. easyfinancial is a division of goeasy Ltd., the leading full service provider of goods and alternative financial services that improve the lives of everyday Canadians.  goeasy Ltd. is listed on the TSE under the symbol 'GSY'.

Purposes for Which goeasy Handles Personal Information

goeasy collects and uses personal information for purposes limited to those which are related to its businesses, which include providing financial services and leasing household furnishings, appliances, and home electronic products to its customers under lease agreements. We collect personal information primarily from you, for instance through applications and supporting documentation you provide. We may also collect personal information about you through your ongoing interactions with us, from references, employers and other financial institutions you have identified in your application as well as credit bureaus and other third party sources. For example, we may collect personal information from credit bureaus for the purpose of locating you to collect outstanding debts. In connection with loan agreements, we may also collect personal information from credit bureaus in order to verify your current and ongoing creditworthiness and other information you may provide to us.

We may collect and use personal information for purposes such as, but not limited to, the following:

• to manage and promote the business activities of goeasy;
• to verify identity and other information provided by customers and to determine eligibility for products and services;
• to open, administer and service accounts and loans and to provide and administer any requested products or services;
• to evaluate current and ongoing creditworthiness and other requirements and to determine eligibility or suitability for products or services offered by goeasy;
• to advertise, market and promote products and services that may be of interest to customers, including by mail, email,  text message, telephone, automatic dialers and announcing devices;
• to establish relationships, provide quality service to and communicate with customers;
• to collect outstanding debts;
• to protect the business interests of goeasy and its customers, including to detect and prevent fraud and other unauthorized or illegal activities;
• to maintain business records for reasonable periods to meet legal and regulatory record retention requirements; and
• for other purposes identified by goeasy with your consent or as permitted or required by law.

Personal Information goeasy Collects

goeasy limits the amount and type of personal information collected to that which is necessary for our identified purposes, and we collect personal information by fair and lawful means.

Personal information that we collect includes:

• customer name and contact information, including mailing address, telephone number, fax number and/or email address;
• additional information for identity matching and credit check purposes, such as occupation, name of employer, names and contact information for references, assets, liabilities, income, previous address, number of dependents, Social Insurance Number (if provided), date of birth or driver's license number;
• information about the account or loan, such as current and historical information, balance and indebtedness, account transaction history and similar information and records relating to the handling of any inquiries or complaints;
• payment-related information such as banking information; and
• such other information that is necessary for our identified purposes and that is collected with your consent or as permitted or required by law.

Transfers and Disclosures of Personal Information

goeasy may disclose personal information in a number of circumstances, including:

• to credit reporting agencies and to your current or future creditors for the purpose of maintaining your credit history and providing credit references;
• to financial institutions for payment processing purposes;
• to third parties as reasonably necessary to enforce your contracts with us and otherwise for the collection or payment of a debt owed to us;
• for the purposes of detecting and preventing fraud;
• in connection with audits;
• for the purposes of meeting legal, regulatory, industry self-regulatory, risk management and security requirements;
• with your consent  to goeasy's insurance partners or other lenders so that they may offer other products and services that may be of interest to you; and
• for other purposes identified by goeasy with your consent or as permitted or required by law.

In addition to the above, personal information may be shared between our affiliates or subsidiaries (including those located in the United States) for internal audit, management, billing or administrative purposes including defending and bringing legal actions.

In the course of fulfilling the purposes described above, goeasy may transfer your personal information to service providers, including affiliates or other third party organizations or individuals retained by goeasy to perform functions on its behalf, such as marketing, data processing, customer service, office, security, collections, insurance, financial and taxation services. When personal information is transferred to service providers, we use contractual or other means to ensure that a comparable level of protection is provided. Some of our service providers may be located outside Canada, including in the United States, and will be subject to applicable legal requirements in the country in which they are located, including lawful requirements to disclose personal information to government authorities in certain circumstances.

goeasy may also use and disclose personal information in connection with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets (including your loan or lease and any agreement to which it relates), for the purposes of evaluating and/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.

goeasy may disclose your personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law.

Safeguards

goeasy uses reasonable safeguards and other security standards to protect all personal information in its custody and control against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. Safeguards will vary depending on the sensitivity, format, location, and storage of the personal information. Only authorized employees, agents, partners and third parties who require access to personal information to fulfill their job requirements will have access to personal information.

Access and Accuracy

goeasy may establish and maintain a file containing an individual's personal information for the purposes described above, which will be accessible at our offices. Individuals have the right to request access to or correction of their personal information that is held by goeasy. Requests must be made in writing, addressed to goeasy's Privacy Officer as per the contact information set out at the end of this Policy. We will respond to written requests within a reasonable time. Copies of records containing personal information may be subject to a fee.  If this is the case, goeasy will inform the individual of the amount of the fee in advance. We will use our best efforts to ensure that personal information is as accurate, complete and up-to-date as necessary for the identified purposes. If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information as required. If we refuse access to personal information or disagree with an assertion that information held by us is incorrect, we will provide a written explanation for such refusal and a description of our complaints procedure should an individual decide to challenge such written explanation.  An individual's right to access or correct personal information is subject to applicable legal restrictions. To prevent fraudulent access to the personal information stored by goeasy, we may take reasonable steps to verify an individual's identity before granting access or making corrections.

goeasy's Websites and E-Mail Communication

goeasy does not guarantee the confidentiality of any communications made by you via e-mail or otherwise through our websites. If you wish to provide information of a confidential or sensitive nature to easyhome, please contact us directly by telephone at 1-866-823-3279 or easyfinancial at 1-888-502-3279 to arrange for delivery/transmission of such information by secure means.

We use cookies and other tracking technologies to improve your experience on our website, to facilitate the online application process and for internal research and reporting purposes. A "cookie" is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences, such as your IP address and the pages of the website that you visit. You can set your browser to notify you when you receive a cookie or to refuse cookies altogether. If you refuse cookies, however, you may not be able to use certain features of our website, view ads based on past visits to our website, report or interact with ad impressions.

Our website may contain links to other websites of interest. These other websites are not governed by our Privacy Policy and we are not responsible for any personal information which you provide while visiting other websites. We encourage you to read the privacy policy of every website you visit.

In compliance with Google's advertising policies, we use Google Adwords Search Engine Marketing (Pay Per Click) and Display Advertising (Remarketing and Google Display Network). We use Google AdWords Remarketing in compliance with the Google AdWords Interest-Based Advertising Policy, which means that you may see our advertisements on Google and other third party websites on the internet after visiting our website.

We use Google Analytics for Display Advertising, including Remarketing, Google Analytics Demographics and Interest Reporting, Google Display Network Impression Reporting and the DoubleClick Campaign Manager integration. You have the option to opt out of Google Analytics for Display Advertising and customize Google Display Network ads. For all the currently available opt-outs, please visit https://tools.google.com/dlpage/gaoptout

We use the data collected through Google Analytics Demographics and Interest Reporting to better understand our website visitors in terms of demographics and interests, to improve our website content in order to cater to our audience, and to customize advertisements based on our audience's interests and demographics.

Consent

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express or implied. In some circumstances, where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn consent, you will be considered to have consented for the purposes identified and described to you.  By submitting personal information to goeasy or its service providers and agents, you consent to the collection, use and disclosure of such personal information as described in this Privacy Policy or otherwise at the time of collection. If you provide goeasy or our service providers and agents with personal information of another individual, it is your responsibility to obtain consent from such person to enable us to collect, use and disclose such information for the purposes set forth in this Privacy Policy. Subject to legal or contractual requirements and reasonable notice, you may withdraw your consent at any time by contacting goeasy's Privacy Officer at the contact information set out at the end of this Privacy Policy. If you withdraw your consent, we may be limited or unable to provide you with certain services or information.

In certain circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual. These circumstances include but are not limited to: personal information that is publicly available as defined by regulation; where collection is clearly in the interests of the individual and consent cannot be obtained in a timely way; where disclosure is made for the purposes of collecting a debt owed to us; or to comply with a subpoena, warrant or court order.

Inquiries or Further Information

goeasy has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. Any questions related to the Privacy Policy or the handling of personal information by goeasy can be addressed directly to the Privacy Officer at:

Privacy Officer, goeasy Ltd.,

33 City Centre Drive, Suite 510

Mississauga, Ontario, L5B 2N5, Canada

[email protected]

If you are not satisfied with our response to a privacy-related matter, you may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or at http://www.privcom.gc.ca. or in Quebec, Alberta or British Columbia, your provincial privacy regulator, as applicable.

We reserve the right to modify this Privacy Policy at any time. If we make a change to this Policy, we will post such changes on our website located at www.goeasy.com.