FlexCap Financial — Privacy Policy

1. Purpose and scope

FlexCap Financial (FlexCap, we, us, or our) respects the privacy of individuals who visit flexcapfinance.ca, contact us, use our payment calculator, or submit a financing inquiry or general financing application through our Website.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with the Website and related financing conversations. It also explains how to contact us with a privacy question or request.

In this Policy, personal information means information about an identifiable individual. Business contact information may be treated differently where applicable law permits, but FlexCap will handle it responsibly.

This Policy does not replace any separate consent, authorization, application form, credit-verification authorization, lender notice, or contractual privacy terms that may apply to a particular financing request or relationship.

2. Accountability and privacy contact

FlexCap is accountable for personal information under its control. Our designated privacy contact is:

Privacy Officer — FlexCap Financial

134 Queen St E, Suite 207
Brampton, ON L6V 1B2
Email: info@flexcapfinance.ca
General email: info@flexcapfinance.ca
Phone: 1.888.530.1980

If the dedicated privacy email above is not active, replace it before publishing this Policy or direct privacy requests to an actively monitored address.

3. Personal information we may collect

The information we collect depends on how you interact with FlexCap. We may collect the following categories.

Do not provide highly sensitive information through an open-text Website field unless FlexCap instructs you to use an approved secure process. This includes social insurance numbers, bank credentials, payment-card information, passwords, and government identification numbers.

4. How we collect personal information

We collect personal information directly from you when you browse the Website, use the payment calculator, contact us, subscribe to communications, or submit an application or inquiry. We may also receive information from a representative acting for a business, a referral source, lender, verification provider, service provider, or public source where authorized or permitted by law.

We may use cookies, web beacons, analytics tools, server logs, and similar technologies. These tools may collect technical information about your use of the Website. Where required, we will seek consent for non-essential cookies or similar technologies and provide appropriate choices.

5. How we use personal information

We use personal information for purposes that are reasonable and identified at or before collection, including:

• responding to inquiries and communicating about a requested financing conversation;
• receiving, reviewing, and administering a general financing application or request;
• verifying information, where you have provided the required authorization or where otherwise permitted by law;
• matching a request with appropriate internal personnel, lenders, service providers, or financing pathways;
• operating, maintaining, securing, monitoring, and improving the Website and our services;
• detecting, investigating, and preventing fraud, unauthorized access, misuse, or other unlawful activity;
• meeting legal, regulatory, audit, recordkeeping, and risk-management obligations; and
• sending commercial electronic messages only where we have the required consent or another legal basis to do so.

We do not use Website calculator outputs as a guarantee of approval or pricing. Calculator inputs may be used to respond to a financing inquiry only if you submit them with identifying information or otherwise ask us to follow up.

6. Consent and legal authority

We obtain meaningful consent for the collection, use, and disclosure of personal information, except where law permits or requires collection, use, or disclosure without consent. The form of consent may be express or implied depending on the sensitivity of the information and the reasonable expectations of the individual.

FlexCap will seek express consent before using or disclosing sensitive information in ways that require it. Where a Website form contains a credit-verification or information-verification authorization, the authorization must state its purpose and scope clearly. You may decline to provide requested information, but this may limit our ability to respond to a request or evaluate a financing opportunity.

You may withdraw consent for future uses or disclosures, subject to legal or contractual restrictions and reasonable notice. Withdrawal may affect our ability to continue a financing review or provide requested services. To withdraw consent, contact the Privacy Officer using the contact information above.

7. How we disclose personal information

We may disclose personal information only as necessary for the purposes described in this Policy, with consent where required, or as permitted or required by law. Recipients may include:

• FlexCap employees, contractors, and professional advisers who need the information for authorized work;
• hosting, website, form-processing, customer-relationship-management, analytics, email, cybersecurity, document-management, and other service providers that process information for us under appropriate safeguards;
• potential lenders, financing partners, referral partners, or other parties involved in evaluating or administering a financing request, where you have authorized the disclosure or law permits it;
• credit bureaus, verification providers, insurers, legal advisers, regulators, law-enforcement agencies, or other parties where authorized by you or permitted or required by law; and
• a purchaser, successor, or assignee in connection with a proposed or completed business transaction, subject to applicable law.

Before publishing, FlexCap should complete and maintain an internal vendor register that identifies each data processor, its role, the location in which it processes information, its security measures, and the relevant agreement or data-processing terms.

8. Cross-border processing

FlexCap or its service providers may store or process personal information outside your province or outside Canada. Where information is processed in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies, or other authorities under those laws.

FlexCap uses contractual, technical, and organizational safeguards that are appropriate to the sensitivity of the information and the processing arrangement. For information about the countries in which a specific service provider processes data, contact the Privacy Officer.

9. Retention and disposal

We retain personal information only for as long as necessary to fulfill the identified purposes, manage our relationship with you, meet legal, regulatory, tax, audit, and recordkeeping obligations, resolve disputes, and enforce agreements.

Retention periods vary by record type and applicable obligations. Before publication, FlexCap should adopt an approved retention schedule that addresses website inquiries, application records, credit-related consents, marketing consent records, CRM records, and security logs. When information is no longer required, we will securely delete, anonymize, or destroy it in accordance with our retention schedule and applicable law.

10. Safeguards

We use safeguards appropriate to the sensitivity of the information in our custody or control. These may include role-based access controls, multi-factor authentication, encryption in transit and at rest where appropriate, secure hosting, vendor due diligence, logging and monitoring, staff confidentiality obligations, and incident-response processes.

No system, website, or electronic transmission can be guaranteed completely secure. You should use reasonable care when communicating online and should not send highly sensitive information through an unsecured channel.

11. Access, correction, and complaints

Subject to applicable law, you may request access to personal information that FlexCap holds about you, ask for corrections to information that is inaccurate or incomplete, ask questions about our privacy practices, or make a privacy complaint.

Submit a request in writing to the Privacy Officer. We may ask for information to verify your identity and authority before responding. We will respond within the time required by applicable law. If we cannot provide access or make a requested correction, we will explain the reason, subject to legal restrictions.

If you are not satisfied with our response, you may have the right to contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator.

12. Commercial electronic messages

FlexCap may send electronic messages about financing services, updates, or other commercial matters only where we have consent or another legal basis under Canada's Anti-Spam Legislation (CASL). Our commercial electronic messages will identify FlexCap, provide contact information, and include an effective unsubscribe mechanism where required.

You may unsubscribe from marketing emails at any time by following the unsubscribe link in the message or contacting FlexCap. We will process an unsubscribe request within the timeframe required by law. We may continue to send non-marketing messages that are necessary to respond to an inquiry, provide requested services, comply with law, or administer a relationship.

13. Children and minors

The Website is intended for business owners, representatives, and other adults seeking business-financing information. We do not knowingly collect personal information from children or minors through the Website. If you believe a child has provided personal information to us, contact the Privacy Officer so we can investigate and take appropriate steps.

14. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, technology, or legal obligations. The current version will be posted on the Website with an updated effective date. Where required by law, we will provide additional notice or seek consent for material changes.

15. Contact

For privacy questions, requests, or complaints, contact:

Privacy Officer — FlexCap Financial
134 Queen St E, Suite 207
Brampton, ON L6V 1B2
Email: info@flexcapfinance.ca
Phone: 1.888.530.1980