Privacy Policy

---

This privacy policy (the “Privacy Policy”) governs the collection and use of information collected by Phoenix Management Group Ltd. (“Phoenix Management”, “we”, “our” or “us”) via our website (the “Site”), including the information provided by you when you create an account (your “Account”) with us on the Site and when you complete an application to be a borrower member (“Borrower”, “you” or “your”) in order to receive funds (a “Loan”) by way of a loan agreement (“Loan Agreement”) with Phoenix Management. This Privacy Policy provides you with details about the information we collect from you and how we use the information.

Please read this Privacy Policy carefully. By accessing the Site, you confirm that you have read, understand, and agree to this Privacy Policy and any subsequently modified Privacy Policy in its entirety. You understand and acknowledge we reserve the right to change or amend this Privacy Policy from time to time without notice. If you do not agree to this Privacy Policy in its entirety, you must not use the Site.

COLLECTION AND USE OF INFORMATION

When you access the Site, when you create, modify and use your Account, and when you submit or modify your application to be a Borrower or for a Loan, we collect information that is personally identifiable information or that is of a confidential nature (“Information”).

The Information you may supply to us includes:

· the name, address and other contact details of your business;

· details of registrations of your business (eg. HST number);

· data regarding the income, assets and debts of your business;

· information to enable automatic payments and transfers; and

· information regarding you as a guarantor of the business’ obligations to us (eg. name, mailing address, email address, social insurance number).

We will use the Information in order to determine your eligibility for a Loan, what terms the Loan will have, and in the administration of the Loan. In particular, Information will be used to:

· research your credit history, including obtaining credit reports about you from credit agencies;

· assign you a credit grade based on your credit history and financial circumstances;

· enable our financial service providers to implement automatic payments and fund transfers;

· contact you if there is a problem with a Loan Agreement or Loan;

· implement collection activities if required;

· maintain communications with you concerning your status as a Borrower, or your Loan Agreement or Loan.

We may use your Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the Opt-Out procedure described in this Privacy Policy below.

We also collect other information (that is not personally identifiable or confidential in nature) in order to improve the functionality of the Site and for marketing or promotional purposes.

We will retain your Information for as long as your Account with Phoenix Management is active or as needed to provide you services. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

INFORMATION COLLECTED USING COOKIES

Cookies are small files that a site or its service provider transfers to your web browser that enable these parties to recognize your browser and capture and remember certain information. We use cookies to understand how you use the Site so that the site can operate more effectively for you in the future. We may contract with Partners to assist us in better understanding the users of the Site. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of the elements of the Site may not function properly.

ACCESS TO INFORMATION

You can access and modify the Information about you associated with your Account by visiting the Site and following instruction with respect to safeguarding and updating Information.

SHARING INFORMATION

We work with our service partners (“Partners”) to operate the Site and provide our services. Information is shared with Partners only to the extent necessary for them to perform their respective functions. Our Partners are required to keep your Information private and secure, and not to disclose or use your Information for any other purpose.

We may share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling and other purposes.

SELLING INFORMATION

We will not sell or rent Information to any third party unless you have given us your consent, which may be withdrawn at any time.

TRANSFER OF INFORMATION

Information that we collect from our users, including Information, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are part of a transaction such as a merger, acquisition or asset sale, your Information may be disclosed or transferred to the third-party in connection with the transaction.

LEGAL AND COMPLIANCE

We reserve the right to disclose any information collected by us to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary: (i) to satisfy or comply with any applicable law, regulation or legal process or to respond to lawful requests; (ii) to protect our property, rights and safety and the rights, property and safety of third parties or the public in general; and (iii) to prevent or stop activity we consider to be illegal or unethical.

INFORMATION WE DISCLOSE WITH YOUR CONSENT OR AT YOUR REQUEST

We will share your Information with third-party sites or platforms if you have expressly requested that we do so.

SECURITY

Phoenix Management maintains an appropriate security program to protect information we collect from you, including Information, from unauthorized access, use or disclosure. However, we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

LINKS TO OTHER SITES

The Site may offer links to sites of Partners or other external websites. These external websites are not subject to this Privacy Policy and we have no control over the content or policies of these sites. Please carefully review the policies on these sites before providing them any information.

OPTING OUT

If you do not wish to receive promotional emails, newsletter notifications, or other communications from us, please follow the unsubscribe instructions provided in any of the communications. However, you can not opt out of certain communications regarding your Account, Loan agreement or Loan.

INTERNATIONAL TRANSFER

Your Information may be transferred to, and maintained on, computers located outside of your province, state, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside Canada and choose to provide your Information to us, we may transfer your Information to Canada and process it there. Your consent to this Privacy Policy followed by your submission of any Information represents your agreement to that transfer.

POLICY CHANGES

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, modify and revise this Privacy Policy from time to time. You should regularly review this page for the latest information on our privacy practices. If we make any material changes to this Privacy Policy, we may notify you of such changes by posting them on the Site or to your Account, or by sending you an email or other notification.

MISCELLANEOUS TERMS

When you contact us with a comment, question or complaint, you may be asked for information we need to help us answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service.

We may offer you the opportunity to participate in our customer research. The information obtained through our customer research is used to help us continue to provide excellent service to our Borrowers.

Please also review our Terms of Use which, among other matters, establish the use, disclaimers, and limitations of liability governing the use of the Site.

CONTACTING US

Please contact our Privacy Officer if:

· you have any questions or comments about this Privacy Policy,

· you wish to access, update, and/or correct inaccuracies in your Information, or

· you otherwise have a question or complaint about the manner in which we or our service providers treat your Information.