Privacy Policy

Privacy Policy

Marble Financial Inc. Privacy Policy

Last updated: March 1, 2021

Contents

Introduction

Welcome to the Privacy Policy of Marble Financial Inc., TPFM Phoenix Fund Management Ltd., Score-Up, Inc. (with its affiliates, “MARBLE”). MARBLE is an online financial, personal finance and credit wellness company.

At MARBLE we take pride in the policies and procedures we use to protect the personal information we collect, use and disclose on behalf of our customers. This Privacy Policy describes how we may collect, use or disclose your personal information. We collect, use and disclose information in accordance with applicable laws, including Canada’s Personal Information Protection and Electronic Documents Act and applicable provincial privacy legislation.

This Privacy Policy applies to the use of our website, personal finance portal, partner portal, lending platform, and our consumer credit analysis tools and services (collectively, the “Services“). This Privacy Policy applies to registrants of our personal finance portal and users of our Services, individual subscribers of our Services and reseller organizations that market or use our Services (a “Reseller”).

MARBLE may provide third-party content or links to third-party websites or applications. When you leave our Services or interact with a third-party feature, you should read the applicable third party’s privacy policies and terms of service to make sure you understand how they might collect and share information about you. If you do not agree with any term in this Privacy Policy, please do not provide us with your information or use our Services.

We encourage you to read this Privacy Policy carefully. By using the website or the Services, you agree to the collection, use and disclosure of personal information in accordance with this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us https://mymarble.wpengine.com/contact/.

Types of personal information that we may collect from you

Personal information means information about an identifiable individual. It may include your name and address, e-mail address, employment history, or other details about you.

The table below explains the types of personal information we may collect from you.

Type Of Personal Information
We May Collect From You
Description of Personal Information
Information you give us when applying to use or when using our Services Individuals that wish to use our Services will typically be asked to provide the following information:

• Contact information such as your name, address and contact telephone numbers;

• Unique identifiers such as your date of birth and social insurance number;

• Your financial goals, and the referral source or Reseller that referred you to our Services; 

• Personal background such as age, marital status, income, employment history and household expenses; and

• Credentials for third-party services when you authorize us to connect to them on your behalf, and payment or banking information.

You are not required to provide your social insurance number in order to use our Services. However, if you choose to provide it, we use it to assist us in identifying you with credit reporting agencies and for internal fraud prevention purposes.

Information we receive from consumer reporting agencies, financial services providers and other sources We may collect personal information from consumer reporting agencies, including information about your credit scores and creditworthiness. We may also receive credit score or creditworthiness or other financial information from other sources including Resellers and financial service providers such as licensed insolvency trustees, licensed insolvency counsellors, debt management solutions companies, mortgage brokers and specialty lending partners.
Information we may receive from third party account verification service providers Information from your visit to our website and your use of our Services We may collect personal information (e.g., bank account and income verification information) from third parties that provide account verification services. We collect information related to your visits to our website and interaction with our Services. This information may include:

• Information from or about the devices you use to access our Services;

• Browsing information, using cookies, web beacons and mobile device identifiers to collect information; and

• Your account balance, account activity and usage of various Services.

Information you provide when you communicate with us This may include your name and contact information and other information you choose to provide us.

We may also collect additional information as otherwise described to you at the point of collection or pursuant to your consent. 

We may monitor and record our telephone conversations with you for training and quality assurance purposes. You will be provided with a notice at the beginning of any call that is being recorded. If you do not wish to have your call recorded, please let us know. 

How we use your personal information

We may use the personal information we collect from you in the following ways:

  • Information you give us when applying to use or when using our Services. We use this information to communicate with you and provide you with the Services. We use unique identifiers (e.g., Social Insurance Numbers) to identify you with consumer reporting agencies and other institutions for credit history file matching purposes. We use information about your personal background to serve you better. We use payment or banking information to complete transactions with you and on your behalf as you may request.
  • Information we receive from consumer reporting agencies, financial services providers and other sources. We use this information to help us determine the Services that would be appropriate to offer you and tailor our Services for you. Consumer reporting agencies we may receive personal information from include TransUnion and Equifax. We may also receive personal information from Resellers and licensed insolvency trustees, licensed insolvency counsellors, debt management solutions companies, mortgage brokers, and specialty lending partners.
  • Information we receive from third party account verification services. We use this information for the purposes of instant account verification, which helps us provide you with the Services more quickly and reduce the risk of fraud.
  • Information from your visit to our website and your use of our Services. We may use information we collect from your interaction with our Services to tailor our offering to you and improve our Services.
  • Information you provide when you communicate with us. You may also provide personal information when you contact us with a question or a concern. We will use this information to address your question or concern and may use this information to improve our Services.

As permitted by applicable law, we may from time-to-time also use your personal information to keep you informed about our Services and about other products or services that may be of interest to you, to improve our Services and to administer contests or surveys. You may opt-out of the marketing and promotional messages but you will continue to receive other communication from us that is necessary to provide the Services. To opt-out of marketing and promotional messages click the “unsubscribe” button in the marketing and promotional message or Contact Us

We may also use online advertising services provided by Google, Facebook and other providers. These advertising services use tools to place advertisements on third party websites based on your past visits to our website. You can choose to opt-out of receiving Google’s tailored advertising services by visiting Google’s Advertising – Privacy & Terms page: http://www.google.com/privacy_ads.html. You can choose to opt-out of Facebook’s tailored advertising services by visiting https://www.facebook.com/help/568137493302217.

Sharing your personal information

We will not disclose, trade, rent, sell or otherwise transfer your Personal Information, without your consent, except as otherwise set out herein. We use information we hold about you to provide our Services to you and improve those services, manage your account and communicate with you and to use information on an anonymous basis for research, profiling and analytical purposes. 

Service Providers: We may share your information with third party service providers. We use technology provided by third party partners, including Point Deduction Technology®, which analyzes credit data to identify where the impacts are placed on a credit file and 200 OK, LLC (“Profitwell”), which analyzes personal information and payment data to improve our products and Services, improve communication to you, and reporting and analytics. We share your personal information with these technology providers to provide you with the Services, including providing cloud computing infrastructure. We may also share your personal information with other third parties to provide the Services you choose, including consumer reporting agencies (e.g., TransUnion), financial institutions, insurers, other financial services providers, customer service providers and marketing communications providers. We also may share your personal information with third parties that process payments on our behalf. We may share your personal information with third parties to conduct research and analysis to improve and obtain knowledge on the Services you choose. We may share your information with affiliates of MARBLE but only for the purposes described in this Privacy Policy.

Investors: Loans are funded through capital provided by third-party investors. Information about current and former customers will be shared on a non-identifiable basis with current as well as potential investors. The information provided to investors includes aggregated data derived from customer credit history data and loan performance information. The information is presented in a manner that the identity of an individual would not be identifiable from the data. We share this information in order to allow current and potential investors to evaluate the performance of the loans. For example, the data may be used to determine default and delinquency rates in the loan portfolio, or to present aggregate information on creditworthiness. 

Business Partners: If you use certain Services we will share certain personal information we have about you (such as your contact information) with third party business partners (for example, if you submit a loan questionnaire or if we pre-populate an application with your information). In these situations, we will confirm with you that we will be sending your information or we will send you to the business partner’s site or platform for you to provide the information directly to them. 

Resellers: We may share your personal information with the Resellers or the referral company that referred you to our Services for the purpose reporting and analytics, including the of tracking the outcome of your account and applications with us. This information may be used for the payment of commissions to third parties for referring you to our services.  

Legal/ Compliance: We may have to share your personal information in special circumstances. This would include situations when sharing is required by law, or we believe sharing will protect the safety, property or rights of MARBLE, our customers, or others. For example, we may share your information in response to a legal request (such as a subpoena, search warrant, or court order) if we believe, in good faith, that we are required to do so by law. 

Sale of Business: We may also share your information in connection with a sale, merger, bankruptcy, sale of assets or reorganization of our company. In such a case, we may share information with potential purchasers, successors and their advisors. This information could also be shared or transferred in the unlikely event that we are the subject of a bankruptcy or insolvency proceeding. 

Transfers of personal information outside of Canada

Some of our third-party service providers, including the provider of Point Deduction Technology®, are located outside of Canada. In order to use these third-party service providers, we may transfer your personal information outside of Canada. When we do that, your personal information may be subject to foreign laws and potential access by law enforcement or other governmental agencies in those countries.

Third-Party Links 

Our Services may contain links to other sites that we do not own or operate, including social media websites. Also, links to our Services may be featured on third-party websites on which we advertise. Except as provided herein, we will not provide any of your Personal Information to these third parties without your consent. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information. 

Protecting your personal information

We maintain reasonable safeguards to protect your personal information against loss or theft and unauthorized access. These safeguards include physical, organizational and technical measures appropriate to the sensitivity of the information we collect and store. While we implement safeguards and are committed to protecting your personal information, no information can be guaranteed to be 100% secure from unauthorized access.

Retaining your personal information

We will retain your personal information as long as needed to provide the Services. We may, however, retain your personal information even after you have closed your account if retaining the personal information is reasonably necessary to comply with legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms of Service.

Your choices

If you are an individual that applies to use our Services, you may elect not to provide certain information. For example, you may choose not to provide your Social Insurance Number or certain financial information . However, by not providing all of the information requested in the application, you may not be able to take full advantage of our Services and it may hamper our ability to provide you with the Services you want.

You can choose how you receive communications from us by changing the communication preferences in your account settings or by clicking on an unsubscribe link in an e-mail from us. Please note that we may continue to send you certain communications relating to the management of your account.

Cookies

We may use technologies such as cookies to collect information about the use of our websites and mobile services. A cookie is a small text file stored on your computer that provides a way for our web site to recognize you and keep track of your preferences. Cookies allow us to provide you relevant information as you use and when you return to our website and help us to provide a personalized experience for you. Most web browsers contain controls that allow you to block or delete cookies (this is usually done through privacy settings). Certain features of our site depend on cookies; if you choose to block cookies you may not be able to use those features or may lose preferences based on those cookies. You can read more about cookies at this link.

Changes to our Privacy Policy

From time to time, we may make changes to our Privacy Policy. When we make changes, we will revise the last updated date in this Privacy Policy. We encourage you to consult this website for updates to the Privacy Policy. We will notify you if we make changes to this Privacy Policy which may have a significant effect on how we treat your personal information.

Accessing your personal information

You can access and update your information by logging into your account and entering or updating your information. You can also contact us https://mymarble.wpengine.com/contact/ to access your personal information. We will respond to requests to access, update or delete personal information.

Information for Resellers

We ask prospective Resellers to complete an application form and provide contact information and other relevant information. We use this information to communicate with Resellers and provide the Services to Resellers. Resellers with questions about our Privacy Policy should Contact Us.

Contact Us

Karim Nanji, Privacy Officer
1166 Alberni St #1200
Vancouver, BC  V6E 3Z3
Phone: 855-539-6784
Email: [email protected]