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This Privacy Policy explains the collection, protection, use, sharing, disclosure and retention practices of ZetaTango Technology Inc. (“Ario”, “Ario Platform”, “ZetaTango”) in relation to the management of Personal Information for all of Ario’s products and services and our websites. By accessing or using the website www.arioplatform.com (“Site”, “portal”, “application”), you confirm that you have read, understood, and agree to the Terms of Use (the “Terms”) and this Privacy Policy. This Privacy Policy and the Terms constitute a binding legal agreement between you, Ario and its subsidiaries and affiliated companies.

  1. Definitions and Scope

This Privacy Policy applies to Personal Information that we collect from our partners and from you when you use our website or services and to Personal Information that we collect from third parties. This Privacy Policy does not apply to the practices of companies or other entities that we do not own or control, or to people that we do not employ or manage. Any Personal Information you supply, or authorize us to supply to any third parties, is governed by the privacy policies of those third parties.

For the purposes of this Privacy Policy, the following terms shall have the following meanings:

“Account” means the financial product or service (including loan, working capital advance, credit card, deposit account, line of credit) or other account opened by us, administered and/or serviced by Ario, and any other credit device issued by us in connection with your account.

“User Profile” means your verified online identity created from your Personal Information, records that reflect your business dealings with and through us, and your preferences and activities used to deliver a secure online experience that can be customized for you.

“Customer” means a prospective customer and/or customer of Ario who has applied for, or been issued, an Account which has been marketed using an Ario trademark or brand of Ario (either alone, or in conjunction with a Partner(s)).

“Partner” means a financial institution, business or organization that endorses a particular Ario product and/or service.

“Personal Information” means any information about an individual that allows that individual to be identified, including, but not limited to, your name, home address, date of birth, gender, contact information (such as mailing address, phone number(s), email), occupation, personal financial records (including, but not limited to, bank account information (including institution number, transit number and account number), income, assets, payment history, credit records, and other banking information), identification documentation (such as driver’s license, Social Insurance Number, passport), records that reflect your business dealings with and through us, and your preferences and activities.

“Account Holder” means the person that applied for the Account and in whose name we have opened the Account.

“Authorized User” means an individual whom you have requested to be added to your Account, including any guarantors, joint account holders, co-applicants, and personal or authorized representatives on your Account.

“We”, “us”, and “our” mean Ario and any of our agents, partners and service providers.

“Website” means www.arioplatform.com or any website owned and operated by Ario.

“You” and “your” means the person in whose name we have opened an Account and includes Authorized Users, as applicable, and any guarantors, or personal or authorized representatives on your Account.

We collect, use and disclose and share Personal Information only in accordance with this Privacy Policy.

  1. How we collect your information

We obtain most of our Personal Information about you directly from you when you use our website, products and/or services. The Personal Information we collect about you depends on which product or service you want. For every product or service, we need your name,

address, date of birth, email address, mobile phone number and identification information (such as driver’s license, provincial / territory ID card or passport). Your Personal Information helps us provide and improve upon the services we deliver to you. Here are the types of information that we gather about you:

Information Provided by You: We collect any Personal Information you give directly on forms when you register on the website or when you apply for a product or services, otherwise enter on our website, through correspondence or other communications, our interactions with you, or that you provide to us in any other way.

Information from Partners: We receive information about you from our Partners, including account information, transaction and credit history, contact information, and information about other products and services you may have with the Partner.

Information from Third Parties: We receive information about you through products and services you use from others with your consent (such as credit reporting agencies and other lenders), or other permitted sources.

Information from other People: We receive information about you from other people who oversee and/or share products and services with you.

Information from Publicly Available Sources: We combine your information with publicly available information (such as weather networks, land registers, internet, news, and social media).

Online Information: Our web servers automatically recognize, collect and retain information, such as the server your computer or mobile device is logged into, the domain of your internet service provider from which you access the Internet, location based information for logged in users, your browser type, the corresponding Internet Protocol (“IP”) address, and the names of the pages you visit while at our website. This information is not personally identifiable and is used to improve the content of our websites and make them more useful.

Email Addresses: We may ask you to provide us with your email address at several points, including online registration, applications for credit, correspondence or communications with you, and where it is required for us to provide the product and/or service.

Cookies: A cookie is a small amount of data that is stored by your web browser when you visit certain websites. Cookies may be used to track the activities of your browser as well as provide you with a consistent, more efficient experience.

Business Information: Information essential for fulfilling most financial requests and applications includes your business name, address, contact information, industry type, financial status and detail(s) on the owner(s), ownership structure, shareholder(s), officers and director(s).

  1. General Use

We use your Personal Information in connection with the provision of products and services from our website to:

  1. evaluate, monitor, maintain, service, and collect any application or account you may have with us, including disclosing or exchanging Personal Information with credit reporting agencies, to develop our relationship with you, and to offer financial products and services, including evaluating the needs, wants, and satisfaction levels of our customers and analyzing and managing our business;
  2. administer services, monitor your purchases, transactions, payments, and evaluate your credit eligibility, for the purposes set out in this Privacy Policy and the Terms;
  3. verify your identity (or that of any authorized user or co-applicant) concerning the account and maintain security measures aimed at the detection and prevention of fraudulent activity in relation to your account;
  4. promote and market products and services offered by Ario and our affiliates including products and services which are directly related to your account and including by means of direct marketing;
  5. to establish and maintain communications with you, and respond, report or discuss information in response to product and service inquiries or suggestions for improving our products and services;
  6. to meet legal and regulatory requirements; and
  7. for everyday business purposes, such as website management, research and product and service development.

  1. Sharing

We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy. Further, we share only the Personal Information we believe is needed to offer a product or service efficiently or to improve such product or service.

We may provide your Personal Information to our service providers who may be located outside Canada for adjudication purposes related to supporting our business (e.g., sending you emails, fulfillment services, technical support, data analytics and/or delivery services), including, without limitation, research and product and service development. These third parties are authorized to use your Personal Information only as necessary to provide these services to us.

We may also disclose your Personal Information:

  • with our affiliates, partners and related companies for the purpose of providing the goods and services requested by you;
  • with our affiliates, partners and related companies that agree to treat it in accordance with this Privacy Policy;
  • as required by law, rule or regulation, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, comply with a subpoena, bankruptcy proceedings, or similar legal process, or respond to a government request;
  • with third parties (who may be located outside of Canada) if Ario is involved in a merger, acquisition, or sale of all or a portion of its assets, in which case you will be notified via email and/or a prominent notice on our website of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information;
  • with partners when the goods or services rendered are transacted for the purpose of that partner;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud.

In addition, Ario may disclose anonymized and/or aggregated information which does not allow you to be personally identified to third parties.

Links to Other Websites or Social Media Features
Ario’s Site may contain links to other websites. This Privacy Policy does not apply to those websites. While exploring the services offered through Ario’s Site, please be aware that other online retailers, partners, third party Internet sites, and third party services accessible through Ario’s Site, have separate privacy and data collection policies and practices, which are independent of and may be different from Ario policies and practices. Ario is not responsible or liable for these independent policies and practices and it is your responsibility to review them and decide whether or not they satisfactorily protect your rights.

Our Site may also include Social Media Features, such as the Facebook button, and Widgets, such as the Share this button or interactive mini-programs that run on our website. These features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.

  1. How long we retain your information

The length of time we keep your information will vary depending on the product or service and the nature of the Personal Information. We have retention standards that meet customer, legal and regulatory requirements. For these reasons, we may keep your information beyond the end of your relationship with us. If you no longer wish to allow us to retain your information, you may withdraw your consent at any time by contacting privacy.officer@arioplatform.com.

When the information is no longer required, we securely destroy it or delete all personally identifiable information.

  1. Securing your information

We pay special attention to the protection of Personal Information and have therefore instituted industry standard security measures to protect users against any unauthorized access or disclosure. Although Ario strives to protect users’ Personal Information, it cannot guarantee the absolute security of such information as no system is immune from fraud or hacking. Neither Ario nor any of its officers, directors, employees, consultants, representatives, agents, successors and assigns may be held liable in case of theft, illegal use, unauthorized disclosure, loss or the alteration or destruction of information by a third party.

  1. Passwords

Where you use passwords, ID numbers, or other special access features it is your responsibility to safeguard them.

  1. Internet Security

Ario will not disclose or request sensitive information in an unencrypted email (for example, full account number, social insurance number, personal identification number (PIN), or security passwords).

If you receive an email purportedly from Ario containing or asking for this type of sensitive information, prior to responding, please contact our Privacy Officer at privacy.officer@arioplatform.com.

  1. Obtaining your consent

By using our website, you consent to let us collect, use, disclose and share your Personal Information as defined herein. We may seek your additional consent when you provide us with Personal Information in connection with your use of a product or service, a website, or when you approach us for information, inquire about, or apply for products or services from us. We will not make your consent a condition of obtaining a product or service, unless it is reasonably or legally required.

Submitting the Personal Information of others

When you submit the Personal Information of your customers or employees to us, you are responsible for informing such customers and employees about Ario, and for obtaining any necessary consent or authority from them.

  1. Withdrawing your consent

Certain consents are mandatory in order to use, or apply to use, our products and services. For example, a business loan account requires ongoing collection to obtain information relating to credit matters. This is to maintain the integrity of the credit granting process.

As your consent is essential to our ability to provide our products and services, all accounts will have to be in good standing before we can process a withdrawal of consent. Upon your withdrawal of consent, any outstanding debts you have on any accounts you may have with us will become due and payable immediately. Accounts in good standing will be closed and you will not be able to continue to use our products and services. If you refuse or withdraw your consent for any purpose required to provide one of our products or services to you, we will no longer be able to provide that product or service to you. To withdraw your consent, please contact our Privacy Officer at privacy.officer@arioplatform.com.

  1. Third Party Providers

Any service provider where Personal Information is provided to, shared with, or who stores or processes Personal Information on behalf of Ario, is reviewed to ensure their privacy policies align with ours and the requirements of PIPEDA or requirements applicable by law.

Some of these third parties, service providers, affiliates or related companies that may collect, use, store or process your information may be located outside of Canada, including in the United States. As a result, your Personal Information may be transferred, stored, and/or processed outside Canada in connection with the purposes described in this Privacy Policy. Contractual or other measures we may use to protect your Personal Information are subject to the legal requirements of the foreign jurisdictions where your Personal Information may be transferred, stored, or processed, (for example, lawful requirements to disclose Personal Information to government authorities in those countries).

  1. Links

Ario’s Site may contain links to other websites. This Privacy Policy does not apply to those websites. While exploring the services offered through Ario’s Site, please be aware that other online retailers, partners, third party Internet sites, and third party services accessible through Ario’s Site, have separate privacy and data collection policies and practices, which are independent of and may be different from Ario’s policies and practices.

Ario is not responsible or liable for these independent policies and practices and it is your responsibility to review them and decide whether or not they satisfactorily protect your rights.

  1. Use of E-mail Address

At the time of sign up, you have provided us with consent to send you electronic messages in compliance with Canada’s Anti-Spam Legislation. At any time, you can opt-out of commercial email communications from us by clicking on the unsubscribe link accessible in the footer of such emails. This consent includes permission for us to share your email

address with third parties under certain conditions. We do not share email addresses provided to us with other companies to market their products or services.

We use servers to deliver and report on the progress of email programs and to maintain service and fulfill products and services. When we use a service provider, we prohibit them from using your email address for any other purpose.

We will use the email address(es) you provided to present you with information about your account. This may include, but is not limited to, activating your account(s), account past due notices, available rates, and adding an authorized user.

We will track the activity of an email (for example, were graphics viewed, was the email opened, links clicked), to allow us to measure the effectiveness of the email, to provide future offers, and for fulfillment of products and services. Additionally, for your convenience, we may pre-fill online forms with your email address.

You may also choose to refer someone to our Site. We will send them a single invitation email to the address you provide. Please ensure that you only submit email addresses of individuals or businesses with whom you have a relationship and who would want to receive the message.

You are entitled to cancel this authorization at any time by contacting us at privacy.officer@arioplatform.com. However, such cancellation may result in the termination of goods and services with us and may require any outstanding amounts to become due and payable immediately upon the cancellation of your consent.

  1. Contacting us about your privacy

If you have any questions, comments or complaints regarding our treatment of your Personal Information, or if you wish to access your Personal Information or have it corrected, then please contact our privacy officer at: privacy.officer@arioplatform.com