Privacy Policy

Privacy Policy

How FNi+ collects, uses, and protects your personal information under Canadian federal and provincial privacy legislation.

1. Introduction

FNi+ is a software-as-a-service platform provided to automobile dealerships (each, a "Dealership") by FNi+ Technologies Inc., or its successor in interest ("FNi+", "we", "us", or "our").

This Privacy Policy explains how we handle personal information collected through the FNi+ platform in respect of Dealership personnel using the platform, and in respect of when a Dealership invites you to complete a credit application or similar workflow. It applies to Dealership personnel (“Personnel”), and to vehicle buyers, co-applicants, and other individuals whose personal information is processed through the platform (each of them, an “Applicant”).

The Dealership is the organization accountable for the personal information collected through the platform under applicable privacy laws. FNi+ acts as a service provider and processor of personal information to the Dealership for the purposes of credit application processing, identity verification, and document handling.

2. Geographic Scope

The FNi+ platform is currently available to Dealerships located in the Canadian provinces of Alberta, British Columbia, Saskatchewan, Manitoba, Ontario, New Brunswick, Nova Scotia, Prince Edward Island, and Newfoundland and Labrador. The platform is not currently offered to Dealerships or buyers located in Quebec. FNi+ does not represent that the platform meets the requirements of An Act respecting the protection of personal information in the private sector (Quebec, "Law 25"). The platform should not be used for transactions involving Quebec residents or for credit applications completed at Quebec dealerships.

3. Information We Collect

Personnel: We collect the personal information of Personnel necessary to create, manage, secure, and administer Dealership user accounts and provide access to the platform. Categories include:

• Identity and business contact information: Name, business email address, business phone number, job title, Dealership, Organization, and Dealership location or rooftop.
• Account information: Username, user role, permission level, account status, subscription tier association, and administrator or authorized user designations.
• Authentication and security information: Login credentials, authentication tokens, PINs or access codes, IP address, device information, login history, session information, and security event logs.
• Platform usage information: Records of user activity within the platform, including dashboard access, application review activity, user support logs, document generation, electronic signature actions, account configuration changes, and other actions taken through the Dealership account.
• Billing and administrative information: Information relating to the Dealership’s subscription, billing contacts, payment administration, support requests, and communications with FNi+.

Applicants: We collect the personal information necessary to process an Applicant’s credit application and provide the related platform services. Categories include:

• Identity information: Full name, date of birth, marital status, and number of dependants.
• Contact information: Email address, phone number, and residential address.
• Financial information: Employment details, income, housing costs, banking information, and credit history disclosures.
• Sensitive identifiers: Social Insurance Number (SIN), collected solely for credit bureau submission by the Dealership and its lending partners.
• Vehicle and deal information: Vehicle details, deal type, trade-in information, and financing parameters.
• Electronic signature data: Signature image data, IP address, device information, and timestamps captured at the time of signing.
• Behavioural and analytics data: How you interact with the platform, including time spent on each section and product interest signals.

4. How We Use Your Information

We use your personal information for the following purposes:

• Account Administration: Creating, managing, securing, and maintaining Dealership user accounts, user roles, permissions, authentication, subscription access, and support communications.
• Credit application processing: Transmitting your credit application to the Dealership and, on the Dealership's instructions, to lenders and credit bureaus.
• Identity verification: Confirming your identity through SMS verification (PIN delivery) and email-based authentication.
• Dealership communication: Enabling the Dealership's finance team to review and act on your application.
• Service delivery: Providing platform features such as document storage, electronic signature capture, and dealer dashboard functionality.
• Fraud prevention: Detecting and preventing unauthorized access or fraudulent activity.
• Service improvement: Analyzing platform usage, completion patterns, and aggregated or de-identified analytics to maintain, troubleshoot, improve, and develop the platform.

5. Analytics and Platform Improvement

We collect limited information about how Applicants interact with the platform, including step completion timing, section views, scroll activity, time spent on each section, and product category interest selections. This information helps the Dealership prepare for follow-up discussions with Applicants and helps FNi+ maintain, troubleshoot, improve, and develop the platform.

Analytics information is used for operational and service improvement purposes only. It is not used to make, influence, or inform any credit, lending, insurance, or financing decision about an Applicant. FNi+ does not use an Applicant’s name, contact information, Social Insurance Number, banking information, income information, or other directly identifying credit application information for cross-Dealership analytics or model improvement.

Where analytics information is used to improve the platform across Dealerships, it is aggregated or de-identified before use. Aggregated or de-identified information does not identify an individual Applicant and is used to understand general platform usage patterns, completion rates, feature performance, and product category engagement.

Questions about the collection and use of analytics information, or requests to exercise privacy rights available under applicable privacy legislation, may be submitted to support@fniplus.ai.

6. Service Providers and Third Parties

We may share personal information with third-party service providers that help us operate, secure, support, and improve the platform. These service providers may include cloud hosting providers, database and file storage providers, authentication providers, SMS and email delivery providers, electronic signature and document generation providers, error monitoring and security providers, analytics providers, and payment processing providers for Dealership account billing.

We require our service providers to use personal information only for the purposes of providing services to us or the Dealership, and to protect personal information using appropriate contractual, technical, and organizational safeguards.

Where necessary to process a credit application or related workflow, personal information may also be shared with the Dealership, lenders, credit bureaus, financing partners, insurance or F&I product providers, and other parties involved in the vehicle purchase, financing, or related transaction. Those parties may collect, use, disclose, and retain personal information in accordance with their own privacy policies and legal obligations.

A current list of material service provider categories, including information about where personal information may be processed, is available upon written request to support@fniplus.ai.

7. Cross-Border Data Transfers

Your personal information is primarily stored in Canada. Limited processing occurs in the United States through the service providers listed in Section 6. By using the FNi+ platform, you consent to the transfer of certain personal information to the United States for these purposes.

We rely on contractual safeguards with each service provider to ensure that your personal information receives a comparable level of protection to that required under PIPEDA and applicable provincial privacy legislation, in line with the Office of the Privacy Commissioner of Canada's guidelines on transfers for processing.

8. Data Retention

We retain an Applicant’s personal information only for as long as necessary to provide the platform services, complete the purposes described in this Privacy Policy, comply with legal, regulatory, contractual, and audit obligations, resolve disputes, and enforce our agreements.

The following retention periods generally apply:

Requests for deletion of personal information may be submitted to support@fniplus.ai. Deletion requests will be reviewed in accordance with applicable privacy legislation; however, information may be retained where required or permitted by law, including for legal, regulatory, contractual, audit, security, fraud prevention, dispute resolution, or record-keeping purposes.

If your credit application has already been submitted to a Dealership, lender, credit bureau, financing partner, or other third party, those parties may retain your information in accordance with their own privacy policies and legal obligations.

If a Dealership changes or cancels its subscription, we may retain, export, or delete information associated with that Dealership account in accordance with our agreement with the Dealership, this Privacy Policy, and applicable law.

9. Your Rights

Subject to applicable privacy legislation, you have the following rights:

• Right of access: Request a copy of the personal information we hold about you.
• Right of correction: Request corrections to any inaccurate or incomplete personal information.
• Right to withdraw consent: Withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions.
• Right to deletion: Request the deletion of your personal information, subject to legal or regulatory retention obligations.
• Right to opt out of analytics: Opt out of cross-Dealership analytics use as described in Section 5.
• Questions or complaints: Submit inquiries or complaints regarding the handling of personal information.

Withdrawing consent or requesting deletion may limit our ability to provide platform services, process a credit application, verify identity, generate documents, or support related transactions.

If personal information has been submitted to a Dealership, lender, credit bureau, financing partner, insurer, F&I product provider, or other third party, those parties may retain and handle that information in accordance with their own privacy policies and legal obligations. Privacy rights requests or inquiries may be submitted to support@fniplus.ai.

10. Security Safeguards

We use reasonable physical, technical, and organizational safeguards designed to protect personal information against unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks.

These safeguards may include encryption of sensitive information, encryption in transit (HTTPS/TLS), access controls, user authentication, role-based permissions, session management, audit logging, security monitoring, multi-tenant data isolation, and administrative controls.

No system is completely secure. We cannot guarantee that personal information will never be accessed, used, or disclosed without authorization, but we take reasonable steps to protect personal information in a manner appropriate to its sensitivity. We review and update these safeguards on a regular basis.

11. Breach Notification

If we become aware of a breach of security safeguards involving personal information, we will take reasonable steps to assess, contain, investigate, and remediate the incident.

Where required by applicable privacy legislation, we will notify affected individuals, the Dealership, applicable privacy regulators, and any other parties required by law. Notices will be provided as soon as feasible or within the timeframe required by applicable law.

We will also maintain records of breaches of security safeguards where required by applicable privacy legislation.

12. Filing a Complaint

If you are not satisfied with our response to a privacy concern, you may file a complaint with the appropriate privacy commissioner:

• Federal: Office of the Privacy Commissioner of Canada (priv.gc.ca)
• Alberta: Office of the Information and Privacy Commissioner of Alberta (oipc.ab.ca)
• British Columbia: Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca)

To facilitate timely resolution, privacy concerns should be submitted to support@fniplus.ai in the first instance.

13. Children's Information

The FNi+ platform is not intended for use by individuals under the age of majority in their province or territory of residence. FNi+ does not knowingly collect personal information from individuals below this age. Where FNi+ becomes aware that personal information of an individual below the age of majority has been collected, FNi+ will take reasonable steps to delete such information, subject to applicable law. Privacy inquiries may be submitted to support@fniplus.ai.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in applicable law, our processing practices, or platform functionality. The "Last updated" date at the top of this policy reflects the most recent revision. Material changes will be communicated through the platform or directly to Dealership administrators.

15. Contact

Privacy inquiries

FNi+ Technologies Inc.

Email: support@fniplus.ai

We will acknowledge privacy inquiries and complaints within a reasonable time and will respond to formal requests to access, correct, or delete personal information within the timeframe required by applicable privacy legislation.