This Privacy Statement explains how Windmill Microlending (“we”, “us”, “our”) collects, uses, and discloses information about identifiable individuals (“Personal Information”) in connection with our website. We are committed to maintaining the accuracy, confidentiality and security of Personal Information in accordance with applicable legislation.
In general, we collect only the information needed to process applications, to offer and manage our products and services, and to communicate with you. You are not required to provide any Personal Information to us; however, if you choose not to do so, we may be unable to provide our services to you.
We collect contact information, financial information, and other information about your in order to assess and qualify applications for financial services. This includes information about you that we obtain from third parties, including your references, credit bureaus, and other financial institutions.
Through your communication with us you may voluntarily provide other information to us. We also collect technical information about the use of our web site to enable us, and our service providers, to operate, maintain, and enhance the services we offer.
We generally use your information in order to provide services to you and to manage our risks and operations.
1. What Information do we collect?
Most of the information is collected when you interact with us, for example when you:
- apply for a product or service;
- communicate and or interact with us; or
- sign-up for newsletter or complete a survey.
We also collect financial and other information about you from a variety of sources including from:
- references you have provided to us;
- transactions you have made with us;
- credit bureaus; and
- other financial institutions.
We will ask you to provide information that enables us to complete your loan application, loan agreement and to provide better service or to offer you products and services we believe you might be interested in.
- Information About You
- Other Information
Information About You
Information essential for fulfilling financial requests and applications include:
- Information establishing your identity, such as your name, address, phone number, title, phone number, email address, date of birth, social insurance number and account numbers;
- Information to authenticate your identity, such as knowledge-based information (i.e. username, password and account information), identification, signature;
- Information you provide on an application for the provision of our products and services, such as your annual income, place of employment, investments, credit card balances, account balance, financial liabilities, transaction history;
- Information you provide during communication with us which may include family details, life events, goals and your opinions and issues you may have encountered;
- Information about financial behavior such as your payment history and credit worthiness;
- Additional information may be requested to help us determine your eligibility for products and services that we offer.
Information collected through our website
We collect and maintain statistics relating to the number of visits to the website, the types of browsers and operating systems used and the internet protocol address of the originator. This information is used only for the purpose of monitoring users of our website in order to provide an effective and user-friendly website. No attempt is made to correlate these details with personal information that an individual submits voluntarily.
It is our goal to continuously improve our service offerings to you. Therefore, we routinely collect non-personal aggregated information from surveys, public archives and websites to help us understand the interests of our current and prospective clients and to manage our risks and operations.
2. Why do we collect Personal Information?
Generally, we collect Personal Information in order to offer services in accordance with our mandate – in particular, to assess applications for and to offer, provide, manage, and collect on loans to eligible individuals – as well as to operate and improve our website and/or other products and services, to protect and enforce our legal rights, and to meet our legal obligations.
We are allowed to use your personal information only if we have a proper legal basis to do so. In some cases, this includes sharing the information with third parties. We may use your personal information on the following basis:
- to fulfill a contract we have with you to provide services covered by your account agreement;
- to comply with legal and regulatory obligations;
- for reporting to our government funders, who require minimal information pertaining to your loan and its use as part of our funding agreement with them;
- for legitimate business purposes. Using your personal information helps us to operate and improve our business and minimize any disruption to the services that we may offer to you;
- where we are processing information based on your consent;
- for the establishment, exercise or defence of legal claims or proceedings; or
- for the purpose of suppression or detection of fraud, or for crime prevention,
3. How do we use Personal Information?
We may use your personal information for the purposes communicated to you at the time of application or in your agreement(s) with us, including:
- to verify your identity and to authenticate you when you contact us;
- to provide you with the financial products and services requested;
- to respond to your inquiries and provide customer support;
- to communicate to you any updates, benefit, feature and other information about products and services you have with us;
- to occasionally send you communication of transactional nature,
- to conduct surveys and get feedback from you on our products and services in order to improve and enrich your experience with us;
- to invite you to attend client working groups, alumni events and or other events that we may organize for our clients;
- to better understand your financial situation, progress on your learning plan and employment goal update to determine your eligibility for products and services we offer and to manage your loan portfolio with us;
- to manage our risks and operations;
- to meet regulatory, legal and government requirements;
- if we have your social insurance number we may also share it with credit reporting agencies as an aid to identify you.
- We may communicate with you through various channels including telephone, computer, mail or mobile applications using the contact information you have provided.
- We may wish to send to you information, which may be of interest to you, on other products and services that we offer and of third parties we select. We will only send you information on products and services in accordance with the choices you have made.
- We may create statistical and anonymized reports, analysis and predictive models, rules and insights using information about you and other customers. Aggregated reports may also be shared with other businesses for business development and to provide insights into their sales performance, identify customer demographics or behavioral insights. The information in these reports is not personal and cannot be used to identify you.
- If for any reason your information is required to fulfill a different purpose then that of your original intent, we ask for your consent before we proceed.
4. Who has access to Personal Information?
We limit access to your Personal Information to those employees, agents, contractors and service providers who have a business need to know. They will only access, process, or use your Personal Information on our instructions and they are subject to a duty of confidentiality.
We use service providers in Canada and in the United States of America, to collect, process and store your Personal Information on our behalf, including through the operation of our website. These service providers may only use your Personal Information to provide services to us (and to you). However, you should be aware that when your Personal Information is located outside of Canada, it may be subject to the laws of the other country or countries where it is located.
5. To whom do we disclose Personal Information?
In general, we do not disclose your Personal Information to third parties except where required by Immigration Refugees and Citizenship Canada, or where necessary to carry out a transaction with you or on your behalf, to protect or enforce our legal rights, or where otherwise permitted or required by law.
For example, we will share information about your loan with financial institutions, to advance funds or to receive and process payments, and with credit bureaus, to build your credit rating.
6. How long do we retain Personal Information?
We will retain your Personal Information so long as your loan or application remains valid and active and thereafter as otherwise required or permitted by law.
7. How do we protect Personal Information?
We have put in place physical, organizational, and technological safeguards to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. How can you access and update your Personal Information?
If you need assistance or additional information, you may contact us as set out below.
We may need to request specific information or supporting documents from you to help us confirm your identity, to ensure that Personal Information is not disclosed to a person who has no right to receive it.
9. How can you contact us?
If you would like more information about our privacy practices or have specific questions relating to your personal information, please contact us at:
10. External Websites
This website contains links to other sites. This privacy statement only applies to information collected by our website. We are not responsible for the privacy practices and policies of third parties.
11. Changes to this Privacy Statement
We reserve the right to modify or supplement this Privacy Statement at any time, with appropriate notice to you. We will obtain the necessary consents required under applicable privacy laws if we seek to collect, use or disclose your Personal Information for purposes other than those to which you have previously consented, unless otherwise required or permitted by law.