FirstStep Financial Corp (“FirstStep”, “we”, “us”, our“)FirstStep Financial was founded on principles of trust, integrity and the delivery of outstanding service and is committed to protecting the privacy of its customers and users. www.firststepfinancial.ca, owned and operated by FirstStep Financial  has taken extensive measures to protect the confidentiality of your personal information and to protect your data from misuse and unauthorized access or disclosure. For the purposes of this Privacy Notice, “personal information” means any information that can reasonably be used, either alone or in combination with other information, to identify you.

‍When does this Privacy Notice apply?
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‍This Privacy Notice explains how FirstStep collects, uses, and discloses your personal information when you inquire about, apply for, or purchase FirstStep Equity Financing or any other product (“FirstStep Product”) from us.

This Privacy Notice applies as long as you have a relationship with us. In addition, this Privacy Notice applies to information we may collect from you when you visit us at www.firststepfinancial.ca, (the “Site”) or when we communicate via email or telephone.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, although we take great measures to protect your information, FirstStep Financial cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Once we receive your transmission, FirstStep Financial takes over and above industry standard efforts to safeguard the confidentiality of your information, such as Firewalls and unique User Name and Password protections. We also restrict internal access of stored data to select employees that have been informed of our privacy policies.

‍What personal information does FirstStep collect?

‍We may collect the following types of personal information directly from you at the point of purchase or service, when you make customer service inquiries, or when we respond to your requests for information. This helps us understand our Customers’ needs better and improve areas of our services that our Customers find valuable:

Your identity (such as your name, address, email address, phone number, occupation, date of birth, or copies of government-issued documents);

Loan Submission If you submit a loan request to www.firststepfinancial.ca you are required to provide certain information necessary to deliver the selected services. In some instances, you will only provide personal information such as name, address, e-mail address, phone number and other contact information. The more information you share with FirstStep Financial the more accurately FirstStep Financial will be able to provide you with information and services you have indicated are of interest.

Your financial status, including your annual income, assets (including the value of your home), and liabilities (including the amount of any remaining mortgage on your home).

Your balances and transactions, including any FirstStep Product account activity or payment history;

‍Communications information: If you send us an email, send us a message on the ‘Contact Us’ page of the Site, phone us, we may collect personal information you provide to us during those communications, such as the content of your comments, complaints, feedback, or inquiries;

‍Any other additional information that we may request to help us to determine your eligibility for a FirstStep Product.  We may collect information about your credit history from third parties like credit reporting agencies in connection with your application to purchase a FirstStep Product.

We may automatically collect certain technical information from any device that you use to visit our Site. This includes:

Your device’s IP address, web browser type and version, hardware model, time zone setting, browser plug-in types and versions, and operating system, as well as your internet service provider.

‍Information about how you use the Site, including the uniform resource locators (“URLs”) of other websites that you click to and from our Site (including the date and time clicked), emails we send that you open, forward, or click through to our Site, page response times, download errors, length of visits to certain pages on the Site, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We may collect some of the above technical information using cookies or similar technologies. See Cookies & Other Technologies below for more detail on how we collect and use this information.

‍How does FirstStep use your personal information?
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‍We may use your personal information to:
– Present our Site and its contents to you;
– Create your account with us;
– Communicate with you;
– Process your application for a FirstStep Product, including verifying information included in your application;
– Enter into and perform transactions related to FirstStep Products, including processing payments to you;
– Manage and administer your FirstStep Product, including ongoing evaluation of credit and maintaining records for legal and accounting purposes;
– Maintain our customer service records;
– Respond to your requests, complaints, comments and questions; comments or requests for information;
– Satisfy any audit, insurance, self-regulatory or regulatory requirements applicable to us;
– Enforce our legal rights with respect to any agreement you may have this us, including to collect a debt or enforce an obligation owed to us by you;
– Better understand how visitors interact with our Site, and improve the Site;
Detect and prevent security threats to the Site.

‍COOKIES & THIRD PARTIES
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‍We may use technologies such as cookies and other similar technologies to automatically collect certain information about visitors to our Site. A “cookie” is a unique numeric code that we transfer to your computer that identifies your browser to our server when you visit various pages of the Site. We use cookies to recognize you as a return visitor to the Site and save any information you may have entered into a form.  Any cookie sent to your computer by FirstStep in connection with your use of the Site does not give us access to your computer. You can set your Internet browser settings to stop accepting new cookies, to receive notice when you receive a new cookie, or to disable existing cookies.

We may use third parties to serve our advertisements on other websites. In serving our advertisements, these companies may use cookies and other tracking devices to collect certain information about your visits to other websites (such as browser type, IP address, which page was visited, and time of day). This information may be used to evaluate our online advertising campaigns or to tailor promotions and other marketing messages to you. You may elect to refuse cookies. Please refer to the Help instructions in your browser to learn more about cookies and how to manage their use.

‍How and why does FirstStep share my personal information?
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‍In order for us to fulfill the purposes of this Privacy Notice, we may need to share your information with third parties. In order to provide you with your FirstStep Product, we will share your personal information with our operating company affiliate, who will use the information to administer and service your FirstStep Product. Our affiliate will only use your personal information based on our instructions, and we use specific contractual means to ensure that your personal information is kept confidential and secure when in the control of our affiliate. If you apply for a FirstStep Product, we may verify your personal information by sharing it with credit bureaus, credit insurers, third party verification services, registries, financial service industry databases, investigative bodies, personal references, or other lenders. If you have purchased a FirstStep Product from us, we may share credit and other information about you with others (including credit bureaus, mortgage insurers, creditor insurers, registries and other persons with whom you may have financial dealings, as well as any other person as may be permitted or required by law) for the purposes of evaluating your current and ongoing creditworthiness and maintaining your credit history. We may also share information with credit reporting agencies or credit bureaus relating to your FirstStep Product. This may include, but not be limited to, if you fail to meet any of your obligations under the applicable terms and conditions of those products. FirstStep may share your information with service providers in order to analyze and determine trends about visitors’ use of the Site. We may share your personal information with third party service providers who help us to, Host Site data; Design, administer, and maintain the Site; Understand how visitors interact with the Site, in order to improve the Site experience; Provide customer service support; When we allow a third party service provider to access your personal information, we will only allow them to access or use it for the sole purpose of carrying out the above services on our behalf. If there are any other parties connected to your account (e.g. guarantors, powers of attorney, and other people named on your application), we may share your personal information with them as permitted by law. We may share your personal information with government, regulatory or law enforcement agencies as requested by these agencies, if we have a good faith belief that the disclosure is required or permitted by law. We may also share your personal information in order to enforce our legal rights; to detect, prevent or address fraud or security issues; and to enforce ours or others’ legal rights, property, or safety. We may also transfer or assign your personal information to third parties because of, or in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation. We do not trade, rent or sell your personal information to third parties.

‍How does FirstStep keep my personal information safe?
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‍FirstStep maintains commercially reasonable methods, including the use of data security and encryption standards, to preserve the confidentiality of your personal information and to ensure that it is only used for the purposes that we have identified. We regularly review our collection, storage, and processing practices to prevent unauthorized access to our systems. We restrict access to your personal information to only those FirstStep associates, affiliates, and service providers who require that information to carry out the purposes identified above at Section 3 of this Privacy Notice, and anyone with this access is subject to strict confidentiality obligations. However, you should be aware that no system is 100% secure, and despite our best efforts, we cannot guarantee that your information will be secure, particularly while it is in transit over the Internet. We only retain your personal information for as long as necessary to fulfill the purposes we have identified throughout this Privacy Notice, or as otherwise required or permitted by law. One or more of our service providers may not be located in Canada, and so your personal information may be transferred to, stored, or processed in another country where the laws are different from those in Canada (e.g. the United States). As a result, your personal information may be accessible to regulatory authorities in accordance with the laws of those other jurisdictions.

Removal of Personal Information
You can request that we purge the entirety of the personal information submitted by you through www.firststepfinancial.ca from our database by providing detailed instructions to FirstStep Financial Privacy Officer (see below). In such cases, FirstStep Financial will delete all digitally warehoused information you have submitted. Please note that FirstStep Financial cannot purge information from the systems or files of our FirstStep Financial Affiliates, service providers or other financial institutions that have subsequently been sent your personal information to provide their services.

If you do not wish to participate in our remarketing, you can opt out here: https://www.google.com/settings/ads/onweb/

Terms Of Use
FirstStep Financial provides the www.firststepfinancial.ca Internet site “as is” to the user without any warranty or condition, express, implied or statutory. FirstStep Financial disclaims any implied warranties of title, merchantability, non-infringement of intellectual property or fitness for any particular purpose.

Except as may be otherwise expressly provided by written agreement between FirstStep Financial and the user, FirstStep Financial will have no tort, contract or any other liability to the user and/or any third party arising in connection with the use of this Internet site, or reliance on any information or services provided at this Internet site.

FirstStep Financial does not endorse the services or products of advertisers, sponsors, or affinity partners. Product or service information is believed to be correct, but should not be relied on without prior verification. www.firststepfinancial.ca contains links to outside sites, through banners, and other portals, to third party sites that send their own cookies, collect data and solicit information. CEG does not control these sites and as such we do not endorse their products, services or information and are not associated with the operators.

In the event of errors or omissions in any information, FirstStep Financial sole responsibility shall be to use its best efforts to correct, by the issue of a corrected release, any errors or omissions which it or any of its employees, servants or agents may have made, negligently or otherwise, in transmitting copy accurately and which are brought to its attention. Without limiting the generality of the foregoing, in no event shall FirstStep Financial or any of its servants, employees or agents be liable in contract, tort or otherwise to any person (including, without limitation, the subscriber) for any loss, damage, injury, liability, cost or expense of any nature (including, without limitation, direct, indirect, consequential, incidental, special and punitive damages) which such person may suffer or incur as a result of any such errors or omissions or any delays in transmission or non-transmission.

Your Acceptance Of These Terms

By using this site, or by submitting personal information to us, you signify your agreement to FirstStep Financial Privacy Policy and Terms Of Use. From time to time we may change or update our privacy policies. It is your responsibility to check back regularly to inform yourself of such changes. Your continued use of www.firststepfinancial.ca following the posting of changes to these terms will be deemed as your acceptance of those changes.