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ClearScore Privacy Policy

Updated: 25 November 2024
Effective from: 14 December 2024

Privacy Policy
ClearScore Canada Limited will be the data controller for the data that you provide us or we collect in relation to the provision of our services to you. We respect your privacy and protecting your information is paramount. We want you to be informed and empowered with respect to your privacy when you use our services. Please read this Privacy Policy carefully before using our website or apps or registering to use our services. This Privacy Policy sets out our views and practices regarding your personal data and how we collect, process and treat it. There may also be additional privacy policies if you use particular services – we will highlight these to you at the relevant time.

By visiting www.clearscore.com/ca and using our apps and services you are accepting and consenting to the practices described in this Privacy Policy.

References in this Privacy Policy and on our website to "we", "our" or "us" are references to ClearScore Canada Limited. References to "you" and "your" means each natural or legal person who uses our website or the associated services.
References to our website below include references to our apps.

Privacy Policy

  • The information we collect
  • How we use the information
  • Who we may share your data with
  • What is the legal basis for us using this information?
  • Direct marketing and how you can change your preference
  • How we protect your information
  • How long we keep your information
  • Links to and from third party websites
  • Automated Decision Making
  • Your rights
  • Changes we make to our Privacy Policy
  • Contact us

Cookies Policy

  • Overview of our Cookie Policy
  • What are cookies?
  • More about the cookies we use
  • Specific cookies we use
  • Turning cookies off
  • Contact us
  • Further reading

The information we collect
We collect and process information which:

  • you give to us when you register with us, such as your name and contact details
  • we obtain from Credit Reporting Agencies on your behalf
  • we obtain from our Cybercheck Partners on your behalf
  • we collect about you based on your use of our website or from your mobile device if you are using our app
  • we receive from other sources, such as third parties who give us information about you
  • is collected from cookies. For more information, see our Cookies Notice.

We may collect and process the following data about you:

Information you give us. You may give us information about you when you use our services or by communicating with us. This includes information you provide when you participate in discussion boards, answer specific questions on our website, provide us with feedback, participate in surveys, and when you report a problem.

The information you give us may include your:

  • title;
  • name;
  • email address;
  • date of birth;
  • phone number;
  • passport details;
  • monthly expenditure;
  • residential details;
  • employment details;
  • income and salary information;
  • address history;
  • bank;
  • property value;
  • deposit;
  • mortgage details;
  • driver's license details;
  • energy and gas charge details;
  • lifestyle information; and
  • if you subscribe to Protect Plus, personal information relating to your use of the benefits or claims for costs or expenses.

Information we collect from Credit Reporting Agencies on your behalf. If you register to use our services, we will obtain your credit score and credit report from one or more Credit Reporting Agencies on your behalf. When you click to search for credit offers on our website or our apps, we may also obtain your credit score and report from one or more of the Credit Reporting Agencies to undertake analysis and profiling of your credit information in order to identify and inform you of credit products that we consider are likely to interest you or be suited to your credit circumstances.

Information we collect from our Cybercheck Partners on your behalf. All our registered customers benefit from our ClearScore Protect service, upon email verification. To provide you with this service, we share the email address connected with your ClearScore account and your passport number (if provided) with our Cybercheck Partners (see more here), who use this information to identify whether any of your information may have been compromised. The Cybercheck Partners will not use the information you've shared for any other purpose (including marketing) and will only keep it for the time necessary to conduct the check after which it will be deleted.

If you verify your email and activate the ClearScore Protect service to include dark web monitoring, we may also receive the following information about you from the Cybercheck Partner:

  • Name
  • Addresses
  • Social profiles
  • Email addresses
  • Driving license details
  • Passport details
  • Phone numbers
  • Usernames
  • Date of birth
  • Education and professional history

If you subscribe to our Protect Plus service, we will also receive your personal data from CyberScout Ventures Limited (“CyberScout”), one of our Cybercheck Partners for Protect Plus, so you can obtain the benefit of the cover offered under your subscription.

Information we collect about you based on your use of our website or apps. Each time you visit our website or use our app we may automatically collect the following information:

  • technical information, including the Internet protocol (IP) address, your login information, browser type and version, time zone setting, operating system and platform
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number

Information we receive from other sources. We may receive information about you if you use any of the websites we operate or the other services we provide. We also work closely with third parties and may receive information from them as follows:

  • We may receive information from our business partners, such as the lenders and credit providers to whom we introduce you as part of the services whether or not you have taken out a product with them, what other products you may have used, and other such details
  • With your consent we will collect your credit report or credit score from credit reporting agencies on your behalf as described in our Terms whether or not you have taken out a product with them, what other products you may have used, and other such details.

Information collected from cookies. We and our service providers collect information about your use of our website from cookies. For more on how we use cookies and how to decline them or turn them off please read our Cookies Notice .

Information collected from two-factor authentication. If you opt to enable two-factor authentication for your ClearScore account, we will collect your phone number and use it to provide you with a code via SMS which you can use to enter your account.

Recording telephone calls and other communications. We may monitor or record telephone conversations or other communications between you and us.

How we use the information
We use information we hold about you to provide our services to you and improve those services, administer your account and communicate with you and to use information on an anonymous basis for research, profiling and analytical purposes.

Information you give to us or we collect from Credit Reporting Agencies , Cybercheck Partners or other third parties on your behalf as part of our services. We will use this information to:

  • administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message, push notification or other electronic means
  • verify your identity as part of our identity authentication process
  • provide you with information, products and services, including, if you subscribed to it, Protect Plus
  • where you have provided your consent for us to market to you, provide you with information about other products and services we feel may interest you or be best for you
  • notify you about changes to our services
  • ensure that content from our website is presented in the most effective manner for you and your device
  • aggregate it on an anonymous basis with other data for data analytical and reporting purposes
  • undertake analysis and profiling of your credit information in order to identify and inform you of credit products that we consider are likely to interest you or be suited to your credit circumstances or to enhance our services.

Information we collect about you based on your use of our website. We will use this information:

  • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • to improve the service we offer you such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
  • as part of our efforts to keep our website safe and secure and to prevent fraud
  • to make recommendations about products or services that may be of interest

Information we receive from other sources. We may combine this information with information you give to us and use this information and the combined information for the purposes set out above.

Recording telephone calls and other communications. We will use telephone recordings or transcripts of communications to check your instructions to us, analyse, assess and improve our services, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us.

Who we may share your data with
We may share your data with other members of our group and with other third parties, such as our service providers, advertisers, Credit Reporting Agencies, and Fraud Prevention Agencies and Cybercheck Partners.

We may need to disclose your data to others to ensure the smooth provision to you of the products, services and information you request. Your data may be disclosed to the other entities as described below.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.

Service providers /sub-processors. We may share your personal information with third party service providers and suppliers who provide us with services that we need in order to operate the website, apps and supply the services. These service providers do not have permission to use any of your personal information that we provide to them for any purpose other than the purpose for which we provide it to them. These third parties act on our instructions and are processors of your information.

Group companies. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, for the purposes of providing our services.

Selected third parties. We may also share your information with selected third parties including:

  • Credit Reporting Agencies, to obtain your credit score and credit report on your behalf and to provide our services to you (please see "Credit Reporting Agencies" below for more detail)

  • Fraud prevention agencies, to prevent crime and trace those responsible (please see "Fraud Prevention Agencies" below for more detail)

  • Product providers, such as our business partners who offer you credit cards, loans, car finance, mortgages, insurance, pensions, investments and other related products, to:
      • assess if you are an existing customer and for fraud prevention purposes
      • conduct analysis to provide you with better products and services in the future, and for segmentation purposes
      • perform the terms of their contract with you
      • pre-fill an application form with the product provider
      • assess your potential eligibility for a product based on criteria set by the product provider.

We may also share your information with product providers to:

  • assess your probability of being accepted for a product based on the information you’ve provided us, so we can indicate to you as part of our services whether or not you are likely to be accepted for a product when you search for credit offers on our website or apps;
  • assess whether you are eligible for pre-approved offers based on the information shared against product provider criteria. Pre-approval is dependent on the accuracy of your information and any changes made to this information directly with the product provider can lead to a change in this pre-approved status, and you would still need to apply with the product provider who may run a hard search and verify your information before making any offer.

You can opt out of this if you want to in your “My Account” section, however, if you do opt out of this, we will not be able to show you any pre-approved offers or assess your probability of being accepted for a product.

The product provider does not have permission to use this data for any other purpose including marketing

  • service providers we use (such as comparison sites and aggregators) for analysis and profiling of your credit information (and any other data provided by you or on your behalf) to identify and inform you of credit products that are likely to be suited to your credit circumstances through targeted advertising. When you click to search for credit offers on our website or our apps, these service providers will record a \'soft credit search\' on your credit file, but this record will be invisible to other lenders, so by itself it will not affect their lending decision and it will not affect your credit score. You can opt out of this if you want to in your \"My Account\" section, however, if you do opt out of this, we will not be able to show you credit offers on our website or apps that are targeted to you and will only be able to show you generic ads, which may not be suited to your credit circumstances
  • advertisers and advertising networks that require data, to perform services on our behalf, including selecting and serving relevant adverts, to and others and to make sure their adverts reach their intended audience, help analyse our site, run contests, special offers, or other events or activities, and track metrics on our behalf or in connection with our Services. We may share non-sensitive information about your visits to our sites and app, and/or your email address (in a hashed or other masked format) with our advertising partners, including social media networks like TikTok, Meta/Facebook, and platforms such as Google / YouTube and Amazon, for interest-based advertising or targeted advertising campaigns. These interest-based advertising platforms may also use personal information about you that they have independently collected in accordance with their privacy policy and practices, including through the use of cookies. That will help us manage and deliver our marketing, including by:
      • excluding you from seeing targeted adverts if you have opted out of ClearScore marketing
      • creating audiences for our advertisements to social media network users who may be similar to you based on the data that the social media network holds about you
      • including you in audiences to receive marketing when you’re on a social media network

You can opt out of the above data processing activities at any time in your ClearScore account settings;

  • analytics and search engine providers that assist us in the improvement and optimisation of our service
  • external affiliate network partners (for example, lending partners), with whom we share the fact that you have clicked on a sponsored link from our website or app. We use a unique ClearScore URL or “hyperlink,” and will not share any personal identifiers or personal information with our external affiliate partners. However, our external affiliate network partners may track you through their website, including connecting our unique ClearScore hyperlink with you in order to calculate a potential commission to ClearScore in accordance with their own privacy policies and practices;
  • if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets (or the buyer or seller's advisers)
  • if we or part or all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of ClearScore Canada Limited, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction
  • our Cybercheck Partners to obtain details of any recorded cybersecurity incidents affecting your nominated email account or passport to provide you with our ClearScore Protect service
  • if you are subscribed to Protect Plus, our Cybercheck Partners, to deliver the Protect Plus service to you and so you can obtain the benefit of the subscription and make claims for costs or expenses.

Credit Reporting Agencies. If you register to use our services we will obtain on your behalf, in accordance with our Terms, copies of your credit report and credit score from designated Credit Reporting Agencies. In order to provide these services to you, we will share your information with such Credit Reference Agencies and their Subcontractor, to allow them to perform the services, for fraud prevention purposes and to allow Subcontractors to provide third parties with product and services.

The information which we provide to the CRA may be supplied by them to other organizations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRA may also use the data to undertake statistical analysis.

If you choose to apply for a product, the lender will undertake a full credit check and provide you with further privacy information for that product.

Fraud Prevention Agencies. We will share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organizations may access and use from other countries the information recorded by fraud prevention agencies.

Cybercheck Partners. We have partnered with web monitoring services providers to provide you with our ClearScore Protect service, which helps you to identify whether or not information associated with your email account or passport has been compromised online. To provide this service, we share your email address (the one we use to send you service emails regarding our services) with our Cybercheck Partners on a monthly basis, alongside your passport number, if you have chosen to provide this. These providers will then check their databases to identify whether there are any recorded instances of your account details having been compromised. Your email address and passport number are processed solely on our instructions and will not be used by our partners for any other purpose, including marketing. We will notify you of the results of the dark web monitoring check in the manner set out in our Terms. For more details about our ClearScore Protect service, please refer to our Terms here.

We will not use the results of these dark web monitoring checks conducted on your behalf for any other purpose.

We have partnered with CyberScout to provide you with certain benefits if you subscribe to Protect Plus. We will share your personal data, including your contact details and full name with CyberScout so that you can obtain the benefit of the cover offered under Protect Plus.

What is the legal basis for us using this information?
We make sure we have appropriate legal bases on which to collect, use and share data about you. If you have any questions about the lawful bases upon which we collect and use your personal data, you can contact our Data Protection Officer.

Consent. We will always seek your consent to process your personal data, except where otherwise permitted or required by law. Your consent may be express or implied, or obtained via an opt-out mechanism. You have the right to withdraw or decline your consent at any time, subject to contractual and legal restrictions.

Direct marketing and how you can change your preference
We offer you the opportunity to receive marketing information from us. You can opt out easily from receiving marketing from us at any time.

We will normally send direct marketing by email if we have your email address, but may choose to contact you via other methods, such as push notifications to your devices.

You may receive the following types of communications from us:

  • Product recommendations - we'll get in touch with personalized, timely product recommendations that can help you improve your financial situation. We'll also send you content such as tips, research, features and news, coaching program on how to keep on top of your money and other related content. You can unsubscribe from these at any time and we will never spam your inbox.
  • Core communications - we will send you your credit report every month, alerts whenever there is a change to your credit report, security alerts pertaining to your ClearScore account, quarterly reports detailing the findings of our ClearScore Protect service, significant changes which may impact our service and other such related content. These communications are an intrinsic part of owning a ClearScore account and cannot be opted-out of unless you delete your ClearScore account.

If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be given an option to unsubscribe. You may also update your preferences here.

You can also tell us that you do not wish to receive any more marketing communications at any time by writing, with your full name, address and other contact details (to enable us to find your records), to:

Data Protection Officer
ClearScore Canada Limited
privacy@clearscore.ca

How we protect your information
We take the security of your data very seriously and use strict procedures to protect it.
All information you provide to us is stored on our secure servers and will be accessible by authorized employees, sub-processors and contractors who require access for the purposes described in this Privacy Policy.

We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.

We or our service providers may transfer and process personal data outside of Canada, including in the US, India, UK or EEA. We always require that appropriate safeguards are in place to protect the information when it is processed. Despite these safeguards, applicable laws in Canada and outside of Canada may allow government and national security agencies to access personal data in certain circumstances.

How long we keep your information for
While your account remains active, we keep your information for no longer than is necessary depending on the purpose for which we are using it.

How long we keep your information will depend on the purpose for which we use it. While you are a customer of ours, we will only retain your information for as long as is necessary for those purposes. We will retain your credit score and credit reports for as long as you hold an account with ClearScore.

After termination of your account, we may continue to use anonymized data (which does not identify individual users) which is aggregated with anonymized data of other users. We use this aggregated anonymized data for data analysis, profiling and research purposes, for example to gain insights about our users. We may also keep your email address for a reasonable period of time to ensure that you no longer receive any communications from us as well as your name, date of birth and latest address for fraud prevention purposes and for the exercise or defence of a legal claim.

Links to and from third party websites
If you follow a link to or from our website to a third party website, please be aware that these websites have their own privacy policies.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Automated decision making
We use an automated decision making system to make automated decisions based on personal information we have about you. This helps us to make sure our decisions are quick and fair, based on what we know.

Identity verification. We use an automated decision making system to verify the details you provide against those held by third party providers. If you do not pass the check using the automated system, we cannot provide our services to you without being able to verify your identity.

Tailored products and services. We may use your information to predict the probability that you may be accepted for a product, or to determine the best order or manner in which to display products to you.

Tailored communications. We want to make sure we're only sending you emails that are relevant to you, and so we will use your personal information to determine which content you may be more interested in receiving.

You have the right not to be subject to a decision based solely on automated processing, including profiling. We understand that not everyone is comfortable with decisions being left entirely up to machines. If you have any questions about automated decision making, please contact us via privacy@clearscore.ca.

Your rights
You can exercise specific rights with regards to the data that we hold about you.

We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. Subject to exceptions provided for by law, you have the right to:

  • Correct your data: You are generally entitled to correct personal information we hold about you that is inaccurate or incomplete. Please contact us at help@clearscore.com if you want to make a correction request.
  • Request access to your data: you can ask for access to the personal data that we hold about you and information about how it has been collected, used and disclosed.
  • Erase your data: you can ask us to fully or partially delete your personal data where there is no compelling reason for us to keep using it, although we may not be able to continue to provide our services. We may keep your email address to make sure your e-mail marketing choices are respected in future. We also have the right to continue using your information if such usage is necessary for compliance with our legal obligations.
  • Download your data or send it to another controller: you can obtain a copy of the data you provided us in a machine-readable format. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
  • Right to withdraw consent: You have the right to withdraw your consent to our collection, use or disclosure of your personal data at any time, subject to contractual and legal restrictions. This can be done by contacting our Data Protection Officer.

For the exercise of any of your rights, you can also contact us at privacy@clearscore.ca.

Changes we make to our privacy policy
Any changes we may make to our Privacy Policy in the future will be posted on this page and, where we decide it is appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.

Contact us
You can address any questions, comments, complaints or requests regarding this Privacy Policy to the Data Protection Officer at privacy@clearscore.ca.

 

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