Our privacy philosophy

At Spark Credit, trust, support, and reliability are core to our guiding principles. Read through this Privacy Policy (“Privacy Policy”) so you understand how we use, share, secure, and store your data.

Our Policy

Welcome to the website https://sparkcredit.ca (the “Website”) of Spark Credit & CompareHub & Loans Canada & Prêts Québec (6069321 Canada Inc) (“Spark Credit”, “we,” “us,” or “our”). Spark Credit is a loan comparison platform and is used to learn about lenders and credit or to apply for loans and other financial services or other related services (collectively, the “Service(s)”). Users may also obtain a free credit report by creating a membership account through our CompareHub brand. Spark Credit does not arrange or underwrite any financial services and is simply a referral service. When you apply for a service on Spark Credit, our platform will make a referral of your application to qualified providers. “Users” and “you” refer to anyone who visits or uses our Services, or communicates with us. The Website is a copyrighted work belonging to 6069321 Canada Inc.

This Privacy Policy explains what personal information we collect, how we use and share that personal information, and your choices concerning our personal information practices. For the purposes of this Privacy Policy, “Personal Information” is any information about an identifiable individual, but does not include business contact information used to contact the individual for purposes relating to their job. For any collection, use, disclosure or other processing that is not reasonably necessary to provide what you’ve asked from us or for purposes connected to enforcing or protecting your or our rights, you can opt-out of such information handling practice. To learn how to opt-out, please see the section entitled “Your Choices”.

Short Summary

The purpose of our technology platforms is to help Canadians achieve better financial outcomes.

We operate multiple brands including Spark Credit, Loans Canada, Prêts Québec and CompareHub. Loans Canada and Prêts Québec provide Canadians with free educational and financial product comparison resources. CompareHub is a free membership platform Canadians can use to obtain their Equifax credit score and report for free.

Loans Canada and Prêts Québec offer the ability to apply for a variety of financial services, including personal loans, car loans, debt consolidation and other services. Users can apply by clicking on links to product or service provider landing pages, or by submitting applications for certain services directly on the Loans Canada or Prêts Québec websites.

When users apply on Loans Canada or Prêts Québec by submitting a form, they will be asked to provide certain personal information to complete their requests. This information may be shared with one or more third parties to help the User with their request as we are not a direct service provider (see our Terms of Use). Users from Quebec can expect their data to be deleted after 12 months of their application submission, with the exception of basic contact information (such as their email address) if they opt in to receive marketing communications.

Given the nature of the CompareHub platform, some personal information will always be required to meet the functional requirements of that platform. If a User no longer wishes to receive their free credit report on CompareHub, they can request for their data to be deleted and their membership account closed.

With an exception existing for Users we identify to be from Quebec, who must first opt-in, we automatically employ the use of cookies and third-party trackers on our web properties.

For information on the type of data we collect, how it is stored, and other details please review the rest of this policy. The table of contents above will make the information you are looking for easy to find.

If you have any questions or would like to contact our privacy officer please submit a privacy information request here or feel free to contact us at our designated request address: legal@loanscanada.ca.

Agreeing To The Terms Of Our Privacy Policy

Before using the Services or submitting any Personal Information to Spark Credit, please review this Privacy Policy carefully and contact us if you have any questions. By using Spark Credit or submitting any information to Spark Credit, you have agreed to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Website or otherwise use the Services. This Privacy Policy is incorporated into and subject to our Terms of Service (the “Terms of Service”). 

The Service is intended to be used by Users only in Canada. If you are not in Canada, please do not use our Services.

Personal Information We Collect

Our primary purpose when collecting Personal Information is to provide the Services expected from us by our Users, to achieve optimal operation of our business, and to improve the quality of their interactions by creating customized experiences. The type of Personal Information we collect is reasonably connected to these purposes. For any information that is not reasonably connected to the reason you reached out to Spark Credit, you may opt-out of the information handling practice.

Spark Credit only collects information required to match Users with providers for the Services they request. Our goal is to minimize intrusiveness and maximize the protection of your Personal Information. The type of information that may be collected varies on the Service used (including loan applications, debt relief, business financing, credit building solutions, car loan services, mortgage services, and money transfers, CompareHub portal membership), and includes, but is not limited to:

  1. Key Contact Information: We collect your name, email address, phone number, mailing/billing addresses, and any other information you choose to provide when you submit information to get a quote.
  2. Financial & Employment & Other Personal Information: When you inquire about a quote/estimate with us, we may ask you to provide, and will collect, the financial information necessary to provide further details to qualified third-party providers who can assist you with your search. Financial information & Other Personal Information (including date of birth and IP address) we collect from Users will be used to find eligible third-party providers for the financial service the User applied for. The information provided to us by Users may be shared with other financial service partners to process the User’s information on their behalf. Information is only disclosed to partners that have been bound by confidentiality obligations. In some instances, your personal or financial information recorded by us might be shared with third party tools, such as instant bank verification tools, so that we can provide improved product-matching Services. We make every effort to ensure your personal and financial information is safeguarded and that the service providers we work with are credible and practice proper security protocols.
  3. Identity Verification Information: In addition to providing their Key Contact Information and Other Personal Information, CompareHub members who choose to obtain their free credit report may be asked to verify their identity via a questionnaire provided by Equifax on the CompareHub portal. This is used to safeguard the user’s identity and protect their data from being accessed by unauthorized individuals or third-parties.
  4. Communication Information: We may collect information when you contact us with questions or concerns (such as for support purposes) and when you voluntarily respond to questionnaires, surveys, or requests for market research seeking your opinion and feedback. Providing communication information is optional for you. This includes communication preferences and your preferences in receiving marketing from us and third parties.
  5. Commercial Information: We may retain a history of the products you apply for using the Services.
  6. Social Media Information: We have pages on social media sites like Instagram, Facebook, Twitter/X.com, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages. 

Technical and Internet Activity Information: When you use the Services, we or (third-party tracking tools that we use) may automatically log the following information: 

  1. Device Information: This includes information like device manufacturer and model, device identifier, IP address, UA string, location, browser type, operating system, duration of use, user behaviour, length of time spent on the services, frequency of use, and unique identifiers of the device you use to access the Service. We may also collect diagnostic information relating to app crashes, app performance, network latency, and network errors. The information we collect may vary based on your device type and settings. 
  2. Usage Information: Information about how you use our Service (including on the Website or App), such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.  For the Website, we use Google Analytics, a web analytics service provided by Google LLC (“Google”) to help collect and analyze Usage Information. For more information on how Google uses this information, click here. Other tracking and analytics tools may be utilized by Spark Credit, including those provided by Facebook, Microsoft, TikTok and other social media or digital advertising platforms.
  3. Email Open/Click Information: We may collect information about the date and time you open or click links in emails we send. This data may be tracked by third-party email service providers such as Google/Gmail, Campaigner.com, MailerSend.com and MailGun.com.

Some of the information defined above may be logged whether or not you submit a Service request with us, with the exception existing for Users from Quebec who are first required to “opt-in” to such logging. When you submit a Service request, all of the information outlined in this section may be logged and stored as it may be required to appropriately service your request.

How We Collect Your Information

Personal Information may be collected in a number of ways, primarily through the Services.

In general, you can browse the Website without telling us who you are or revealing any Personal Information about yourself. If you would like to proceed with the Services, we require certain information from you in order to fulfill service features and functionality, or to verify your identity, and to provide a safe experience for all parties. Information collected includes, but is not limited to, identifying information, and contact information.

We may use the following technologies to collect information:

  1. Cookies, which are text files stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, and enable functionality (“Cookies”), help us understand user activity and patterns, and facilitate online advertising. By using Spark Credit, its websites or any of its services, you are accepting Cookies and in continuing to visit or use our Website, you are agreeing to the use of Cookies and similar technologies for the purposes we describe in this Privacy Policy.
  2. Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device, outside of your browser in connection with specific applications.
  3. Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
  4. Third-party metrics and analytics, including Google Analytics and other social media or digital advertising tracking pixels, on certain pages or features of the Service to help us understand and analyze visitor traffic, measure the promotional effectiveness and efficacy of our features, offerings, and marketing campaigns. We also use these tools to identify pitfalls, shortcomings, and areas of our operations in need of improvement, and to view the overall performance and ranking of our online presence. These tools might store Cookies on your device at their discretion. We sometimes use surveys or other forms provided by a third party. It is possible that when engaged, the third-party provider might collect information or store a Cookie. We never explicitly provide information that we have collected about you to any third parties. We recognize your right to employ the use of programs that may block our use of any third-party tools.
  5. Social media, if you post a review, make a comment, or otherwise submit Personal Information on a public forum such as with one of our social media accounts, your communications may be viewable by the public.

You do not have to use the Services if you do not want to disclose your information. You have the right to refuse to provide us with information by disengaging from the feature or offering that is making the request.

In compliance with Quebec law, users from the province of Quebec will automatically and by default be exempt from third-party tracking. Users from Quebec can expect an “opt-in” mechanism for cookies, local storage and other tracking technology. Spark Credit reserves the right to store cookies and/or other data for essential purposes only.

How We Use Your Information

In general, we use your Personal Information for the following purposes:

  1. Service Delivery, including to:
    • Provide, operate, maintain, and secure the Service.
      • Service request decisions are usually rendered automatically and when this occurs, Users are immediately notified of the results of the decision
  2. Communicating with You, including to:
    • Send you updates about administrative matters such as changes to our Terms of Service or Privacy Policy; and
    • Provide user support, and respond to your requests, questions, and feedback.
  3. Service Improvement, including to: 
    • Improve the Service and create new features; 
    • Facilitate and improve future Service requests,
    • Personalize your experience; and 
    • Create and derive insights from aggregated information. 
  4. Marketing and Advertising, including for:
    • Direct Marketing: To send you marketing communications, including notifying you of special promotions, offers, and events via email, SMS, phone calls and other means. Marketing communications can include both first-party and third-party offers sent by one of our brands.

      In adherence with Canada’s Anti-Spawn Legislation, you may only receive direct marketing messages from us if one of the two conditions below is met (and you have not unsubscribed):
      1. You provided us with express consent to receive marketing emails when submitting a Service request or when signing up as a CompareHub member.
      2. You provided us with implied consent to receive marketing emails from us when submitting a Service request. In this case your consent will expire 6 months after your request was submitted.

    1. Interest-Based Advertising: We engage advertising partners, including third-party advertising companies and social media companies, to display ads on the Service and other online services. These companies may use cookies and similar technologies to collect Technical and Internet Activity Information over time across the Service, our communications, and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to similar users (known as a “lookalike audience”) on other online platforms. 

      Users from the province of Quebec must first opt-in to have their data used for interest-based advertising by third party advertising platforms. These users may opt-in by selecting the appropriate cookie banner option when visiting one of our websites, by submitting a Service request, or by becoming a CompareHub member.

  5. Compliance and Protection, including to:
    • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
    • Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
    • Audit our compliance with legal and contractual requirements and internal policies; and
    • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

Personal Information Sharing

Spark Credit limits access to Personal Information provided by its Users. Personal Information may only be accessed by Spark Credit employees who require this access to achieve the requirements of their roles. Personal Information may be securely accessed by our employees in the following departments, and only to complete a function of their roles:

Data Sharing: We do not sell, rent, license, or lease your Personal Information to third parties except for the purpose of servicing your Service request.

Personal Information may be accessible by:

  1. Service Providers, including lenders, credit counsellors, mortgage brokers and other financial service providers that we are partnered with to help users find (or qualify for) the product or service they are requesting, or to find or qualify for a related service. For example, when a user submits a Personal Loan application, the User’s data may be shared with one or more service providers to assist the User with their loan application request.
  2. Technology Providers, including hosting services, email services, address APIs, bank verification services, credit reporting agencies, advertising and marketing services, payment processors, VOIP providers, customer support services, and analytics services. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Information.
  3. Professional Advisors, such as lawyers and accountants, where doing so is necessary to facilitate the services they render to us. 
  4. Business Transaction Recipients, such as counter parties and others assisting with a merger, acquisition, financing, reorganization, bankruptcy, receivership, dissolution, asset sale, or similar transaction, and with successors or affiliates as part of or following that transaction.
  5. Regulatory requirements, where required to comply with all laws and applicable regulatory requirements.

Spark Credit may disclose your Personal Information: (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations); (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding; (c) as otherwise required or permitted under any applicable law, rule, or regulation; and (d) in good faith, to protect or defend the rights or property of Spark Credit or a third party.

In the instances described above, we may be required to share your Personal Information with or without your consent. In limited circumstances, we may be legally prohibited from advising you that your information was shared in this way.

Personal Information Retention And Data Deletion

We keep Personal Information until:

  1. We no longer need it to satisfy the purposes described in this Privacy Policy; and 
  2. The information is no longer reasonably necessary to enforce, defend, or protect our, yours or a third party’s rights and no longer reasonably necessary to satisfy legal requirements. 
  3. In the case of CompareHub Users, until the User closes their account.

Users from Quebec can expect to have their data automatically eliminated from our servers after 12 months unless they are members of CompareHub. Users who have provided us with “express” marketing consent or who have subscribed to our email newsletters can expect to have their basic contact information stored by us for as long as their opt-in status remains unchanged.

Data managed by Spark Credit is stored on servers located in Montreal, Quebec and Toronto, Ontario. When a user submits a Service request, User data may be securely stored and hosted on servers managed by Zenutech/We Care Hosting Inc. and Digital Ocean Holdings, Inc. Email marketing data, including email link click or email open message metrics, is securely stored and managed by J2 Global Canada, Inc (Campaigner.com), while transactional email data may be temporarily and securely logged and tracked in servers owned or managed by MailerSend.com or MailGun.com.

If you wish to have us delete your data held on our servers, please contact us at the support contact information listed in this Privacy Policy.

If you have any questions or would like to contact our privacy officer please submit a privacy information request here or feel free to contact us at our designated request address: legal@loanscanada.ca.

Children

Our Service is not intended for children who are under the age of 18. Spark Credit does not knowingly collect Personal Information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to Spark Credit through the Service please contact us and we will endeavour to delete that information from our databases.

Job Applicants

When you apply for a job with Spark Credit, we collect the information that you provide in connection with your job application. This includes name, contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or provided during interviews (which may be recorded). This may also include demographic or diversity information that you voluntarily provide. We may also conduct background checks and receive related information.

We use applicants’ information to facilitate our recruitment activities and process employment applications, including evaluating candidates and monitoring recruitment statistics. If you are a successful applicate, we have a separate privacy policy for employees; however, as a general overview, we use successful applicants’ information to administer the employment relationship. We may also use and disclose applicants’ information (a) to improve our Website; (b) as otherwise necessary to comply with relevant laws; (c) to respond to subpoenas or warrants served on Spark Credit; and (d) to protect and defend the rights or property of Spark Credit or others.

Links To Other Websites

The Service may contain links to other websites not operated or controlled by Spark Credit, including social media services (“Third Party Websites”). The information that you share with Third Party Websites will be governed by the specific privacy policies and terms of service of the Third Party Websites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Websites directly for information on their privacy practices and policies. 

Data Security and Risk

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. In addition, our employees, service and technology partners, and other contractors or third-parties understand the importance of keeping your information private. All Spark Credit employees and contractors are expected to maintain the confidentiality of Personal Information.

However, no Internet or e-mail transmission is ever fully secure or error-free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Risks resulting from breaches depend on the nature of the information at issue and the circumstances around the breach. When third-party threat actors are involved, the risks increase and are varied including phishing attempts and identity theft. Please keep this in mind when disclosing any Personal Information to Spark Credit via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service or Third Party Websites. We encourage all individuals to provide only the information they are comfortable with providing a third-party, keep watch for communications that are suspicious, and report any suspicious activity to us as soon as possible.

Disclosure Of Personal Information Outside Canada

To the extent we transfer or disclose Personal Information to a third party outside Canada, your Personal Information may be subject to the laws of the foreign jurisdictions to which the data is processed or in which it is stored, including any law permitting or requiring disclosure of the information to the government, government agencies, courts, and law enforcement in that jurisdiction. We have undertaken due diligence and have taken appropriate safeguards to require that your Personal Information will remain protected and require our third-party service providers, and partners if applicable, to have appropriate safeguards as well. Where we transfer any Personal Information out of the jurisdiction where you live, including for one or more of the purposes as set out in this Privacy Policy, we will do so in accordance with the requirements of applicable data protection laws, including by entering into data transfer agreements with the recipient to ensure your Personal Information is accorded an adequate level of protection.

Your Choices

  1. Update or Correct Personal Information: You can contact us and request any updates or corrections needed to keep your Personal Information accurate, current, and complete. 
  2. Opt-Out of Marketing Communications: You may opt-out of marketing communications by following the unsubscribe instructions in any marketing email we send you. Please note, however, that you may continue to receive communications after opting out of marketing communications.
  3. Opting out of Information Handling Practices:  You may opt-out of those information handling practices set forth herein that are not reasonably necessary to achieve the purposes you’ve requested, subject to certain limitations.
  4. Limit Online Tracking: Here are some of the ways you can limit online tracking:
    • Block Cookies: Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Use the following links to learn more about how to control cookies and online tracking through your browser:
      1. FirefoxChromeMicrosoft EdgeSafari
  5. Limit the Use of Advertising ID: You may be able to limit use of your mobile device’s advertising ID for interest-based advertising purposes through your device’s settings.
  6. Use Privacy Plug-Ins or Browsers: You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy BadgerDuckDuckGoGhostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also install a browser add-on to opt-out of Google Analytics.
  7. Advertising Industry Opt-Outs: You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
    1. Digital Advertising Alliance 
    2. Network Advertising Initiative 
  8. Do Not Track: We currently do not respond to “Do Not Track” or similar signals.  Learn more about “Do Not Track” here.

Note that the above opt-out mechanisms are specific to the device or browser on which they are exercised. You will need to opt-out on every browser and device that you use to access the Website.

Governing Law

This Privacy Policy and all related matters shall be interpreted and construed in accordance with the laws of Canada.

Changes To Privacy Policy

The Service and our business may change from time to time. As a result, we may change this Privacy Policy at any time. Unless another type of notice is required by applicable law, we will post an updated version on this page indicating the effective date of the update at the top of this Privacy Policy. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

We encourage you to periodically review our Website for the latest information on our privacy practices. If at any point you do not agree with the terms of this Privacy Policy, you must not use the Website or our Services.

Contact, Complaints & Data Deletion Requests

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: legal@loanscanada.ca or by submitting a privacy information request here.