Flahmingo
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Flahmingo’s Privacy Policy

Your privacy and information is very important to us. The personal information Flahmingo Investmnets Inc. (“Flahmingo”, “us” and “we”) collect about you is managed in accordance with this Privacy Policy (“Policy”).

1. PRIVACY COMMITMENT AND PERSONAL INFORMATION
We collect, use and disclose personal information to operate our business and as required by law. Personal information is information about an identifiable individual, as defined in the Personal Information Protection and Electronic Documents Act and in any applicable provincial legislation, including the Alberta Personal Information Protection Act (PIPA).
2. CHANGES TO PRIVACY POLICY
This Policy describes our current privacy practices. We update this Policy on an ongoing basis to ensure consumers, applicants, customers and service providers, are aware of updates to our privacy practices, to streamline those practices and to comply with applicable laws. Consumers are individuals who are not currently our customers; applicants are individuals who apply to become our customers; and customers are individuals who have been approved for a Flahmingo product, currently utilize a Flahmingo product or have used our products and services in the past. Please visit this site regularly for updates. We will also notify individuals with whom we have a relationship of any material changes that may impact them.
3. ACCOUNTABILITY
Our founding team is responsible for ensuring that we comply with this Policy and applicable privacy laws. We are responsible for personal information in our possession or custody, as well as personal information transferred to a third party for processing. More details on our third parties are provided below under “Limiting Use, Disclosure and Retention”.
4. INFORMATION WE COLLECT, AND LIMITING COLLECTION

Except where information is required to fulfill an identified purpose, you get to decide what information you want to share with us. Contact details. We may collect information you provide, such as your name, phone number, address, city, email address, and marketing preferences if you visit or use our website or app, register or apply for one of our products or services, interact with us through social media or online ads, participate in surveys, or engage with us in any way. We may collect that information for uses as described in this Policy.

Information about you. If you apply or sign up for one of our products or services, depending on the product or service, we may collect information about you, including your name, date of birth, and other details about you. When you provide authorized user information, we expect that you have the authority to consent to its collection, use, and disclosure as outlined in this Policy. We may keep the information described above along with other information about you in our records, even after your account is closed. Digital and online information. We may collect information from your mobile and online activity; for example,information about your web browser, time zone, Internet Protocol (IP) address, mobile device ID, application and website use, and history. Cookies (small computer files that a website’s server places on your computer) collect information about your online behaviour. You can set your browser to reject cookies, but this may impair our ability to customize and test your experience, like remembering your preferred language or present location-specific information to you.

Usage information. If you sign up for one of our products or services, depending on the product or service, we may collect information regarding the use of our website and application, including screens visited and in-app behavior in order to monitor and improve the app. Third party service providers. We may collect information about you from third parties. We may collect publicly available information about you from online sources, or from surveys that you participate in. You may also enter into various services, agreements and reward and loyalty programs operated by third parties. The privacy policies of such third parties will apply to such transactions with third parties, and not this Policy.

Communication. When you have a telephone and online chat conversation with one of our representatives, your call and chat may be recorded for quality and training purposes, as well as to resolve concerns. If you choose to contact us by email or mail, we may retain your email address, the content of your communication and our responses.

5. IDENTIFYING PURPOSES

We will clearly identify the purposes for which personal information is collected, used or disclosed prior to, or at the time of, collection, and as in our customer agreements and disclosures.

We may use your information to contact you. Your information allows us to contact you by various methods, including mail, email, SMS message, app push notification, and telephone at the contact points you’ve provided to us. We will contact you to respond to your questions, proactively provide you with information about your accounts with us, inform you about our products and services, and update you on changes to our website, mobile app, and other digital services we provide. We may use your information to send you important updates about your application status and account opening disclosures, and important or useful messages about your accounts. When you communicate online or by email, you should be aware that sending information over the internet isn’t secure, as it can be intercepted or manipulated and retransmitted. We may use your information to authenticate you. With your information, we can confirm your identity by sharing your information with third party identity verification providers to authenticate you when you apply for a product or service, to verify that it’s you we are speaking with when you call into our Customer Service to discuss your account, or identify you when you visit us online or on our mobile app.

We may use your information to service you. Your information may be used to maintain, service, process, analyze, audit and collect on your accounts. We may use your information to service your mobile account, optimize our website, perform analytics, and provide you with a unique user experience. We may also send notifications and support mobile payments with this information.

We may use your information to make improvements. We may use your personal information to evaluate existing products and services, develop new products and services, drive strategy and improve the customer experience we offer. Information we collect is also valuable for our quality and servicing training programs. We also customize our website and mobile applications based on information collected, and use that information to understand and deliver products and services that you, and others who are similar to you, may find useful. The information is used to better understand our website and mobile application activity, and how users interact with our digital sites. It’s also used to monitor and improve our website and mobile applications.

We may use your information to prevent fraud. We may use your information to assess fraud and other risks to you and us, and to protect consumers, applicants, customers and providers from identity theft, fraud and unauthorized account access. When investigating fraud, we may ask for identification documents (such as a Canadian driver’s licence, Canadian passport, birth certificate, utility bill or bank statement, or other forms of identification).

We may use your information to provide you with offers, advertising and marketing. Elements of your personal information may be used to determine your suitability, or to directly communicate with you, for targeted advertising, marketing, promotions, rewards programs, research or contests. You may see advertisements for our products and services on our website, mobile applications or on third-party websites, based on your online or mobile activity and information you’ve shared with third parties. We may use your personal information to identify you on third-party platforms you already use (such as Facebook and Twitter) and serve you ads through their marketing platforms. We may also use your information to identify you on third-party platforms (such as Facebook and Google), and then use the algorithms of those platforms to find other people with similar characteristics.

We may prevent you from seeing offers that are unsuitable for you, based on the information we know about you. For example, if you are already a customer, we don’t want to serve you ads for products and services you already have with us. You can opt out of offers, advertising and marketing uses of your information, and opt out of the use of cookies by following the instructions in section 6 (Consent) below. We may use your information to report. We may share application, transaction, authentication and “know your client” information with our partners, potential third-party providers, and other regulatory agencies as required by law.

6. CONSENT

If you apply for a product or service, communicate with us or provide personal information to us in any way, you acknowledge your consent for personal information collection, use and disclosure as set out in this Policy, applicable laws and industry standards. If we want to use your information for a purpose that was not disclosed at the time of initial consent, consent will be sought at the time of this new purpose.

Updating consent. Subject to legal and contractual restrictions, you can, with reasonable notice to us, withdraw your consent for use and disclosure of your personal information, other than that which is required for us to maintain your account and to provide services for which you were approved. Opt out of mail, email and phone marketing. You can request that we don’t contact you for advertising, marketing, promotions, rewards programs, research or contests, by updating your privacy preferences. You should know that withdrawing your consent in these instances may result in you missing out on offers specific to your account. To opt out of our email marketing list after you have opted in, you may use the unsubscribe link provided in any email marketing material you receive. To update your privacy preferences outside of email marketing, please do so by emailing info@flahmingo.com and leave the subject line *Email-Opt Out. You must opt out of the use of cookies separately.

Opt out of cookies used for Online Behavioural Advertising (“OBA”) You can adjust your browser to reject cookies by clicking on the “AdChoices” link embedded in many of our ads. We subscribe to the Digital Advertising Alliance of Canada’s Self-Regulatory Principles for OBA. These principles promote consumers’ awareness and choice about how their information is used for OBA. You can opt out of the use of your browsing habits for OBA – just visit the AdChoices website provided by the Digital Advertising Alliance of Canada, and use the opt-out mechanism.

7. LIMITING USE, DISCLOSURE AND RETENTION

We limit use, disclosure and retention of personal information to the purposes we identify, and as required by applicable laws. Third parties. We do not sell or rent customer lists or personal information to others. We may share your personal information with service providers who perform services for your account on our behalf (such as identity verification services, marketing, research, call centres, collections agencies, and other services as required to service you). Our contracts with third parties include obligations to protect your personal information, and third parties must meet our rigorous privacy standards. When you engage with other companies directly, or contact us through their platforms, their use of the information they collect from you is subject to the terms of their privacy policies. We may share your information with regulators, courts or other institutions as required by law.

In particular:

Third party verification providers – We may share your information with third party verification service providers, including those who maintain records relating to you telecommunications service providers, for the purposes of identity validation, risk assessment, and maintaining accurate contact details for your account. Information shared may include the following: name; address; SIN; phone; device information; location information, identification details, and ‘selfie’ photos for identification validation purposes.

Collections and law firms – We may share your information to help us collect a debt owed to us by you. Information shared may include the following: contact details, communication history, account details, and financial information.

Fraud detection services – We may use third parties to monitor your transactions to identify fraudulent activity on your account. Call centres and quality assurance providers – We may share access to your account information maintained on our financial systems, with call centres to service your account and provide you with customer support. We may share your customer experience with a third party to evaluate how we are doing, and ensure we are complying with applicable laws and regulations.

Marketing and research companies – We may share your information to understand and deliver products, services and offers that you, and others who are similar to you, may find useful. We may also share your information to block offers that you won’t find useful. This includes digital affiliates. Regulators, courts, law enforcement and other government institutions – We may share your information to resolve concerns and as required by law. Assignees. We may, at any time, sell, transfer or assign any or all of our rights to our Canadian business, including our interests, rights or obligations regarding your accounts with us. If we do so, we may share your personal information with prospective purchasers, transferees or assignees.

Information processed outside Canada. Your personal information may be stored and processed with approved third parties within Belgium, Germany, Ireland, the Netherlands, the United Kingdom, and the United States. If a third party processes or stores information outside Canada, foreign governments, courts or regulatory agencies may therefore be able to obtain such personal information through the laws of the foreign jurisdiction.

8. ACCURACY

We take steps to ensure that your personal information is as accurate, complete and up to date as is necessary for the purposes for which it is to be used. If you believe that the personal information we have about you isn’t accurate or complete, please contact us by updating your information through our web or mobile apps, by notifying any of our customer services lines or by email at info@flahmingo.com. If you move, change your phone number, or change your email address, you are required to update your information with us.

9. SAFEGUARDS

We use procedures and practices appropriate to the sensitivity of personal information to protect against loss, theft and unauthorized access. Access to your information is restricted to those individuals and parties who require access.

For example, we have electronic protection (such as passwords and encryption) and safe business practices. We also train our staff on how to safeguard personal information.

While we take all reasonable measures to protect data, there is always inherent risk when providing personal information. You can help us safeguard your information too. If you contact us through email or social media, you should avoid sending highly sensitive information, such as your banking information or any specific account information. If someone purporting to represent us contacts you and requests your personal or financial information, and you are suspicious, you can always contact us to confirm that the request was legitimate. We also recommend that you use unique and strong passwords for your online accounts and that you don’t share your passwords with anyone.

10. OPENNESS, INDIVIDUAL ACCESS AND CHALLENGING COMPLIANCE

You can write to our Founders to request access to the personal information we have on file for you. We will provide you with the personal information we have, subject to certain considerations specified by law.

You can contact Customer Service for general privacy inquiries or concerns: info@flahmingo.com

For more information about our Policy, or to raise a privacy concern, please contact our Founders at the following address:

Attention: Privacy Issue

Flahmingo Investment Inc.

45 Cityscape Gardens NE.

Calgary, AB

T3N 0N7