Giving You Credit Financial Services Inc. ("Giving You Credit," "GYC," "we," "us," or "our") respects your privacy and is committed to responsibly handling personal information collected through our websites, applications, communications and services.

This Privacy Policy explains what personal information we collect, why we collect it, how we use and disclose it, how we protect it, and the choices and rights available to you.

This Privacy Policy applies to the following websites and their associated webpages, forms, applications and services:

• givingyoucredit.ca

• consumer.givingyoucredit.ca

• dealers.givingyoucredit.ca

• commercial.givingyoucredit.ca

Collectively, these websites and related digital services are referred to as the "Sites."

This Privacy Policy should be read together with our Terms of Use and any additional consent, authorization or privacy notice presented when you use a particular service.

1. ACCOUNTABILITY FOR YOUR PERSONAL INFORMATION

Giving You Credit Financial Services Inc. is responsible for personal information under its control.

We use employees, contractors, technology providers and other service providers to help us operate our business. Where another organization processes personal information on our behalf, GYC remains responsible for personal information under its control and takes reasonable measures appropriate to the circumstances to protect it.

Certain organizations involved in a financing transaction, including lenders, dealerships, Soluco Financial Group Inc. and financing partners, may also collect, receive or process information for their own purposes and may have their own privacy obligations and policies.

Questions, requests or complaints concerning this Privacy Policy or GYC's handling of personal information may be submitted using the contact information in Section 21.

2. WHAT PERSONAL INFORMATION WE COLLECT

The information we collect depends upon how you interact with GYC and which services you request.

Personal information we may collect includes:

Identity and contact information

• name;

• telephone number;

• email address;

• mailing or residential address;

• date of birth, where required;

• government-issued identification information, where reasonably required for a particular transaction; and

• other information used to identify or contact you.

Employment and financial information

• employment status;

• employer information;

• occupation;

• employment duration;

• income;

• housing or residential information;

• financing requirements;

• existing financial obligations;

• credit-related information;

• banking or payment-related information where required; and

• other financial information relevant to a requested service.

Consumer and automotive information

• vehicle preferences;

• current vehicle information;

• trade-in information;

• financing needs;

• dealership or referral information; and

• information relevant to an automotive financing application.

Business and commercial financing information

• business or company name;

• business contact information;

• province or territory;

• type of business;

• financing purpose;

• requested financing amount;

• equipment or vehicle information;

• vendor or seller information;

• business financial information;

• ownership information where required;

• supporting documentation; and

• other information reasonably required to evaluate or process a commercial financing request.

Dealer and vendor information

• dealership, vendor or business information;

• business contact information;

• program or service inquiries;

• referral information;

• lead information; and

• information associated with a dealer or vendor relationship with GYC.

Communications
We may collect or maintain information from communications with us, including:

• emails;

• SMS/text messages;

• telephone calls;

• voicemail;

• webchat;

• social-media messages;

• consultation or appointment information;

• form submissions;

• application communications; and

• customer-service interactions.

Telephone calls may be recorded or monitored where permitted by law. Where appropriate or required, notice will be provided.

Website and technical information
When you interact with our Sites, we may automatically receive certain technical information, such as:

• IP address;

• browser type;

• device type;

• operating system;

• pages viewed;

• referring website or source;

• date and time of access;

• website interactions;

• cookie or similar technology identifiers; and

• general analytics and performance information.

3. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information:

• directly from you;

• through applications and forms;

• during telephone, SMS, email, webchat or social-media communications;

• when you book a consultation or appointment;

• through our Sites and website technologies;

• from a dealership, vendor or referral source where authorized or otherwise permitted by law;

• from financing providers or partners involved in your request;

• from service providers acting on our behalf; and

• from other sources with your consent or where permitted by applicable law.

We seek to collect personal information by fair and lawful means.

4. WHY WE COLLECT AND USE PERSONAL INFORMATION

GYC collects and uses personal information for purposes reasonably connected with providing and operating our services.

These purposes may include:

• responding to inquiries;

• providing requested services;

• receiving and processing applications;

• determining the appropriate destination for an application or request;

• communicating with applicants, customers, dealers, vendors and businesses;

• verifying information;

• assisting with financing requests;

• connecting applicants with dealerships, lenders or financing providers;

• coordinating commercial financing requests;

• facilitating consultations or appointments;

• administering dealer or vendor programs;

• managing customer and business relationships;

• maintaining records of communications and transactions;

• providing application or service updates;

• providing customer service and support;

• operating our CRM and communications systems;

• preventing fraud, misuse or security incidents;

• maintaining and improving our Sites and services;

• measuring website and marketing performance;

• complying with legal, regulatory, contractual or record-keeping requirements;

• establishing, exercising or defending legal rights; and

• other purposes disclosed to you at or before the time information is collected.

We will not use personal information for a materially different purpose without obtaining additional consent where consent is required by applicable law.

Canadian privacy guidance specifically calls for organizations to identify their purposes before or at collection and avoid overly broad purposes. Office of the Privacy Commissioner.

5. CONSENT

Where consent is required, GYC seeks consent appropriate to the nature and sensitivity of the personal information and the purposes for which it is collected, used or disclosed.

Consent may be express or implied depending upon the circumstances and applicable law.

For example, when you submit an application requesting financing assistance, you may reasonably expect information necessary to respond to and process that request to be used for those purposes and, where disclosed to you and authorized, shared with organizations necessary to process the request.

More sensitive information or uses outside a person's reasonable expectations may require express consent.

Canadian privacy guidance emphasizes that meaningful consent requires people to understand what information is being collected, why it is being collected, with whom it will be shared, and the consequences associated with the collection, use or disclosure. Office of the Privacy Commissioner.

You may withdraw consent to certain uses of your personal information, subject to legal or contractual restrictions and reasonable notice. Withdrawal may affect our ability to provide a requested service where the information is necessary to provide that service.

6. CONSUMER AND AUTOMOTIVE FINANCING

When you submit a consumer or automotive financing application or inquiry, GYC may use and disclose information as reasonably necessary to process the request and connect you with an appropriate dealership, lender, financing provider or other applicable organization.

Depending upon the program, this may include information concerning your identity, contact details, employment, income, housing, vehicle requirements, trade-in and other financial or application information.

Submitting an application does not guarantee financing approval.

Any lender, dealership or financing provider receiving information may have its own privacy practices and may require separate consents or authorizations before performing activities such as obtaining a credit report.

7. COMMERCIAL FINANCING AND SOLUCO FINANCIAL GROUP INC.

GYC Commercial Financing is a customer-facing service operated by Giving You Credit Financial Services Inc.

Giving You Credit is not itself the lender for financing offered through GYC Commercial Financing.

Commercial financing is provided or arranged by Soluco Financial Group Inc. and/or its applicable financing partners.

Giving You Credit and Soluco Financial Group Inc. are separate legal entities.

When you submit a commercial financing inquiry or application, GYC may collect and disclose information to Soluco as reasonably necessary to:

• review the financing request;

• identify potentially suitable financing options;

• communicate with you about the request;

• verify information;

• obtain required documentation;

• evaluate a proposed equipment, vehicle or business transaction; and

• arrange or facilitate financing.

Soluco may disclose information to applicable financing partners as part of reviewing or arranging the requested financing, subject to applicable consent requirements and its own legal obligations.

Soluco and applicable financing partners may process information independently of GYC and may maintain their own privacy policies, practices and records.

Where separate consent or authorization is required for a credit inquiry or other financing-related activity, that authorization will be addressed separately as appropriate.

8. DEALERS, VENDORS AND REFERRAL PARTNERS

GYC may receive personal information from or disclose information to dealerships, equipment vendors, referral partners or other businesses where reasonably necessary to provide a requested service and where authorized or otherwise permitted by law.

For example, an individual may submit a financing request through a dealership or vendor, or GYC may connect an applicant with a dealership or financing source.

These businesses are separate organizations and may have their own privacy policies and obligations.

9. A2Z SOLUTIONS AND TECHNOLOGY SERVICE PROVIDERS

GYC uses third-party technology and service providers to operate, maintain, secure and support its Sites and digital services.

A2Z Solutions provides certain website, customer relationship management (CRM), automation, communications and technology services to Giving You Credit.

In providing these services, A2Z Solutions may process or have access to personal information on behalf of GYC where reasonably necessary to provide, maintain, secure, troubleshoot or support those services.

This may include information contained within:

• CRM contact records;

• forms and application submissions;

• email and SMS communications;

• telephone and messaging systems;

• webchat;

• appointment and consultation systems;

• workflow and automation systems; and

• website and technical systems.

A2Z Solutions acts as a technology/service provider in this context. It does not make credit decisions, approve or decline financing applications, determine financing terms or act as a lender through the GYC Sites.

GYC may also use other service providers for services such as:

• website hosting and infrastructure;

• CRM and communications;

• telephone and messaging;

• email delivery;

• cloud storage;

• analytics;

• security;

• payment processing;

• document management and electronic signatures;

• appointment scheduling;

• customer support; and

• other operational technology.

Service providers may only require access to information appropriate to the services they perform.

The Office of the Privacy Commissioner of Canada states that an organization remains accountable for personal information under its control, including information transferred to third parties for processing. Office of the Privacy Commissioner

10. WHEN WE DISCLOSE PERSONAL INFORMATION

Depending upon the service requested, GYC may disclose personal information to:

• employees and authorized contractors;

• A2Z Solutions and other service providers acting on our behalf;

• dealerships;

• vendors;

• Soluco Financial Group Inc.;

• lenders, lessors and financing partners;

• referral partners where applicable;

• professional advisers;

• regulatory or governmental authorities where required; and

• other parties with your consent or as permitted or required by law.

We do not sell or rent personal information as a business practice.

We may disclose information without consent where permitted or required by applicable law, including circumstances involving legal process, investigations, fraud prevention, emergencies, debt collection or protection of legal rights.

11. CREDIT INFORMATION AND CREDIT INQUIRIES

Certain financing services may require a credit report or other credit information.

GYC does not represent that merely visiting a Site or submitting a general inquiry automatically authorizes a credit inquiry.

Where a credit inquiry or other activity requires specific authorization, consent will be obtained through the applicable application, authorization or financing process as required.

Credit bureaus, lenders and financing providers may maintain information under their own privacy practices and legal obligations.

12. ELECTRONIC COMMUNICATIONS AND CASL

If you provide us with an email address, telephone number or other electronic contact information, we may communicate with you regarding your inquiry, application, consultation, requested service or existing relationship as permitted by law.

We may communicate through email, SMS/text messaging, telephone, voicemail, webchat, social-media messaging or other electronic channels.

Marketing and other commercial electronic messages are sent in accordance with applicable requirements under Canada's Anti-Spam Legislation ("CASL").

Where CASL applies, commercial electronic messages are sent on the basis of an applicable form of consent or other lawful authority and include required identification and unsubscribe functionality.

The CRTC states that organizations sending commercial electronic messages must obtain applicable consent, provide identification information and include an unsubscribe mechanism. Requests to unsubscribe from commercial electronic messages must generally be acted upon within 10 business days. CRTC Web

You may unsubscribe using the mechanism provided in an applicable electronic message or contact us using the information below.

Opting out of marketing does not necessarily prevent us from sending transactional, administrative, security, application-related or other communications permitted or required by law.

13. AUTOMATION AND ARTIFICIAL INTELLIGENCE

GYC may use automated workflows, artificial intelligence and related technologies to support communications and business operations.

These systems may assist with:

• responding to inquiries;

• answering common questions;

• collecting or verifying information;

• routing inquiries;

• scheduling;

• application follow-up;

• reminders;

• customer service;

• summarizing communications;

• organizing CRM information; and

• assisting GYC personnel.

Information provided through these interactions may be processed through technology systems used by GYC and its service providers.

Automated technology does not independently guarantee financing approval and does not replace the credit or underwriting requirements of an applicable lender or financing provider.

Where automated tools are used, GYC remains responsible for personal information under its control.

14. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES

Our Sites may use cookies, pixels, tags, analytics tools and similar technologies.

These technologies may be used to:

• operate essential Site functionality;

• remember preferences;

• maintain security;

• understand how visitors use our Sites;

• measure traffic and performance;

• identify technical problems;

• measure advertising and referral performance; and

• support marketing and remarketing activities where permitted.

Depending upon your location and applicable law, you may be provided with controls allowing you to accept, reject or manage certain non-essential technologies.

You may also adjust browser settings to block or delete cookies. Disabling certain cookies may affect Site functionality.

15. THIRD-PARTY WEBSITES

Our Sites may contain links to websites or services operated by third parties.

GYC does not control the privacy practices of independent third-party websites.

When you leave a GYC Site or interact directly with another organization's service, that organization's privacy policy and terms may apply.

We encourage you to review the privacy practices of organizations to which you provide personal information.

16. CROSS-BORDER PROCESSING AND STORAGE

GYC and its service providers may use technology infrastructure or service providers located outside British Columbia or Canada.

As a result, personal information may be processed or stored in another province, the United States or another jurisdiction.

When personal information is processed or stored in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies or governmental authorities in accordance with applicable law.

GYC remains accountable for personal information under its control and uses reasonable contractual, administrative and technical measures appropriate to the circumstances when information is processed by service providers.

17. SAFEGUARDS

GYC uses reasonable administrative, technical and physical safeguards appropriate to the sensitivity of personal information under its control.

Measures may include, as appropriate:

• access controls;

• authentication measures;

• encryption in transit;

• secure technology infrastructure;

• restricted access to systems and information;

• security monitoring;

• employee and contractor access limitations;

• service-provider controls;

• backups and system protections; and

• procedures for responding to security incidents.

No electronic system or method of transmission is completely secure. We therefore cannot guarantee absolute security.

If GYC becomes aware of a privacy breach, we will assess and respond to the incident in accordance with applicable legal requirements.

18. RETENTION AND DELETION

GYC retains personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected and to meet legitimate business, contractual, legal, regulatory, dispute-resolution and record-keeping requirements.

Retention periods may vary depending upon the type of information and service involved.

When personal information is no longer reasonably required, GYC will take appropriate measures to securely delete, destroy or anonymize it, subject to applicable legal and operational requirements.

A request to delete personal information does not necessarily require GYC to delete information that it must or is permitted to retain for legal, regulatory, contractual, fraud-prevention, dispute-resolution or legitimate record-keeping purposes.

19. ACCESS AND CORRECTION

Subject to applicable law, you may request access to personal information GYC holds about you and request correction of information that is inaccurate or incomplete.

We may need to verify your identity before responding to a request.

Certain information may be withheld where permitted or required by law, including information concerning another individual, legally privileged information or information subject to another lawful restriction.

If we cannot provide access to requested information, we will explain the reason where required by law.

British Columbia's Office of the Information and Privacy Commissioner confirms that PIPA provides individuals with rights concerning access and correction of personal information held by private-sector organizations. OIPC British Columbia

Requests may be submitted using the contact information in Section 21.

20. CHILDREN AND MINORS

The Sites and GYC's financing services are not directed toward children.

Individuals should not submit financing applications or other personal information unless they have the legal capacity and authority required for the applicable transaction.

If we learn that personal information has been collected from a child in circumstances where it should not have been collected, we will take reasonable steps appropriate to the circumstances.

21. PRIVACY QUESTIONS, ACCESS REQUESTS AND COMPLAINTS

Questions concerning this Privacy Policy, requests to access or correct personal information, withdrawal of consent where applicable, or privacy complaints may be directed to:

Privacy Officer
Giving You Credit Financial Services Inc.
2702 Highway 97 North
Kelowna, British Columbia
V1X 4J7
Canada

Telephone: 1-888-506-0516
Email: [email protected]

Please include enough information for us to understand and respond to your request.

We may need to verify your identity before providing access to personal information or acting on certain requests.

GYC will review privacy complaints and inquiries and take reasonable steps to address substantiated concerns.

Canadian privacy guidance specifically recommends identifying the person or title accountable for privacy compliance and making that contact information readily available. Office of the Privacy Commissioner

22. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to:

• our services;

• our Sites;

• technology;

• service providers;

• financing relationships;

• privacy practices; or

• applicable legal requirements.

When changes are made, we will update the "Last Updated" date at the beginning of this Policy.

Where a change materially alters how personal information is collected, used or disclosed, we will provide additional notice or obtain additional consent where required by applicable law.

Continued use of a Site does not override any consent rights or other protections that cannot lawfully be waived.

23. YOUR PRIVACY CHOICES

Depending upon the circumstances and applicable law, you may:

• ask questions about our privacy practices;

• request access to personal information under our control;

• request correction of inaccurate or incomplete information;

• withdraw certain consent, subject to applicable restrictions;

• unsubscribe from commercial electronic messages;

• manage available cookie preferences; and

• submit a privacy complaint.

Some information is necessary for GYC to provide a requested service. If you decline to provide required information or withdraw consent necessary to process an application or provide a service, we may be unable to continue providing that service.

24. APPLICABLE PRIVACY LAWS

GYC handles personal information in accordance with applicable Canadian privacy laws.

Depending upon the circumstances, these may include British Columbia's Personal Information Protection Act (PIPA) and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

Which law applies can depend upon factors such as the nature of the activity and whether personal information moves across provincial or national borders. Canada's Privacy Commissioner continues to identify accountability, consent, limiting collection, limiting use/disclosure/retention, safeguards, openness and individual access among PIPEDA's core requirements. Office of the Privacy Commissioner.

Nothing in this Privacy Policy limits any privacy rights that cannot lawfully be limited or waived.