Last updated: November 1, 2020
(“Fraction”, “we”, “us”, our
“) is committed to protecting the privacy of its customers and users. Fraction makes every effort to ensure that its customers and users understand the nature, purposes and consequences of the collection, use, and disclosure of their personal information, which we explain in this Privacy Notice. For the purposes of this Privacy Notice, “personal information”
means any information that can reasonably be used, either alone or in combination with other information, to identify you.
When does this Privacy Notice apply?
This Privacy Notice explains how Fraction collects, uses, and discloses your personal information when you inquire about, apply for, or purchase Fraction Equity Financing or any other product (“Fraction Product
”) from us.
This Privacy Notice applies as long as you have a relationship with us. In addition, this Privacy Notice applies to information we may collect from you when you visit us at https://www.fraction.is/
, (the “Site
”) or when we communicate via email or telephone.
What personal information does Fraction collect and how does it collect it?
We may collect the following types of personal information directly from you at the point of purchase or service, when you make customer service inquiries, or when we respond to your requests for information:
Information establishing your identity
(such as your name, address, email address, phone number, occupation, date of birth, or copies of government-issued documents);
Information about your financial status
, including your annual income, assets (including the value of your home), and liabilities (including the amount of any remaining mortgage on your home).Information about your balances and transactions
, including any Fraction Product account activity or payment history;
If you send us an email, send us a message on the ‘Contact Us’ page of the Site, phone us, or speak to us using the Site’s live-chat feature, we may collect personal information you provide to us during those communications, such as the content of your comments, complaints, feedback, or inquiries;
Any other additional information
that we may request to help us to determine your eligibility for a Fraction Product. We may collect information about your credit history
from third parties like credit reporting agencies in connection with your application to purchase a Fraction Product.
We may automatically collect certain technical information
from any device that you use to visit our Site. This includes:
Your device’s IP address, web browser type and version, hardware model, time zone setting, browser plug-in types and versions, and operating system, as well as your internet service provider.
Information about how you use the Site
, including the uniform resource locators (“URLs”) of other websites that you click to and from our Site (including the date and time clicked), emails we send that you open, forward, or click through to our Site, page response times, download errors, length of visits to certain pages on the Site, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.We may collect some of the above technical information using cookies or similar technologies. See Cookies & Other Technologies
below for more detail on how we collect and use this information.
How does Fraction use your personal information?
We may use your personal information to:
- Present our Site and its contents to you;
- Create your account with us;
- Communicate with you;
- Process your application for a Fraction Product, including verifying information included in your application;
- Enter into and perform transactions related to Fraction Products, including processing payments to you;
- Manage and administer your Fraction Product, including ongoing evaluation of credit and maintaining records for legal and accounting purposes;
- Maintain our customer service records;
- Respond to your requests, complaints, comments and questions; comments or requests for information;
- Satisfy any audit, insurance, self-regulatory or regulatory requirements applicable to us;
- Enforce our legal rights with respect to any agreement you may have this us, including to collect a debt or enforce an obligation owed to us by you;
- Better understand how visitors interact with our Site, and improve the Site;
Detect and prevent security threats to the Site.
COOKIES & OTHER TECHNOLOGIES
for more information on how to do so. Note that the opt-out will apply only to the browser that you are using when you decide to opt out of cookies. Without cookies though, the features described here will not function properly. We also place certain web tracking tools on our Site to collect information about how you use the Site. We may use this information to better understand: how our visitors interact with the Site; the amount of overall traffic to our Site, and whether visitors to our Site become our customers; how to improve our Site; etc
. We use service providers such as Google Analytics and Mixpanel to help us with these particular processes.
If you would like to opt-out of your information being tracked using Google Analytics, you may install theGoogle Analytics Opt-out Browser Add-On
. If you would like to opt-out of your information being tracked by Mixpanel, please set the browser on your device to send ‘Do-Not-Track’ signals. Please see https://allaboutdnt.com/
for more information on how to do so.
How and why does Fraction share my personal information?
In order for us to fulfill the purposes described above at Section 3
of this Privacy Notice, we may need to share your information with third parties. In order to provide you with your Fraction Product, we will share your personal information with our operating company affiliate, who will use the information to administer and service your Fraction Product. Our affiliate will only use your personal information based on our instructions, and we use specific contractual means to ensure that your personal information is kept confidential and secure when in the control of our affiliate.If you apply for a Fraction Product, we may verify your personal information by sharing it with credit bureaus, credit insurers, third party verification services, registries, financial service industry databases, investigative bodies, personal references, or other lenders.If you have purchased a Fraction Product from us, we may share credit and other information about you with others (including credit bureaus, mortgage insurers, creditor insurers, registries and other persons with whom you may have financial dealings, as well as any other person as may be permitted or required by law) for the purposes of evaluating your current and ongoing creditworthiness and maintaining your credit history. We may also share information with credit reporting agencies or credit bureaus relating to your Fraction Product. This may include, but not be limited to, if you fail to meet any of your obligations under the applicable terms and conditions of those products.Fraction may share your information with service providers in order to analyze and determine trends about visitors’ use of the Site. We may share your personal information with third party service providers who help us to, Host Site data;Design, administer, and maintain the Site;Understand how visitors interact with the Site, in order to improve the Site experience;Provide customer service support;When we allow a third party service provider to access your personal information, we will only allow them to access or use it for the sole purpose of carrying out the above services on our behalf. If there are any other parties connected to your account (e.g. guarantors, powers of attorney, and other people named on your application), we may share your personal information with them as permitted by law. We may share your personal information with government, regulatory or law enforcement agencies as requested by these agencies, if we have a good faith belief that the disclosure is required or permitted by law. We may also share your personal information in order to enforce our legal rights; to detect, prevent or address fraud or security issues; and to enforce ours or others’ legal rights, property, or safety. We may also transfer or assign your personal information to third parties because of, or in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation.We do not trade, rent or sell your personal information to third parties.
How does Fraction keep my personal information safe?
Fraction maintains commercially reasonable methods, including the use of data security and encryption standards, to preserve the confidentiality of your personal information and to ensure that it is only used for the purposes that we have identified. We regularly review our collection, storage, and processing practices to prevent unauthorized access to our systems. We restrict access to your personal information to only those Fraction associates, affiliates, and service providers who require that information to carry out the purposes identified above at Section 3 of this Privacy Notice
, and anyone with this access is subject to strict confidentiality obligations. However, you should be aware that no system is 100% secure, and despite our best efforts, we cannot guarantee that your information will be secure, particularly while it is in transit over the Internet.We only retain your personal information for as long as necessary to fulfill the purposes we have identified throughout this Privacy Notice, or as otherwise required or permitted by law. One or more of our service providers may not be located in Canada, and so your personal information may be transferred to, stored, or processed in another country where the laws are different from those in Canada (e.g. the United States). As a result, your personal information may be accessible to regulatory authorities in accordance with the laws of those other jurisdictions.
How can I access or correct my personal information?
If you request, we will let you know what information Fraction has about you, what it is being used for, and with whom it has been shared. If you notice any inaccuracies or wish to update any of your personal information, we will make those changes. At your request, we will provide you with access to your personal information that is in our control, subject to certain exceptions. These include where the information includes the personal information of another individual that cannot be separated from your personal information, information subject to solicitor-client privilege, or information that cannot be disclosed for any other legal, security, or commercial proprietary reasons. To make a request to access, update or correct inaccuracies in your personal information, contact us at firstname.lastname@example.org
If you have any questions or concerns about this Privacy Notice, you can contact Fraction’s Privacy Officer at:
Email address: email@example.com
Mailing address: 1700-1055 West Hastings Street, Vancouver, BC, Canada, V6E 2E9
If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner
if you live in Ontario, or the Office of Information of the Privacy Commissioner
if you live in British Columbia.