Terms

These terms and conditions outline the rules and regulations for the use of BoroMi's Website.  


By accessing this website we assume you accept these terms and conditions in full. Do not continue to use BoroMi's website
if you do not accept all of the terms and conditions stated on this page.
The following terminology applies to these Terms and Conditions, Privacy Statement and Disclaimer Notice
and any or all Agreements: "Client", "You" and "Your" refers to you, the person accessing this website
and accepting the Company's terms and conditions. "The Company", "Ourselves", "We", "Our" and "Us", refers
to our Company. "Party", "Parties", or "Us", refers to both the Client and ourselves, or either the Client
or ourselves. All terms refer to the offer, acceptance and consideration of payment necessary to undertake
the process of our assistance to the Client in the most appropriate manner, whether by formal meetings
of a fixed duration, or any other means, for the express purpose of meeting the Client's needs in respect
of provision of the Company's stated services/products, in accordance with and subject to, prevailing law
of . Any use of the above terminology or other words in the singular, plural,
capitalisation and/or he/she or they, are taken as interchangeable and therefore as referring to same.Cookies
We employ the use of cookies. By using BoroMi's website you consent to the use of cookies
in accordance with BoroMi's privacy policy.Most of the modern day interactive web sites
use cookies to enable us to retrieve user details for each visit. Cookies are used in some areas of our site
to enable the functionality of this area and ease of use for those people visiting. Some of our
affiliate / advertising partners may also use cookies.License
Unless otherwise stated, BoroMi and/or it's licensors own the intellectual property rights for
all material on BoroMi. All intellectual property rights are reserved. You may view and/or print
pages from http://www.boromi.ca for your own personal use subject to restrictions set in these terms and conditions.
You must not:

Republish material from http://www.boromi.ca
Sell, rent or sub-license material from http://www.boromi.ca
Reproduce, duplicate or copy material from http://www.boromi.ca

Redistribute content from BoroMi (unless content is specifically made for redistribution).
Hyperlinking to our Content

The following organizations may link to our Web site without prior written approval:

Government agencies;
Search engines;
News organizations;
Online directory distributors when they list us in the directory may link to our Web site in the same
manner as they hyperlink to the Web sites of other listed businesses; and
Systemwide Accredited Businesses except soliciting non-profit organizations, charity shopping malls,
and charity fundraising groups which may not hyperlink to our Web site.




These organizations may link to our home page, to publications or to other Web site information so long
as the link: (a) is not in any way misleading; (b) does not falsely imply sponsorship, endorsement or
approval of the linking party and its products or services; and (c) fits within the context of the linking
party's site.

We may consider and approve in our sole discretion other link requests from the following types of organizations:

commonly-known consumer and/or business information sources such as Chambers of Commerce, American
Automobile Association, AARP and Consumers Union;
dot.com community sites;
associations or other groups representing charities, including charity giving sites,
online directory distributors;
internet portals;
accounting, law and consulting firms whose primary clients are businesses; and
educational institutions and trade associations.



We will approve link requests from these organizations if we determine that: (a) the link would not reflect
unfavorably on us or our accredited businesses (for example, trade associations or other organizations
representing inherently suspect types of business, such as work-at-home opportunities, shall not be allowed
to link); (b)the organization does not have an unsatisfactory record with us; (c) the benefit to us from
the visibility associated with the hyperlink outweighs the absence of ; and (d) where the
link is in the context of general resource information or is otherwise consistent with editorial content
in a newsletter or similar product furthering the mission of the organization.

These organizations may link to our home page, to publications or to other Web site information so long as
the link: (a) is not in any way misleading; (b) does not falsely imply sponsorship, endorsement or approval
of the linking party and it products or services; and (c) fits within the context of the linking party's
site.

If you are among the organizations listed in paragraph 2 above and are interested in linking to our website,
you must notify us by sending an e-mail to admin@boromi.ca.
Please include your name, your organization name, contact information (such as a phone number and/or e-mail
address) as well as the URL of your site, a list of any URLs from which you intend to link to our Web site,
and a list of the URL(s) on our site to which you would like to link. Allow 2-3 weeks for a response.

Approved organizations may hyperlink to our Web site as follows:


By use of our corporate name; or
By use of the uniform resource locator (Web address) being linked to; or
By use of any other description of our Web site or material being linked to that makes sense within the
context and format of content on the linking party's site.

No use of BoroMi's logo or other artwork will be allowed for linking absent a trademark license
agreement.
Iframes
Without prior approval and express written permission, you may not create frames around our Web pages or
use other techniques that alter in any way the visual presentation or appearance of our Web site.
Reservation of Rights
We reserve the right at any time and in its sole discretion to request that you remove all links or any particular
link to our Web site. You agree to immediately remove all links to our Web site upon such request. We also
reserve the right to amend these terms and conditions and its linking policy at any time. By continuing
to link to our Web site, you agree to be bound to and abide by these linking terms and conditions.
Removal of links from our website
If you find any link on our Web site or any linked web site objectionable for any reason, you may contact
us about this. We will consider requests to remove links but will have no obligation to do so or to respond
directly to you.
Whilst we endeavour to ensure that the information on this website is correct, we do not warrant its completeness
or accuracy; nor do we commit to ensuring that the website remains available or that the material on the
website is kept up to date.
Content Liability
We shall have no responsibility or liability for any content appearing on your Web site. You agree to indemnify
and defend us against all claims arising out of or based upon your Website. No link(s) may appear on any
page on your Web site or within any context containing content or materials that may be interpreted as
libelous, obscene or criminal, or which infringes, otherwise violates, or advocates the infringement or
other violation of, any third party rights.
Disclaimer
To the maximum extent permitted by applicable law, we exclude all representations, warranties and conditions relating to our website and the use of this website (including, without limitation, any warranties implied by law in respect of satisfactory quality, fitness for purpose and/or the use of reasonable care and skill). Nothing in this disclaimer will:

limit or exclude our or your liability for death or personal injury resulting from negligence;
limit or exclude our or your liability for fraud or fraudulent misrepresentation;
limit any of our or your liabilities in any way that is not permitted under applicable law; or
exclude any of our or your liabilities that may not be excluded under applicable law.

The limitations and exclusions of liability set out in this Section and elsewhere in this disclaimer: (a)
are subject to the preceding paragraph; and (b) govern all liabilities arising under the disclaimer or
in relation to the subject matter of this disclaimer, including liabilities arising in contract, in tort
(including negligence) and for breach of statutory duty.
To the extent that the website and the information and services on the website are provided free of charge,
we will not be liable for any loss or damage of any nature.

PRIVACY POLICY

Latest Update: <@> June 2020

Hey there! If you’re looking for more information about how we handle your personal information, you’re at the right place!

We are BoroMI and this Privacy Policy covers:

Our mobile application and the services that we provide to you through our App to allow you to link your credit cards and repay your purchases over time, and the other services that we provide in relation to our App (our “App”);

Our website and our marketing activities (our “Website”);

Any communications you may have with us, through social media, e-mails or otherwise.

In this Privacy Policy, we will use the term “Services”to refer to all of the above indiscriminately. This Policy also explains how cookies and other tracking technologies are used on our Website (the “Cookies”).

When you use our Services, you may have access to websites, applications or services that are offered by other entities. Prior for accessing these third-party services, please make sure that you review their privacy policies and terms and conditions, as we don’t control how they handle your personal information. This includes our social medias and links to other websites.  This Privacy Policy does not cover these third-party services.

We only provide our Services for Canadians at the time, and we do not accept any foreign applications. Stay tune, we may make our Services available in your jurisdiction soon!

1. HOW CAN YOU CONTACT US?

If you have any questions, comments our concerns regarding this Privacy Policy, how we handle your personal information, or if you want to exercise your privacy rights, you can contact us by e-mail at: privacy@boromi.ca or by mail:

 

Privacy Officer

BoroMi Inc.

1 Yonge Street, Suite1801

Toronto, Ontario

M5E 1W7

Canada

 

2. DO WE PROCESS PERSONAL INFORMATION ABOUT MINORS?

No.While it’s important for people of all ages to get their finance right andreduce their interests over their loans, we do not allow anyone under the ageof 18 years old to use our Services. If we find out that you are not 18 yearsold or older, we may delete your accounts with us and block you from using ourServices until you are old enough.

 

3. WHAT DO WE MEAN BY “PERSONAL INFORMATION”?

Personal data means information that can directly or indirectly identify you, such as IP addresses, names, and financial information.

4. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU, AND WHY?

We collect your personal information to provide you with the Services, to market our Services, to respond to your support requests and inquiries, to provide you with a newsletter and for performance analytics. We do not collect mobile advertising IDs nor do we perform any targeted advertising based on your transaction history.

·      Registration Data and Credentials

When you register to use our App, we will ask you to provide your e-mail address, your full legal name, your date of birth and your full address. You will also be asked to create a password for your account. We also collect your consents to our terms and conditions and as required as part of the App.

·      Banking Information; Transaction Information

Once you have an account with us, you can link your bank account to our App by connecting in your bank account using your usual credentials. We don’t store your credentials, and we can’t see it. Your credentials are encrypted and stored by Plaid, our trusted service provider

Then, once you are signed up, you can connect your bank accounts to our App. Your credentials to your bank account are encrypted, and stored by Plaid, our trusted service providers. We have no access to it. We collect and use up to 12 months of your transaction history to look at your income and your cash flow. This helps us understand which transactions are eligible for a loan and determining if we provide the loan to you.

·      Credit History

In order to loan you money, we also need your credit history. If you consent, we will obtain your credit score from Equifax. In some cases, if they cannot find your credit history, we may need to ask for additional information or social insurance numbers.

·      Fraud Prevention, Know-Your-Customer Due Diligence

We use your Registration Data to conduct fraud prevention and due diligence, such as to validate your identity. We are required to do this because of applicable laws and to prevent money laundering.

·      Loan History; Payment History

Our App collects the amounts that are owed to us, how much interests is owed, the total monthly payment amount, the dates and frequencies of payments, the terms of your loans and the transactions that must be paid. You can pay your loan through e-transfer using a unique code that you use as password.  We collect any data you put in the e-transfer. We collect your credit card number to proceed to pay your debt to your credit card company once you obtain the loan.

·      Support andCommunication Data

If you have support inquiries for our App, you can contact us by e-mail or through our chatbot on our website. We collect any information you share with us for support purposes. When you use our chat, Drift, our service provider, installs a Cookie on your device to associate you with their profile in the Drift system.This allows Drift to remember the information that you have provided through the chat on subsequent visits.

If you inquire about our Services, if you fill a contact form on our website, interact with us on social media or whenever you exchange with us, we collect the personal data that you share with us. On social media, we will have access to your publicly available information when you interact with us. You can also comment on our publications through our Website, and if you choose to do so, then this information is collected through our Website.

·      Log Data

When you visit our Websites, your browser or device send data automatically, such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to help us improve our performance and understand better the traffic on our Website. This is collected anonymously through Cookies and is aggregated for us. We can’t see what you’re doing specifically when navigating our Website. When you use the App, we also collect certain information automatically, including the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, and your general location information.

·      MarketingCommunications

If you join our newsletters or mailing list, we can provide you with marketing information. You can unsubscribe at anytime through our e-mails, or by contacting us!

·      Direct Marketing

To commercialize our App, we may organize events and other types of direct marketing activities from time to time. If we need to disclose additional information as part of these activities, we will do so on a punctual manner.

5. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

We don’t sell your personal information to third parties. We disclose your personal information to service providers to deliver the Services and obtain performance analytics. In some cases, we may be required by law to disclose your personal information to law enforcement or government authorities, but if we do so, we ensure that the request is lawful and enforceable before doing so.We can also disclose your personal information if we sell our assets or part of them, in a merger or acquisition and similar corporate transactions or reorganization.

More precisely, we disclose your personal information to the following types of recipients:

·      Financial Partners

In order to provide you with a loan, we share some of your personal information with underwriters, such as your name, address, birth date, credit information and income. If you do not pay your loan, we may also provide this information to Equifax and/or collection agencies, and this may affect your credit score.

·      Financial Aggregators

Where possible, we obtain your personal information directly from your banking institution. If we don’t have a partnership with your banking institution, we use Plaid to collect your personal information from your bank account. Plaid isa data aggregator which uses data scrapping and API connection with your bank account to obtain your data through an encrypted channel

·      Analytic Partners

We use analytic partners such as Google Analytics to understand the performance of our services.

·      IT Service Providers

We use IT service providers to provide you with the Services, such as cloud hosting. We also work with Drift to provide you with online support through ourWebsite. You can read Drift’s Privacy Policy here. We use Mailchimp to send mass e-mails, you can read their Privacy Policy here.

·      Law Enforcement, Authorities

We may receive requests by authorities to access your personal information. We will validate that the request is licit before responding. When possible, we will advise you. We will only share what is strictly required.

In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of BoroMI, in whole or in part, your personal information may be transferred as part of the transaction.

6. WHERE WILL MY PERSONAL INFORMATION BE STORED?

We store your personal information in Canada, however, our service providers may store your personal information elsewhere, such as in the United States. Some countries may not offer the same level of protection than in Canada for personal information. We ensure that we have adequate contractual provisions in place with these service providers.

7. HOW DO YOU ENSURE MY PERSONAL INFORMATION IS SAFE?

We understand that sharing personal information with us requires trust, and for this reason, we strive to implement reasonable security safeguards given the sensitivity of the personal information that you share with us. We strive to pick suppliers that offer extensive evidences of security controls, such as certifications. However, keep in mind that it’s important that you do your part to protect your personal information, such as not using unsecured public WiFi when transmitting personal information.

We host your data with Google Cloud, which is certified under ISO/IEC 27001, SOC I Type II, and is compliance with the Personal Information Protection andElectronic Documents Act (“PIPEDA”), which is the federal legislation applicable to personal information in Canada. This white paper explains how Google Cloud complies with PIPEDA.

We use trusted suppliers to keep your data safe. Drift  has a SOC 2 Type II attestation, a reregistered with the Cloud Security Alliance and conduct vulnerability scanning and penetration testing. Our financial partner, Plaid, regularly undergoes both internal and external network penetration tests and third-party code reviews, maintains a SOC 2 Type II report and the Plaid API only allows client requests using strong TLS protocols and ciphers. Communication between Plaid infrastructure and financial institutions is transmitted over encrypted tunnels. All client communication with the Plaid API requires API key authentication and utilizes cryptographically hashed headers and timestamps to verify authenticity.

8. HOW LONG DO YOU KEEP MY PERSONAL DATA?

We keep your personal data as long as necessary (a) for the purposes of the collection or (b) as required under applicable laws, whichever is longer. We ensure that our partners have retention periods.

9. HOWCAN YOU CONTROL YOUR COOKIE PREFERENCES?

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Website and/or Services. Click on your browser for more information:

  • Google Chrome
     
  • You can also browse on Incognito Mode while using      Chrome.
  • Firefox
  • Safari
  • Internet Explorer
  • Opera
10. DO YOU HAVE ANY RIGHTS REGARDING YOUR PERSONAL DATA?

Yes! You have the right to access and correct your personal information. We offer functionalities within the App that allow you to update your personal information to ensure that they remain accurate – we suggest that you first explore these options as they are conveniently available to you! However, we are always happy to respond to your concerns, you can contact us at any time.We will respond to you within 30 days, and if we can’t accept your request, we will provide you with explanations. In some cases, we may need additional information to identify you, in which case, we will use this information only for this purpose.

While we encourage you to reach out directly to us if you are not satisfied with our privacy practices or how we handled your complaints, it is important to know that you can always lodge a complain to your local privacy authority. For instance, you can lodge a complain to the Office of the Privacy Commissioner ofCanada by following the steps set forth here and by using the Privacy Complaint Form.

 

11. CAN YOU OPT-OUT OF MARKETING COMMUNICATIONS?

Yes, you can do so directly in the e-mails you receive by clicking the “unsubscribe”link. You can also contact us directly.

12. CAN WE CHANGE THIS POLICY?

Yes. We need to update this Privacy Policy frequently to reflect our new functionalities, to respond to new legal requirements or to reflect new ways in which we collect, use or disclose personal information. You can see our latest update date above. In case of a change to this Privacy Policy, we will advise our App users by e-mail or through an in-App notification.