Privacy Policy

Moves Financial Inc. operating as Moves (“Moves”), provides quick loans to approved members of the gig economy. This privacy policy (“Privacy Policy”) summarizes what personal information we collect when you visit our website, use our mobile application, apply for or use our products and services, or otherwise provide us with personal information. It also explains how we use and disclose this information, and how you may opt-out of some practices.

By using our website or mobile application (together the “Site”), or by choosing to give personal information to Moves, including through using our Site, or applying for or using a financial product (together the “Services”), you signify your consent to all of the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use this Site, or the Services and do not give us any personal information.

This Privacy Policy includes the following sections. You should read the entire policy; however, you may use the links below to be directed to the information you want:

1. Personal information that we collect and how we collect it. The personal information we collect depends on how you use our Site and Services. We may collect information such as your name, contact information, password, and financial and identification information, including information about your work, information related to your loan, lease or other credit products or other transactions with us or others, including account numbers, balances and historical balances, account history such as transactions you make, overdrafts, debts and available credit, direct deposit number and transit numbers, bank account authentication information, and information about your financial and credit history and worthiness, such as any defaults, or declarations of bankruptcy. We may collect this information when you first contact us, and from time to time during our relationship.
2. How we use personal information. We use personal information for the purposes for which it was collected, or as provided in this Privacy Policy or in any agreement you have with us. This includes creating your account and providing you with access to the Services, confirming your identity and eligibility for our Services, evaluating your credit worthiness and deciding whether to offer our Services, to manage, administer, maintain, service, collect and enforce our Services, including to extend loans, implement fund transfers, and to collect payment, contacting or notifying you, offering or obtaining services such as insurance, investigating or settling disputes, or to protect our rights or those of others. We also use personal information to investigate breaches, fraud, or cooperate with authorities, and to manage, protect and improve our business, such as by providing customer service, developing new products and services, marketing, conducting analytics, and for legal compliance.
3. When we share personal information. We may disclose information to service providers that assist us with the purposes set out in this policy.
4. How we collect information using technology. We use technologies, including cookies, web analytic tools, beacons, and pixel tags, to collect technical information such as domain name, time of visit, pages of our Site visited and what features and links are clicked or used, what advertisements are viewed or interacted with, how you interact with our communications, IP address, Internet Service Provider, operating system, web browser, and the website visited immediately before coming to our Site. We may use this information, and personal information, to manage our Site, diagnose any technical problems, track click streams, measure, monitor, and report on website traffic and page views, language preferences, how visitors arrive at our Site and interact with our content, determine which of advertisements are the most effective, and remember you, and improve the content of our Site.
5. How to Opt-Out of certain uses of your Personal Information. You can opt out of certain of our practices, including some online data collection, our commercial email, and push notices.
6. Security. We use technical, contractual, physical, and administrative security measures to help protect the personal information in our possession, but we cannot ensure 100% security for any personal information you provide. There is always a chance of a data breach.
7. We may transfer personal information outside your country. By providing us with personal information, you understand and expressly agree that we may transfer some or all of that information to be stored or processed outside of Canada, including in the United States.
8. How to Access and Correct your Personal Information. Subject to certain limits, you may access, review, and request correction to your personal information that we hold.
9. Children. We do not intend to collect personal information about children under 13. If we do, the parent or guardian of the child may ask us to delete it.
10. This Privacy Policy does not apply to third party sites. This policy does not apply to sites we do not control. We are not responsible for such sites.
11. This Privacy Policy may Change. You should review this privacy policy from time to time. We may change it.
12. How to Contact Us. You may contact us at [email protected].

1. Personal information that we collect and how we collect it

Personal information is information about an identifiable individual, such as your name, address, your telephone number, email address, or financial information (“personal information”).

The personal information we may collect depends on how you choose to use our Site and Services.

We collect personal information when you voluntarily provide it through our Site, or when you apply for our Services, such as a loan, from time to time while you continue to use our Services, or when you provide it to us through other means.

For example, Moves collects personal information:

1. Registration Information. When you register on the Site we collect your full name, your email address, and your chosen password. You may also provide us with your mailing address and telephone number.
2. Application, Credit and Financial Information.
   • If you apply for a loan or other Services, we collect your full name, address, telephone number and email address. We will also need information to verify your identity, and your financial information, to determine if we are able to offer you a loan, and if we are, to administer it. We collect this information when you first apply for our services, and we may update it from time to time as long as you use our Services.
   • This Application, Credit and Financial Information may include information about your work in the gig economy (for example, the company you work with, and the frequency and amount of your payments), information establishing your identity (e.g. name, date of birth, and contact information), and information related to your loan, lease or other credit products or other transactions with us or others. This may include your account numbers, balances and historical balances, account history including transactions you make (including the date, description, amount, and category of each transaction), overdrafts, debts and available credit, direct deposit number and transit numbers, bank account authentication information, and information about your financial and credit history and worthiness, such as any defaults, or declarations of bankruptcy, and information to allow us to process pre-authorized payments.
   • We collect Application, Credit and Financial Information from your financial information, such as a bank. This information is collected by our service provider, Plaid. Plaid transfers, stores, and processes your personal information in accordance with Plaid’s privacy policy which you can Read Here.
3. Contact Information. If you subscribe to a mailing list/request a newsletter, or communicate with us, we collect your name, email address, telephone number and mailing address. We collect the contact information you provide for our reply, as well as any information you include in your communication.
4. Other Information. We also collect any other information you choose to provide us.

For information about how we collect technical information from your computer or mobile device, please see “How we collect information using technology”.

2. How we use Personal Information

The personal information we collect may be used for the purposes for which it was collected, as provided in this Privacy Policy, our loan agreement or application, or for other purposes that are disclosed to you and to which you consent.  We mainly use personal information to offer our Services, including processing loan applications, and managing the loans we issue.

For example, we may use your personal information in the following manners:

• Registration Information.We use your registration information to create your account and provide you with access to the Services we provide through our Site. This may include allowing you to assess information about your use of our Services, such as the status of your loan, and information about your payments.
• Application, Credit and Financial Information.We use your Application, Credit and Financial Information to:
  1. confirm your identity and confirm you are a member of the gig economy;
  2. decide whether to offer our Services, including to determine your current and ongoing creditworthiness, to establish the existence of and condition of your bank account and other financial products;
  3. manage, administer, maintain, service, collect and enforce our Services, including to extend loans and transactions, implement fund transfers, and collect payment in accordance with our loan agreement. For example, if you have signed up for pre-authorized debits, we collect your payments directly from your designated account;
  4. connect with you if there is a problem related to a transaction you requested or to discuss a problem with your Moves account;
  5. obtain ourselves, or offer you, other products and services related to our Services, such as credit insurance or underwriting;
  6. investigate and settle any dispute or claim which relates to our Services; and
  7. assign, whether as security or otherwise, any or all of our rights or interest in, our portfolio of loans.
• Contact Information.If you request to join our mailing list, we will take your name and email address. Once we have collected this information, you will receive our email alerts, informing you of news and special offers (including any promotional offers from third parties). You can also receive special promotions and other benefits, such as information about new product introductions and special events. You can remove yourself from our commercial email list at any point by clicking “unsubscribe” in the commercial emails sent to you. However, even if you opt-out, we may still send you transactional notices regarding your use of our services, such as statements, or notices if we change our terms, agreements, or privacy policy.

  We may also use contact information to administer the Services we provide you. For example, we may send you transactions information about the Services, such as when a payment is due, using your mailing address, your email, a push notice to your device, or other information available to us. You may be able to turn off push notifications through your device settings.

  If you contact us with a question or comment about our products, Services or Site, we may require certain information so that we can help you, such as your name, email address or phone number. We use the information you provide to respond to your question or comment.

• Other uses of personal informationWe may also use your personal information to:
  1. investigate security breaches or cooperate with government authorities pursuant to a legal matter;
  2. manage our business, including to keep business records, and meet legal and regulatory requirements;
  3. provide customer service and to communicate with you;
  4. maintain, protect, improve and provide our Services, including for the development of new product and service offerings;
  5. notify you about changes to our Services;
  6. keep records of your communications with our customer support team;
  7. enforce and apply our terms or any agreement you have with us;
  8. carry out marketing purposes, such as to offer our products and services to you;
  9. offer you tailored products and services;
  10. conduct and report on certain analytics, benchmarking, and performance tracking with aggregate data; and
  11. comply with applicable laws and regulations.

  We may also use personal information to provide customer service, for credit, or fraud prevention and to protect our company, our Site, and our customers. This includes investigating and remediating fraud or other suspected illegal activity. For example, we may use information to detect intrusions into our network. We might share our server logs, which contain visitors’ IP addresses, with investigative authorities who could use that information to trace and identify you.

  We may also use personal information for any other purpose permitted or required by applicable law.

  Personal information collected online may also be combined with information you have provided to Moves through other sources such as over the telephone.

  We may also anonymize, aggregate or otherwise strip any personal 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:

From time to time we engage unaffiliated third parties and their affiliates, agents and subcontractors (“Service Providers”) to perform services for us. For example, we work with Plaid to obtain information from your financial institution when you apply for our Services.

A Service Provider may be asked to perform payment processing services, including administering pre-authorized debits. We also may use a Service Provider to host and administer one or more of our Sites, process and store data, and fulfill similar technology-related functions on our behalf or to carry out any other purpose described in this Privacy Policy. We also may engage Service Providers to provide us with computing services. Examples of these services include online file storage, webmail and online business applications.

We reserve the right to transfer any personal information we have about you in the event that 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 your 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. Lastly, we may disclose your personal information for any other purpose to which you consent, or which is permitted or required by law.

4. How we collect information using technology

In addition to the personal information described above, we may collect information about your use of the Site through electronic tools such as cookies. Moves may automatically receive information from you or your device as part of your connection to our Site. This may include network routing information (where you came from), equipment information (browser type) and date and time.

Moves may also use cookies, embedded URLs, embedded pixels and other similar technologies to capture additional information.

The information that we or our service providers may collect through electronic means may include:

• your domain name,
• the time of your visit,
• which pages of our Site you visit and what features and links you click or use,
• what advertisements you view or interact with,
• how you interact with communications we send you, such as whether you open an email we send you,
• your Internet Protocol (IP) address,
• your Internet Service Provider (ISP),
• the Operating System (Windows, Macintosh, etc.) you use,
• the web browser (Netscape, Internet Explorer, etc.) you use, and
• the identity of the website you visited immediately before coming to our site.

We may use this information and personal information to help us:

1. Manage our Site,
2. Diagnose any technical problems,
3. Track click streams, measure, monitor, and report on website traffic and page views,
4. Determine how visitors arrive at our Site and interact with our content, including determining which of our advertisements are the most effective,
5. Remember you as you navigate through our Site, and if you return too it, and
6. Improve the content of our Site.

We may work with third parties that help us collect and use information in this manner. For example, we work with Google Analytics, which uses cookies and other technologies to collect and analyze information about the use of our Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and resources. We may use this for impression reporting, and to learn, on an aggregate basis, about the demographics and interests of people who visit our website or click our advertising. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at: https://tools.google.com/dlpage/gaoptout.

Cookies. Moves’ server may query your browser to see if there are “cookies” previously set by the Site. A cookie is a small piece of information sent by a web server to store on a web browser so that it can later be read back from that browser. Cookies on the Site may collect a unique identifier and user preferences. Moves also uses cookies to collect general usage, volume, and statistical information.

Most browsers provide you with information and control over cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their browser without affecting their ability to use the Site, except in some cases where cookies are used as an essential security feature necessary for transaction completion.

Embedded pixels. Moves may also use embedded pixel technologies on selected pages for the purposes of identifying unique user visits to the Site, as opposed to aggregate hits, and to identify the pages viewed.

5. How to Opt-Out of certain uses of your Personal Information

If you receive commercial email from us, you may opt-out by using the ‘unsubscribe’ tool at the bottom of such messages. If you receive push notices from us, you may be able to turn off push notifications through your device settings

6. Security

Moves uses a variety of security technologies and procedures, including organizational, technological, and physical measures to help protect your personal information from unauthorized access, use, or disclosure.

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 indicated above.  Personal information we collect is managed from our offices in Toronto.

Even though Moves has taken steps to help ensure that your personal information is not intercepted, accessed, used, or disclosed by unauthorized persons, 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.

7. We may transfer personal information outside your country

Some or all of the personal information we collect may be stored or processed outside of Canada or your jurisdiction of residence, including in the United States. Your personal information may be processed and stored in the United States and the governments, courts or law enforcement or regulatory agencies of the United States may be able to obtain disclosure of your personal information through a lawful order made where the information is located.

By providing us with personal information, you understand and expressly agree that we may transfer it outside of Canada or your jurisdiction of residence. If you do not agree to the transfer of your personal information outside of Canada or your jurisdiction of residence, do not provide us with personal information.

8. How to Access and Correct your Personal Information

You have a right to request access to your personal information and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal information Moves has about you, or if you would like to have it corrected, 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. For example, we may require you to verify your identity before you access your personal information.

9. Children

We do not intend to collect information from children who are under 13 years of age. If you are under 13, please do not provide us with any information.

If you are the parent or legal guardian of a child who has provided us with personal information, you may ask to review or delete this information.

10. This Privacy Policy does not apply to third party sites

Our Site may contain links to websites owned by third parties. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit. Any links from this Site to other websites, or references to products, services or publications other than those of Moves, do not imply the endorsement or approval of such websites, products, services or publications by Moves.

11. This Privacy Policy may Change

Moves reserves the right to modify this Privacy Policy at any time. We will promptly reflect any such modifications to this Privacy Policy on our Site and will indicate at the top of this page the date this Privacy Policy was last amended. Your continued access to and/or use of the Site or the Services after any such changes constitutes your acceptance of, and agreement to this Privacy Policy, as revised.

Please periodically review this Privacy Policy so that you know what personal information we collect, how we use it, and with whom we may share it.

12. How to 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;
• request the deletion of personal information regarding your minor child; or
• to submit a complaint

Please advise us by contacting our Privacy Officer by email at [email protected].