Privacy Policy

Who we are

17581602 CANADA INC., carrying on business as Sphera Credit ("Sphera Credit", "we", "us", "our"), operates the website at spheracredit.com and the calculators, educational content, request forms and software made available through it (together, the "Services").

Sphera Credit is a technology company. It sells advertising and marketing services to licensed mortgage brokers and to lenders, and it licenses software to financial institutions. It is not a lender, it is not a mortgage brokerage, and it is not a financial adviser. It holds no lending, mortgage brokerage, deposit-taking, insurance or securities licence or registration in any province or territory of Canada.

This Privacy Policy explains what personal information we collect, why we collect it, who we disclose it to, where we keep it and what rights you have. It is written to meet the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25. Our Terms of Service govern your use of the Services.

What we never do with your information

Our role is easy to misread, so we state its limits before anything else. Sphera Credit does not:

• Assess, score, verify or evaluate your financial situation, your creditworthiness or your ability to repay
• Make, take part in, influence or review any lending, credit, pricing or approval decision concerning you
• Obtain your credit report or credit score from Equifax, TransUnion or any other credit reporting agency, and we will not ask you for your consent to do so
• Use your personal information to render a decision about you based exclusively on automated processing
• Provide mortgage, lending, financial, investment, insurance, tax or legal advice
• Lend money, offer or present credit products, or negotiate with any lender on your behalf
• Sell your personal information, or disclose it to data brokers or to advertising networks for their own purposes

Any review of your file, any advice and any decision about financing comes from the licensed broker or the lender you choose to deal with. It never comes from us.

Information we collect

We collect the following categories of personal information:

• Contact and identity information: first and last name, email address, telephone number, and the province you live in
• Information you enter in a request form: the amount you are looking for, what it is for, your employment status, your annual income and, on some forms, your monthly expenses, the debt you already carry and the types of that debt, and how you describe your own credit situation
• Information specific to certain forms: vehicle make and year, business name, business revenue, years in business, down payment, and the location of a property
• Information from the mortgage financing program: your name, telephone number, email address and the address of the project described in your general contractor's quote
• Business contact information: name, work email address, job title and company name, when you ask about our software or request a demonstration
• Technical and usage information: pages viewed, features used, time spent, referring URL, browser and device type, operating system, IP address, and an identifier we set so that a returning session can be recognised
• Approximate geographic location, derived from your IP address
• Correspondence: what you write to us through a form, by email or by telephone

Request forms save each step as you complete it. If you start a form and leave without finishing it, the steps you already completed are kept. We consider financial information of this kind to be sensitive, and we handle it accordingly.

How we collect it

We collect personal information in three ways:

• Directly from you, when you complete a form, write to us, call us, or ask about our software
• Automatically, through cookies, analytics tools and server logs, when you browse the website
• From a partner whose software you were using, in one specific case described below

That case is the mortgage financing program. If you ask for it from inside a general contractor's quoting software, that software sends us your name, telephone number, email address and the address of the project. Sphera Credit is a separate company from your contractor, and your contractor's own privacy policy governs what that company does with your information.

Why we collect it

We use personal information only for these purposes:

• To put you in contact with a licensed mortgage broker or a lender that advertises through our network, and to confirm that introduction with you
• To answer your questions and reply to your correspondence
• To operate, secure, maintain and improve the Services
• To understand, in aggregate, how the Services are used
• To send you messages about a request you have made, and, where you have agreed to it, marketing messages you can stop at any time
• To meet our legal obligations and to enforce our Terms of Service

We do not use the financial information you give us to evaluate you. Which broker or lender we introduce you to depends on the province you are in and on the type of financing you asked about. It does not depend on any assessment of you or of your finances, because we perform none.

Who we disclose it to

We disclose personal information only to the following categories of recipient:

• Licensed mortgage brokers: for requests about mortgage financing, we pass your information to a mortgage broker licensed or registered in your province who advertises through our network. This currently operates in Quebec, Ontario, British Columbia and Alberta. Once your information reaches that broker, the broker handles it under its own privacy policy and its own regulator's rules
• Lenders: for requests about other types of financing, we are still establishing relationships with lenders. Until those are in place, information from those forms is not disclosed to anyone outside Sphera Credit and the service providers listed below. We will not start disclosing it without first updating this policy and obtaining your consent to that disclosure
• Service providers: Amazon Web Services for database hosting, Vercel Inc. for website hosting and performance analytics, Google LLC for Google Analytics 4, Google Tag Manager and email delivery. Each is permitted to use your information only to perform services for us
• Financial institution clients: where a financial institution licenses our software and you interact with that institution through it, the institution is responsible for the personal information it processes
• Legal and regulatory authorities: when we are required to disclose by law, by regulation, by legal process or by an enforceable government request
• A purchaser: if all or part of our business is merged, acquired, reorganised or sold, personal information may be transferred as part of that transaction, subject to this policy continuing to apply

Where your information is kept

Information submitted through our forms is stored in a database hosted by Amazon Web Services in the Canada (Central) region, located in Montreal, Quebec.

Some of our service providers operate outside Canada. Our website is served, and some of its functions run, on infrastructure operated by Vercel Inc. in the United States. Our analytics and email providers are established in the United States and may process information there.

Personal information held in another country is subject to the laws of that country, and may be accessible to its courts, its law enforcement agencies and its national security authorities. Before communicating personal information outside Quebec we assess the transfer as Law 25 requires, and we contract with our providers for protection equivalent to what applies here.

How long we keep it

We keep personal information only as long as it is needed for the purpose it was collected for, or as long as a law requires us to keep it.

A request form, whether you finished it or not, is kept for 24 months from your last interaction with it, and is then destroyed. Business enquiries about our software are kept for the duration of the discussion and for 24 months afterwards. Correspondence is kept for 24 months. Analytics data is aggregated and does not identify you individually.

You can ask us to delete your information earlier, and we will do so unless a law requires us to keep it.

Your rights

Under PIPEDA and Quebec's Law 25, you have the right to:

• Access: obtain a copy of the personal information we hold about you, and be told how it has been used and who it has been disclosed to
• Rectification: have information that is inaccurate, incomplete or out of date corrected
• Withdrawal of consent: withdraw your consent to our collection, use or disclosure of your information at any time, subject to any legal restriction
• Deletion: have your information deleted when it is no longer needed for the purpose it was collected for
• Portability: receive the computerised personal information you gave us in a structured, commonly used technological format
• Complaint: complain to the Office of the Privacy Commissioner of Canada, or, in Quebec, to the Commission d'acces a l'information du Quebec

To exercise any of these rights, write to privacy@spheracredit.com. We answer within 30 days. There is no charge, and exercising a right will never affect how a request of yours is handled.

Person in charge of protecting personal information

Quebec's Law 25 requires us to name the person responsible for the protection of personal information within our organisation, and to publish their contact details. That role is held by our Privacy Officer, who can be reached at privacy@spheracredit.com or by telephone at (289) 672-3047.

Write to that address for any question about this policy, to exercise a right, or to raise a concern about how we have handled your information.

Cookies and analytics

We use cookies and similar technologies for the following purposes only:

• Essential cookies, which the website needs in order to work
• Google Analytics 4, which tells us in aggregate how the website is used
• Google Tag Manager, which manages the analytics scripts on the website
• Vercel Analytics and Speed Insights, which measure page performance and loading times

We do not use cookies for advertising, for retargeting, or to build a profile of you across other websites. You can refuse or delete cookies through your browser settings, and parts of the website may then stop working properly.

Security

We protect personal information with technical and organisational measures appropriate to how sensitive it is. These include encryption of data in transit using TLS, encryption at rest in our database, access limited to the people who need it to do their work, and review of that access.

No system is completely secure, and we cannot guarantee absolute security. If a confidentiality incident presents a risk of serious injury, we will notify the affected people, the Commission d'acces a l'information and the Office of the Privacy Commissioner of Canada as the law requires, and we will keep a register of incidents.

Automated decision-making

We do not use your personal information to render any decision about you based exclusively on automated processing. We make no decision about you at all. If this ever changes, we will tell you at the time we collect your information, and we will give you the right to make observations and to ask that the decision be reviewed by a person, as Law 25 requires.

Children

The Services are meant for adults. We do not knowingly collect personal information from anyone under 18. If you believe a minor has given us personal information, write to privacy@spheracredit.com and we will delete it.

Changes to this policy

We may update this policy. When we do, we post the new version here and change the date at the top. If a change affects how we use or disclose information we already hold about you, we will tell you before it takes effect and, where the law requires it, ask for your consent.

How to reach us

17581602 CANADA INC., carrying on business as Sphera Credit

Head office: Toronto, Ontario, Canada

Privacy Officer: privacy@spheracredit.com

General enquiries: support@spheracredit.com

Telephone: (289) 672-3047