Privacy Policy

This privacy policy sets out how Vambora Inc. (“Vambora”, “we”, “us”, or “our”) collects, uses, and discloses, any personal information that you give us or that we collect when you use our website or Services. Vambora offers a platform intended to help newcomers to Canada and others with poor, thin and non-existent Canadian credit profiles to prove their identity and create a trust profile that can help them get approved for financial services, tenancy and other products and services in Canada using their financial history in their home country (“Services”). You may ask a business in Canada with a direct need to access a trust profile or verify identity, both as allowed by the applicable law, to contact us about you. We will not provide your trust profile to a business without your permission.  

By using our Services, or by choosing to give us personal information, you consent to this Privacy Policy and the processing of your Personal Information it describes.  

If you do not agree with any terms of this Privacy Policy, please exercise the choices we describe in this Policy, or do not use the Services and do not give us any personal information. Vambora may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. Your continued access to and/or use of our website or services after any such changes constitutes your acceptance of, and agreement to this Privacy Policy, as revised.


Policy Summary

1. What Personal Information we Collect. We collect personal information to provide our site and Services. As a result, the information we collect about you depends on what Services of ours you use. We may collect biographical information such as your name, date of birth, mailing address,
telephone number, and email address, information about you, such as nationality, destination information about your needs, the stage and timing of your move, your interests and preferences, information about the services you need, information about your financial situation such as income, employment status and employer, education history, bank account information, balances, statements, transaction history, payments, information about your assets, debts, information about loans or other financial products, your credit worthiness, your financial institution, account type and numbers, including branch information, account ownership, IBAN, BIC, routing number, and sort code. We may also collect government ID, passport, visa, and your letters of acceptance, and any
other information you choose to provide to us. If you are a business or landlord that uses our Services, we collect payment information, and other information about needed to provide the Services.   If you create a trust profile, we use trusted third party service providers to collect your
financial account(s) access credentials, and retrieve your financial information. Vambora does not collect your access credentials directly.

2. How we Use the Personal Information we Collect. We use the information we collect to provide our Services and for the purposes we describe in this Policy. For example, at your request we use personal information to create your trust profile, to verify your identity, for record keeping, to improve our Services and site, to respond to you, for promotional purposes, including to provide you with information about communities and third party organizations, to administer and enforce
our terms and agreements, to respond to you, to investigate and settle disputes, to investigate security breaches or cooperate with government authorities, and to comply with applicable laws. We may also use information for other purposes to which you consent.

3. How we Share Personal Information. We may share information with third parties that help us provide our Services. For example, we may use a third party to host our website. With your consent, may collect financial information from your financial institution using a third party service
provider. Please see “When we Share Personal Information” for more information. If you ask, we may share your trust profile or identity verification with a third party whose services you are interested in, such as a financial institution or landlord. We may also share information if we enter a business transaction, to protect ourselves or others, or if required or permitted by law.  

4. How we Collect Information using Technology. We use cookies and other technologies to collect information about how our site is used. This may include IP Address or device ID, operating system, browser type, username, the pages of our site that you visit, the time spent on those
pages, access dates and times, clicks, links used, and actions you take on our site, any errors you encounter, and general location derived from IP address. We use this information to identify which portions of our Services are being used and how they are being used. This helps us analyse traffic
on our site, correct any errors our users encounter, and improve our services in order to better tailor them to user needs. We also use this information for statistical analysis purposes. We work with Google Analytics to collect this information and demographics to understand how our site is used. For more information, including how to opt-out of certain Google Analytics, visit: www.google.com/policies/privacy/partners/.

5. Your Choices. If you receive marketing from us, you may contact us to ask us not to send you marketing. You may also use the ‘unsubscribe’ tool we include in our commercial email. You may also withdraw your consent to our processing your personal information. Please note that if you
withdraw consent for our processing of information we need to process to provide our Services, we may not be able to provide those services to you. You also have rights to access and correct the personal information we hold about you.

1. What Personal Information we collect
“Personal Information” is information that may identify an individual such as a first and last name, home or other physical address, an email address, payment information, or a phone number or other contact information.

The Personal Information we may collect depends on how you choose to use our Services. For example, we may collect the following information:
• Biographical information such as your first and last name, date of birth, country of origin, employer and employment status, and other biographical information you choose to provide, such as a description of yourself you would like to share with potential landlords or service providers.  
• Contact information including mailing address, telephone number, and email address.
• Information about your move to another country, including your nationality, destination province/territory and city/community, information about your needs, the stage and timing of your move, your
interests and preferences and desired lifestyle, such as information about the services you need or wish to arrange.
• Information about your financial situation or to verify your identity. With your consent, we may obtain financial information from your bank or other financial services provider(s) using a third party data aggregator, both in Canada and in your home country. The data we obtain from your bank accounts, using the data aggregators you authorize to access those accounts (“data providers”), differs based on several factors. These factors consist of the type and manner in which the information is provided by the banks and financial institutions, along with how the data aggregators subsequently share that information with us. This may include information about your bank accounts obtained from your financial
services provider, including:
    •  account information, including financial institution name, account type, account numbers (including if you have them, savings, chequing, and credit card), including branch information, account ownership, IBAN, BIC, routing number, and sort code,
    •  identifiers and information about the account owner(s), including name, email address, phone number, date of birth, and address information,
oaccount balances and available funds,
    •  bank statements and account statements,
    •  information about your transaction history, such as whether you make your payments on time or miss payments, the amounts, type, dates and frequency of payments,
    •  income, sources of income, assets, and asset class,
    •  outstanding debts,
    •  information regarding other loans, leases or other credit products you may have,
    •   information about your employment and educational history, and
    •  other information about your credit worthiness.


• Identifying information such as your government ID, passport, visa, a letter of acceptance from an educational institution, and other information you choose to provide. If you use identity verification services, you provide your information directly to a third party service provider named Plaid. Plaid collects information including measurements of your face to conduct a comparison to your ID to confirm you are who you say you are. Vambora does not receive your facial measurements. We only receive whether you pass or fail the check, or if the request expired. If you use identity verification, you must review and agree to the Plaid privacy policy:
https://plaid.com/legal/#consumers  
• Other information such as your communications with us, emails, surveys, and/or other information
that you choose to provide to us.

2. How we Use the Personal Information we Collect
We use the information we collect to provide our Services in accordance with our Terms and Conditions, to understand your needs and provide you with better service, and in particular for the following reasons:
• To allow us to process and provide the services you request, including if selected by you, by creating a Trust Profile to assess and reflect your credit worthiness and financial capacity, and to confirm your identity. Based on the information we collect, your Trust Profile may be “poor”, “fair”,
“good”, “very good”, or “exceptional”. This is called your “Vambora Trust Profile”. Your Trust Profile may be used by others you select and consent to receiving it, to decide whether to do business with you.
• To verify your identity, and to allow businesses and landlords you choose to do so as well.  
• To allow you to create an account to access our platform and use the functionalities and Services we offer.
• To provide you with information about communities and third party organizations in Canada, from whom you may wish to receive products, services, or information. For example, we may provide you with information about telephone, financial services, insurance, internet or wireless, offered by third parties.
• To assist you with generating a customized plan for your move.
• For our internal record keeping.
• To improve our Services and the user experience on our platform, or to develop new products and services.
• To send promotional emails and other communications about our Services, special offers or other information which we think you may find interesting. We do not use your financial information or Trust Profile for this purpose.
• To manage, administer, maintain, service, collect and enforce our Terms of Service, or any other agreement we have with you.
• To respond to your questions or complaints.
• To investigate and settle any dispute or claim which relates to our site, or Services, and to enforce our Terms of Service.  
• To investigate security breaches or cooperate with government authorities pursuant to a legal matter.
• To comply with applicable laws and regulations, including applicable ‘know your client’ and anti-money laundering requirements.
• For other purposes which are disclosed to you and to which you consent.

We may also anonymize, aggregate or otherwise strip any personal information or other information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data
with third parties for any purpose we deem appropriate.

3. When we Share Personal Information  
With your consent, we share your name, contact information, address history, personal statement (if you provide one), Trust Profile, including your financial institution name, account numbers and types, account
balances, account statements if available, income and sources of income, with other companies or people you select. For example, if you tell us to, we share your Trust Profile with entities such as a potential landlord, a financial institution, or a service provider such as an insurance company, or telephone or internet services providers. You may choose to fill out a form and ask us to give that information to a financial institution whose services you are interested in or to a landlord if you apply for an apartment.

Your Trust Profile and identity verification allow the companies you select to assess your credit worthiness, financial capacity, and ability to pay for their services, and/or repay your debts. It also allows them to confirm your identity, and to detect and prevent fraud. Based on your Trust Profile, these companies may choose to do business with you. They may also choose not to. Vambora is not responsible for the decisions of any other company or entity.  

To share your Trust Profile, you must provide us with the email address of the service provider you want to grant access to. You must carefully check the address you provide and ensure it is correct. If you give us an incorrect address, your Trust Profile can go to the wrong person. We are not responsible for any errors where you provide us with incorrect information.

Similarly, if you are a business or landlord that has been asked by a consumer to access their Trust Profile or verify their identity using our services, you are responsible to ensure you provide us with the correct information for that consumer. You may only do so if: 1. you are considering entering a business or tenancy relationship with that specific consumer (or otherwise have a lawful need for the information you seek); and 2. You have the express consent of that consumer.

We may share your personal information with third parties that help us use your personal information for the purposes described in this Privacy Policy. For example, we share personal information with service providers that assist us with the activities described in this Privacy Policy, such as data providers, payment processors, and companies that help us run our website. If you create a Trust Profile you will be asked to provide the access credentials to your financial account(s) to a third party data provider. Vambora and third parties, such as landlords and financial institutions, do not receive your access credentials directly, and are
not able to make any transactions using your account. You must review and agree to the Privacy Policy of the service provider for your region here:

• For Brazil, Mexico, and Colombia
  •  Belvo Privacy Policy: https://belvo.com/privacy-policy-end-users/
• For North America and EU
  •  Plaid Privacy Policy: https://plaid.com/legal/#consumers
• For Vietnam, Singapore, Philippines, Malaysia, Indonesia, Hong Kong
  •  Finverse Privacy Policy: https://www.finverse.com/legal/
• For India and Australia
  •  Envestnet | Yodlee Privacy Policy: https://www.yodlee.com/legal/privacy-notice

We reserve the right to transfer any personal information we have in the event of bankruptcy, or if we or any part of our business merges with or is acquired by a third party, or if any such transaction is proposed.

We may also disclose personal information to third parties if we have reason to believe that disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or
bring legal action against someone who may be violating an agreement they have with us; or (iii) to protect our rights, safety or property, or those of others.

Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise
protect our rights.

4. How we use cookies and collect information using technology
A cookie is a small file which is placed on your computer or mobile device’s hard drive. Cookies and other technologies can help analyse web traffic or let us know what portions of our site people visit and what features they use. We may use cookies and other technologies to identify and keep track of, among other things, your Internet Protocol ("IP") address or device ID, operating system, browser type, username, the pages of the website or App that you visit, the time spent on those pages, access dates and times, clicks, links used, and actions you take on our site, any errors you encounter, and general location derived from IP address.

We use cookies and other technologies to identify which portions of our Services are being used and how they are being used. This helps us analyse data about traffic on our site, correct any errors our users encounter, and improve our Services in order to better tailor them to user needs. We also use this information for statistical analysis purposes.
You can also choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from
taking full advantage of the Services.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

Our Site uses Google Analytics, which is a web analytics service that provides statistics and analytical tools. We use Google Analytics on our website to analyze how users use the Site. Google Analytics may collect information such as general location as inferred from IP address, the amount of time a visitor spends on our Site, which pages are more frequently accessed, how the website is accessed (either directly, a search engine, or from a link), what sort of software is used (e.g. operating system, browser type, etc.), as well as demographics. For more information on how Google Analytics collects and processes information, please visit the Google Privacy Terms web pages: https://policies.google.com/privacy?hl=en,  and  www.google.com/policies/privacy/partners/.  

For information about how to opt out of having your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/.  

Mixpanel
We use a service provider called Mixpanel to understand your users interact with our website.  You may learn more about Mixpanel on their website: https://mixpanel.com/. You may review the Mixpanel privacy policy here: https://mixpanel.com/legal/privacy-policy/  

5. Security and Retention
In order to help prevent unauthorised access or disclosure of personal information, we have put in place physical, electronic and managerial procedures to help safeguard and secure the personal information we
collect.

Personal information may be accessed by persons within our organization, or our third-party service providers, who require such access to carry out the purposes described in this Privacy Policy, or otherwise permitted or required by applicable law.  Personal information we collect is primarily managed from our offices in Kitchener, however, we may also store personal information in other locations.

Even though we have taken steps to help protect the personal information in our control, you should know that we cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.

We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law. The criteria we use to determine our retention policies include the length of our relationship with you, your requests, your continued use of our site, ongoing obligations such as contracts and services, and our legal obligations.

6. We may Transfer Personal Information to Other Countries
Personal information that we collect may be stored and processed in a jurisdiction other than the one it was collected in, including any country in which we or our data providers maintain facilities, such as Canada,
and the United States. We may use service providers in other jurisdictions for any of the purposes described in this policy.  

Personal information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to
its laws.

By using our Services or by providing us with personal information, you consent to any such transfer of information outside of your country. If you have any questions about our use of service providers outside of Canada, you may contact us using the information below.

7. Links to other websites
Our Services may contain links to other websites that may interest you. For example, we may link to Canadian service providers, such as insurance companies, financial institutions, telephone companies or internet services providers. However, once you have used these links to leave our Site or App, you should note that we do not have any control over that other website. We cannot be responsible for the protection and privacy of any information which you provide when visiting such sites, and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to any website you visit.

8. Your Choices
You may choose to restrict the collection or use of your personal information in the following ways:
• You may write to or email us using the contact information below to withdraw your consent to us using your personal information for direct marketing purposes.
• If you receive commercial email from us, you can also unsubscribe using the unsubscribe tool we provide in such messages.
• If you have given permission for a third party to view your Trust Profile, that permission is valid for only 30 days. You may also withdraw that permission. However, you should know we cannot control whether the third party may have copied your information while they had access to it. You must contact the third parties you have allowed to access your Trust Profile to exercise your privacy rights in respect of them.

You may also withdraw your consent to our processing your personal information. Please note that if you withdraw consent for our processing of information we need to process to provide our Services, we may not be able to provide those services to you. Your withdrawal of consent does not have retroactive effect.

You also have rights to access and correct the personal information we hold about you as described below.

9. Your Rights
Under certain circumstances and subject to applicable data protection laws, supported by a written request and a proof of identification, you may consult the personal information that we have collected, used or disclosed, and/or ask that it be corrected, and/or withdraw your consent to our disclosure or use of personal information collected. As required or permitted by law, you may be entitled to additional rights regarding your personal information, including: (i) the right to control the dissemination of your personal information; (ii) the right to receive computerized personal information collected from you in a structured, commonly used and technological format and to have this information transferred directly to another organization; (iii) the right to be informed of and submit observations regarding automated decision-making; and (iv) the right to request information about data processing.

Finally, you have also a right to lodge a complaint with a competent data protection authority, in particular in the country/province/state where you normally reside, where we are based or where an alleged infringement of data protection law has taken place.

To exercise any of these rights, please contact us using the contact information provided below. In some cases, we may not be able to allow you to access certain personal information in certain circumstances, for
example, if it contains personal information of other persons, or for legal reasons.

To help protect against fraudulent requests for access to your personal information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the below address.

10. Children
We do not intend to collect information from children. If you are under the age of majority where you live, please do not provide us with any information.

11. Contact Us
If you have any questions regarding this Privacy Policy, any personal information you have submitted to us, or if you would like to:
• access personal information that you have already provided to us so that you can correct or update it; or
• to submit a complaint,

Please advise us by contacting our Privacy Officer by writing to:  COO, 151 Charles Street West, Suite   100,   Kitchener,   Ontario,   Canada,   N2G   1H6. You   may   also   email   us   at privacy@vambora.com.Last updated: April 2023

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