Privacy Policy

Capital Lynk respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how Capital Lynk collects, uses, discloses, stores, retains, and otherwise processes personal information when you visit our website, use our mobile experiences, complete digital application flows, communicate with us, or otherwise use our services, including financing marketplace services, lender matching tools, verification workflows, and related products and features (collectively, the “Services”).

In this Privacy Policy, “Capital Lynk,” “we,” “our,” and “us” refer to Capital Lynk and its affiliates. “You” and “your” refer to any visitor, applicant, customer, user, or business representative who interacts with the Services.

By accessing or using the Services, you acknowledge that your personal information will be handled as described in this Privacy Policy, subject to applicable law and any additional consents, disclosures, or notices provided for specific products or workflows.

1. Scope of This Policy

This Privacy Policy applies to personal information we collect in connection with:

• our website and online interfaces;

• digital application and intake flows;

• account registration and authentication;

• identity, financial, document, and verification workflows;

• communications with us by email, phone, SMS, chat, or support ticket;

• interactions with third-party service providers integrated into the Services; and

• business development, sales, customer support, and operational activities related to the Services.

This Privacy Policy does not apply to:

• personal information handled solely by third-party lenders, funders, insurers, payment processors, analytics providers, verification partners, or other third parties acting under their own privacy policies;

• publicly available information, where permitted by law; or

• information that has been aggregated or de-identified so that it no longer reasonably identifies an individual.

2. Personal Information We Collect

Depending on how you interact with the Services, we may collect personal information such as:

Identity and contact information

Your name, email address, phone number, mailing address, date of birth, and other identifying information.

Account and authentication information

Login credentials, account preferences, account activity, two-factor authentication details, and related security information.

Application and profile information

Information you provide when completing an application, intake form, onboarding flow, or account profile, including employment, business, financial, and background details.

Government-issued identification and verification data

Identification documents, document images, selfies, biometric verification results where available and separately consented to where required, verification status, and fraud signals.

Financial and banking information

Bank account information, transaction data, income information, cash-flow information, account verification data, and related financial records obtained from you or authorized third-party connectivity providers.

Credit and credit-related information

Credit application information, credit report data, credit attributes, and related information, where requested, authorized, and permitted by law.

Business information

Business name, ownership details, formation details, tax or registration information, merchant processing information, operating information, and related business records.

Communications and support information

Records of your communications with us, including emails, support messages, call notes, SMS messages, and customer service interactions.

Device, usage, and technical information

IP address, browser type, operating system, device identifiers, session data, referral URLs, pages visited, clicks, and other information about how you interact with the Services.

Payment and transaction information

Payment status, transaction identifiers, billing details, and limited payment-related information where fees are charged through the Services. Payment card information is typically processed by third-party payment processors, not stored by us in full.

Compliance and risk information

Fraud, sanctions, anti-money laundering, know-your-customer, watchlist, identity-risk, and security-related information generated by us or received from service providers and partners.

Other information you submit

Documents, forms, IDs, contracts, signatures, uploads, survey responses, feedback, and any other information you choose to provide.

We collect only the personal information reasonably necessary for the purposes identified in this Privacy Policy or otherwise disclosed to you, in line with Quebec private-sector privacy law’s necessity principle and broader meaningful-consent expectations under Canadian privacy guidance.  

3. How We Collect Personal Information

We may collect personal information:

• directly from you when you fill out forms, create an account, complete an application, upload documents, make a payment, or contact us;

• automatically when you use the Services through cookies, pixels, logs, analytics tools, and similar technologies;

• from third-party verification, banking, credit, communications, payments, and fraud-prevention providers that you authorize or that are engaged to support the Services;

• from lenders, brokers, referral sources, marketplaces, service providers, or business partners involved in a transaction or workflow you request;

• from publicly available or legally accessible sources, where permitted by law; and

• from corporate representatives, co-applicants, guarantors, beneficial owners, or other persons connected to a business application or account.

4. Why We Use Personal Information

We may use personal information for the following purposes:

To provide the Services

To create and manage accounts, present application flows, process requests, connect users with providers, and operate the platform.

To verify identity and eligibility

To verify identity, review submitted information, validate documents, confirm banking or income information, support fraud prevention, and facilitate application processing.

To facilitate lender or provider matching

To route, transmit, or present information to lenders, brokers, funders, insurers, or other providers relevant to your request.

To communicate with you

To send transactional messages, service notices, reminders, support responses, status updates, verification steps, security notices, and, where permitted and appropriately consented to, marketing communications.

To process payments and fees

To collect and reconcile payments, verification fees, service fees, or related transaction amounts.

To maintain security and integrity

To detect, investigate, and prevent fraud, abuse, unauthorized access, cyber threats, and other misuse of the Services.

To comply with legal and regulatory obligations

To meet obligations relating to recordkeeping, consumer protection, anti-fraud, anti-money laundering, sanctions screening, dispute handling, and lawful requests.

To improve and develop the Services

To analyze usage, improve user experience, develop features, troubleshoot issues, test systems, and enhance workflows.

To manage our business

To administer operations, enforce our agreements, manage audits, handle claims, train staff, and support internal governance and compliance.

Under Canadian privacy guidance, consent is meaningful only where people understand the nature, purpose, and consequences of the collection, use, or disclosure of their information. That is why certain higher-sensitivity steps, such as bank connectivity, ID verification, biometrics, hard-credit events, or fee-bearing workflows, should also be paired with more specific just-in-time notices or consents in the product flow.  

5. Our Legal Basis and Consent Approach

Where required by applicable law, we collect, use, and disclose personal information with your consent or as otherwise permitted or required by law.

Depending on the situation, consent may be express or implied, subject to applicable law and the sensitivity of the information. We generally seek clearer or more explicit consent for more sensitive information or activities, including where appropriate:

• identity verification involving document capture or biometrics;

• banking connectivity and transaction retrieval;

• credit-related information or credit report access;

• marketing or promotional communications where consent is legally required; and

• disclosures to third parties outside what a reasonable person would expect from the workflow.

In some cases, we may collect, use, or disclose personal information without consent where permitted or required by law, including for fraud prevention, legal compliance, security incidents, debt collection, investigations, or responding to lawful requests.

6. How We Share Personal Information

We may disclose personal information to the following categories of recipients:

Lenders, funders, brokers, insurers, and financial partners

To evaluate your request, provide offers, assess eligibility, or service a transaction.

Verification and data service providers

Including identity verification, banking connectivity, income verification, credit, fraud, sanctions, compliance, e-signature, and workflow infrastructure providers.

Payment, communications, and technology providers

Including payment processors, cloud hosting providers, analytics vendors, CRM providers, messaging vendors, support platforms, and software tools that help us operate the Services.

Professional advisors and corporate counterparties

Including lawyers, auditors, insurers, financing sources, investors, acquirers, and advisors, where reasonably necessary for lawful business purposes and subject to appropriate protections.

Regulators, authorities, and parties involved in legal process

Where required to comply with applicable law, court orders, regulatory requests, subpoenas, or other lawful obligations.

Affiliates and internal personnel

To the extent reasonably necessary for operations, support, security, product development, compliance, and administration.

Business transaction participants

In connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, or similar transaction, subject to customary confidentiality measures.

We do not sell personal information in the ordinary consumer-data-broker sense. We may, however, share application and related information with financing and service partners as part of providing the Services you request.

7. Third-Party Integrations and Providers

The Services may rely on third-party technologies and providers, including providers for:

• identity verification;

• credit and risk data;

• banking and financial-data connectivity;

• e-signature;

• communications and messaging;

• payments;

• analytics;

• fraud, AML, and compliance tools; and

• cloud hosting and infrastructure.

When you proceed through a workflow that uses these providers, your information may be collected, processed, or disclosed to them as needed to complete that step. In some cases, the third party acts on our behalf. In other cases, the third party may act under its own legal terms and privacy policy. We encourage you to review any additional disclosures presented in the workflow.

8. Cookies, Analytics, and Similar Technologies

We and our service providers may use cookies, pixels, local storage, SDKs, and similar technologies to:

• keep the Services functioning properly;

• remember preferences and sessions;

• understand website traffic and usage patterns;

• measure performance and troubleshoot issues;

• improve user experience; and

• support marketing and advertising efforts where permitted.

These technologies may collect information such as IP address, device information, browser characteristics, pages visited, time spent, clicks, and referral data.

Where required by law, we will seek consent before using non-essential cookies or similar technologies. You may also be able to control cookies through your browser settings, though doing so may affect functionality.

9. Marketing and Electronic Communications

If you provide contact information, we may send you transactional and relationship messages about your account, application, support case, verification steps, payments, security, or service updates.

We may also send marketing or promotional communications where permitted by law and where any required consent has been obtained. Under CASL, commercial electronic messages generally require consent, identification information, and an unsubscribe mechanism.  

You can unsubscribe from marketing emails by using the unsubscribe link included in the message. You may also contact us to withdraw consent for certain promotional communications. Even if you opt out of marketing, we may still send you service, legal, fraud-prevention, payment, and security-related communications where permitted by law and operationally necessary.

10. Cross-Border Processing and Service Providers

Capital Lynk may use service providers or partners located outside your province, territory, or country, including elsewhere in Canada and in the United States.

As a result, your personal information may be processed, stored, or accessed in jurisdictions with different legal regimes, including jurisdictions where courts, regulators, law enforcement, or national security authorities may have lawful access rights.

When we use service providers to process personal information on our behalf, we aim to use contractual and operational safeguards that are appropriate to the sensitivity of the information and the nature of the processing.

11. Retention of Personal Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, to satisfy legal, accounting, reporting, dispute-resolution, fraud-prevention, security, and recordkeeping obligations, or as otherwise permitted or required by law.

Retention periods may vary depending on:

• the nature and sensitivity of the information;

• whether an account, application, or transaction remains active;

• legal and regulatory requirements;

• dispute, litigation, audit, or enforcement needs; and

• fraud and security considerations.

When personal information is no longer required, we will delete it, anonymize it, or securely destroy it, subject to technical feasibility and legal retention requirements.

12. Safeguards

We use administrative, technical, and physical safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification.

These safeguards may include:

• access controls and role-based permissions;

• encryption in transit and, where appropriate, at rest;

• vendor due diligence and contractual controls;

• logging and monitoring;

• secure development and change-management practices;

• employee training and confidentiality obligations; and

• incident response processes.

No system can be guaranteed to be completely secure. You are also responsible for protecting your credentials, devices, and account access information.

13. Your Privacy Rights

Subject to applicable law and certain exceptions, you may have the right to:

• request access to personal information we hold about you;

• request correction of inaccurate or incomplete information;

• withdraw consent, where processing is based on consent and withdrawal is legally and operationally possible;

• request information about how your personal information has been used or disclosed;

• request deletion or anonymization in certain circumstances;

• request that we stop certain communications; and

• file a complaint with us or, where applicable, with a privacy regulator.

The exact scope of these rights depends on the laws that apply to you and the nature of the information and processing involved.

To exercise a privacy request, contact us using the details in the “Contact Us” section below. We may need to verify your identity before responding.

14. Automated Processing and Decision Support

Capital Lynk may use software, rules, analytics, scoring logic, or workflow tools to help organize applications, detect fraud, prioritize reviews, or support matching and routing decisions.

Unless expressly stated otherwise for a specific product, Capital Lynk does not itself make final lending or underwriting decisions. Final credit, lending, insurance, or similar product decisions are generally made by third-party providers using their own criteria and systems.

Where a particular workflow involves a more material form of automated decision processing by Capital Lynk itself, additional disclosures may be provided where required by law.

15. Children’s Privacy

The Services are not intended for children under 18, and we do not knowingly collect personal information directly from anyone under 18 in connection with the Services. If we become aware that personal information has been collected from a person under 18 in violation of applicable law or our policies, we will take reasonable steps to delete it.

16. External Links and Third-Party Sites

The Services may contain links to websites, services, or resources operated by third parties. We are not responsible for the privacy practices, content, or security of those third parties. Your interactions with those third parties are governed by their own terms and privacy policies.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the Services, our practices, technology, legal requirements, or business operations.

When we make material changes, we will update the “Last updated” date and may provide additional notice where required by law or where appropriate, such as by posting a notice on the website, within the Services, or by contacting you directly.

Your continued use of the Services after an updated Privacy Policy becomes effective means that you acknowledge the updated policy, subject to any additional legal requirements that may apply.

18. Contact Us

If you have questions about this Privacy Policy, want to exercise a privacy right, or want to submit a privacy-related complaint or request, please contact:

Capital Lynk

5101 Rue Buchan, Montréal, QC H4P 0A9

info@capitallynk.com

1-866-903-5012

capitallynk.com

Privacy Requests / Privacy Officer

You may also direct privacy-specific requests to: info@capitallynk.com