Policy on confidentiality and use of personal and business information

Date last modified: May 2021

This Privacy Policy describes how Matter Inc. and its subsidiaries and affiliates (“Matter, Strawhouse, Velocity, Uncoil, Afferent, cpgLAB” “we,” “us,” and/or “our”) handle personal data we collect online (through our websites) and offline (through customer support channels, our retail locations, and in-person promotional activities). We call all of these the “Services”. This Privacy Policy explains the types of personal data we collect and process, how we may use and share the data, and the choices that are available to you with respect to our handling of your personal data.

How we collect your personal information and your business information and what we do with it

Must I Read This?

Of course! This Policy on confidentiality and use of personal and business information describes how personal and business information is collected and processed by Matter in relation with its operating program and activities when:

  • You inquire about our services
  • You use our online services. For example, if:
    • You visit our website
    • You subscribe to our email publications
    • You login to our website and use our services
    • You apply for a job

However, this Policy on confidentiality and use of personal and business information does not apply to the collection and processing of Matter’s employees' personal information.

1. Our commitment to the confidentiality of your personal and business information

Because protecting your personal and business information is important to us, we at Matter have adopted strong principles in that respect.

  1. We don’t sell your personal or business information to anyone.
  2. We tell you why we use your personal or business information, and we don’t use it for anything else.
  3. We limit how much personal or business information we collect, use, communicate and store to what is necessary for our purposes.
  4. Sometimes, our service providers need access to your personal or business information. They are only allowed to use your personal and business information to provide services on our behalf or to process the information as per our instruction. The only exception is when they have a legal obligation to disclose your personal or business information to the authorities.
  5. We give you the option to control your personal and business information. For example, we offer you tips on how to control the personal and business information we collect. We also have a Privacy Group that responds to your privacy or confidentiality concerns, gives you access to your personal and business information and implements the corrections that you have requested, when appropriate.
  6. We may communicate your personal or business information to the authorities without your consent where permitted or required by law.

2. Types of information we collect

We may use the information we collect to deliver the products and services you request, to maintain and customize your account and our interactions with you (such as on our digital properties), and to provide, maintain and improve our Services.

2.1 Personal information

Personal information is information about an identifiable individual.

The personal information we collect includes:

  • Identification information: Like your name
  • Contact information: Like your phone numbers, personal address, email addresses
  • Interactions and preferences information: Like data that relates to your use of our products and services, data from your interactions with us, our website, our services
  • Education and employment information: Like résumé, level of education, employment, interview notes, remuneration, references
  • Website activities information: About your activities, if you are using or logging into your account with our website

2.2 Data considered to be personal information

We collect information about how you use our website. Even though this information is not linked to your identity, it can be in certain circumstances by using cookies. This is why we consider this data to be personal information as well when linked to your identity. The data we collect includes:

  • The pages of our website viewed
  • The date and time when those pages were viewed
  • The region where you are connecting from (geolocation)
  • How long each page was viewed
  • The web browser used (Chrome, Edge, Firefox, Internet Explorer, Opera, etc.), browser settings and the type of device used (Mac or PC, mobile or desktop, etc.), AdWords used and references from which websites, applications or social media you come from before your visit

2.3 Business information

Business information is information about your business.

The business information we collect may include:

  • Identification information: Like name and trade name of your business,
  • Contact information: Like positions, names, titles, business addresses, business phone numbers and business email addresses
  • Interactions and preferences information: Like data which relates to the use by your business of our products and services, data from your interactions with us, our website, our services

3. When and how we collect your personal and business information

3.1 We collect personal or business information when you give it to us directly

For example:

  • When you apply for a job (only personal information)
  • When you fill in an online form
  • When you subscribe to one of our email publications
  • Whenever you use online tools and give information about yourself or your business

3.2 We also collect personal or business information obtained from sources other than yourself

For example:

  • From our service providers for web analytics or ads
  • From websites/social media pages containing information made public by you or your business
  • From data services or databases made publicly available by third parties or that we have an agreement with

3.3 When you are logged in to your Account we record your activities

We keep an electronic log of your activities so that we can detect and review any suspicious activity on your account or interact with you.

3.4 When you browse our website, we use cookies that track your activities

How we track your activities

When you browse our website, we track your activities to infer your interests based on pages you have visited. We may match this information to your account as soon as you identify yourself on our website by using cookies. We may do so to know what your interests are, to promote our products and services to you or your business, and to offer you or your business products or services that are more relevant to you or your business.

What cookies are and what we can do with them

Cookies are files that a website automatically creates and stores on your computer to collect information on your web browsing activities. We use first-party cookies to improve your user experience (most websites do).

Our website creates first-party cookies that allow us to:

  • Recognize you the next time you visit our website
  • Personalize our website, application, email publications and emails for you or your business

For example, we can know if you have already completed a survey so we do not ask you to do it again. These cookies are called persistent cookies because they stay in your browser after you have closed your session.

We also use Google Ads, DoubleClick and other third-party cookies for marketing purposes. With cookies, we can:

  • Automatically create lists about our users' interests based on pages they have visited, not only within the Matter website but also with other websites
  • Use this information to target users with specific ads
  • Analyze how well our ads perform for a specific audience

For example, if you visit a page about business loans, an alphanumeric code that identifies you will be added to a list of users who are interested in marketing solutions. This code will also be stored in a cookie on your computer. As a result, you may see a Matter ad about marketing solutions on a different website.

You can disable cookies

You can disable cookies in your browser’s settings. You will still be able to access our website, although some features may not work optimally.

3.5 We use Google Analytics to collect data about how you use our website (web analytics)

We use Google Analytics to analyze how users utilize our website.

Google Analytics makes your data anonymous by removing part of your IP address.

Google Analytics relies on cookies to collect information. Cookies used by Google Analytics will expire two years after your last visit to our website. For more information, consult the Google Analytics website and its privacy policy.

You can opt-out of Google Analytics by installing this add-on on your browser.

3.6 This policy does not cover personal or business information you or your business give to social media companies or online payment providers

When you interact with us through social media, for example on our Facebook page, you give information to social media companies and not to us. This information is covered by their own privacy policy. Keep in mind that the information you publish on social media can be made public.

When you pay online for our services, you give your payment information to an online payment provider. This information is processed by the online payment provider and it is covered by its own privacy policy.

4. Why we collect and use your personal or business information

We only collect your personal or business information if it relates directly to operating programs or Matter’s activities and for the following purposes:

4.1 For business purposes

  • We use your personal or business information to identify you or your business
  • Create and manage your online accounts and profiles
  • To register you, notably for an event
  • Complete the transactions you request, perform our contractual obligations, and use as otherwise anticipated within the context of our ongoing business relationship;
  • Respond to your requests, inquiries, comments, and suggestions;
  • Facilitate your engagement with the Services, including to enable you to post comments and reviews, to engage with other customers, and to post on social media;
  • Offer contests, sweepstakes, loyalty programs or other promotions;
  • Carry out short-term activities and other internal uses related to the products or services you purchase from us or your ongoing relationship with us;
  • Detect, investigate, and respond to security incidents and protect against illegal or objectionable activities, including the unauthorized use of the Services, and protect the rights and property of Matter and others;
  • Debug, identify and repair errors that impair existing intended functionality of our Services;
  • Conduct or administer surveys and other market research.

We use your personal or business information to communicate with you and to answer your questions.

  • To determine if you or your business are eligible for specific services.
  • When you request a specific service from Matter or if an offer could be available, we use your personal and business information as part of our due diligence to determine if you or your business meet the conditions to receive the loan or service you or your business have applied for or requested. This may include the validation of the details you directly disclose, which may include your identity, your business assets and liabilities, and other financial information.
  • We use your personal or business information to decide if your business is eligible for a service and, thereafter, to manage the service until it is completed.
  • To get deeper knowledge, make predictions, or generate recommendations through advanced analytics.
  • We use your personal or business information to perform advanced analytics. We examine this information using sophisticated techniques and tools to get deeper knowledge, make predictions, or generate recommendations.

We may use your personal or business information to help develop new products and services.

  • We use your personal and business information to develop new tools and models, so that Matter can improve its operating programs or activities for the benefit of its client.
  • To advise you or your business when you or your business request our products or services and to improve your experience.
  • We use your personal or business information to provide tailored advice and direct you towards the most appropriate resources, products and services upon request. This way, we make sure our advice, resources, products and services are best suited to you or your business profile.
  • To protect you and us against errors or fraud.
  • If you use a client login, we keep a log of all your activities. This allows us to detect suspicious activity on your account.

4.2 For web analytics purposes

To analyze how you use our website and improve your experience

We collect and analyze data about web traffic and visits to our website. This is called web analytics. Web analytics allow us to:

  • Understand how users utilize our website
  • Improve our website
  • Further develop our business and operations
  • Monitor, audit and analyze trends, usage, and activities in connection with our Services

4.3 For marketing purposes

To promote our products and services to you

We may send you promotional emails only if you have specifically agreed to receive them. For example, if you have subscribed to one of our newsletters.

Whenever you have specifically given your consent, you can revoke your consent at any time. For example, you can always opt-out of one of our newsletters.

To offer you products and services that meet your needs

  • To offer you or your business personalized advice and marketing opportunities, such as personalizing your online experience and the advertisements you see when you use the Services or third-party platforms based on your preferences, interests, purchasing history and browsing behaviour.
  • To communicate with you or your business about our Services, including to tell you about products and services that may be of interest to you.
  • We may use third-party Service providers to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC. For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/
  • We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve Our Service, products, services, marketing and Your experience.

4.4 For hiring purposes (only personal information)

To allow you to apply for jobs

We use your personal information to evaluate your job application and to contact you if needed.

5. How we store your personal and business information

5.1 Where we store it

Your personal or business information can be stored outside Canada because we use third-party service providers to store and process your personal or business information.

5.2 How we keep it secure

We take stringent measures to ensure that your personal and business information is protected and handled properly.

5.3 How long we store it for

We do not store your personal or business information forever. Hence, we will destroy, erase or dispose of your personal and business information in accordance with Matter’s retention period that complies with the Privacy Act and banking industry requirements.

6. To whom we communicate your personal or business information

6.1 Our employees or representatives may view your personal or business information on a need-to-know basis

Our employees or representatives may view your personal or business information for their work for Matter’s programs and activities.

They will not view your personal information for any other reason.

6.3 Our service providers may process your personal or business information

Our service providers may need to access or process your personal or business information. They are not authorized to disclose your personal or business information for any reason other than providing the services we ask from them, or if they have a legal obligation to do so.

We obtain the following services from our service providers:

  • Conducting analytics
  • Processing your payments
  • Advertising our products and services
  • Managing email delivery
  • Distributing useful content
  • Performing legal services

Some of our service providers are based outside Canada and some in the United States. They may store or process your personal and business information on our behalf. For instance, under the USA Patriot Act, they might be forced to disclose your personal or business information to U.S. authorities if they suspect that it is linked to terrorism or money laundering activities.

6.4 We may share your personal or business information in cases of fraud, suspected fraud

We may share your personal or business information with authorities in case of fraud or suspected fraud.

6.5 We may communicate your personal or business information in certain circumstances

In exceptional cases, we may communicate your personal or business information to others without your consent:

  1. If we are legally required to do so. For example, if we receive a court order to communicate your personal or business information.
  2. If it is impossible to get your consent and privacy laws allow us to communicate your personal information. For example, if it is necessary for the protection of public interest or to collect money you owe us (overdue accounts).

7. Things you can do to control how we process your personal and business information

7.1 You can access your personal or business information and ask us to correct any error

You can access your personal information at any time

To do so, please contact our Privacy Team at privacy@mttr.ca.

You can ask us to correct any error or omission

You can ask us to make corrections to personal or business information that we have that is not accurate. If we do not make these corrections, you can ask us to add annotations to your personal information to explain why certain corrections you asked were not made. Finally, you can ask us to notify certain persons about these corrections or annotations. To do so, please contact our Privacy Team at privacy@mttr.ca.

7.2 You can express your privacy concerns and file a complaint

You can express your privacy concerns by calling us or writing to us.

To do so, please contact our Privacy Team. To file a privacy complaint, you must send an email to our privacy team at privacy@mttr.ca. This ensures that we keep a record of your complaint. Our Privacy Team will respond to you as soon as possible.

Note that your complaint must be about your privacy or about how we deal with your personal information.

If you are not satisfied with how we respond to your complaint, you can contact the Office of the Privacy Commissioner of Canada.

8. European Residents

If you are a European Resident, defined for the purposes of this Privacy Policy to include residents of the European Economic Area, United Kingdom and Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.

8.1 Legal Basis for Processing

If you are a European Resident, we process your personal data when:

  1. We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the Matter products you have ordered).
  2. We have a legitimate interest in processing your personal data. For example, we may process your personal data for performance marketing activities, to conduct data analytics and to provide, secure, and improve our Services.
  3. We need to do so to comply with a legal obligation to which we are subject.
  4. We need to do so to protect your vital interests or those of others.
  5. We have your consent to do so, which you may withdraw at any time.

8.2 Data Subject Requests

If you are a European Resident, you have the right to access personal data we hold about you and to ask that your personal data be corrected, updated, or erased. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below. If you have a Matter account, you may also review, update, and delete certain personal data by logging into your account.

8.3 Questions or Complaints

If you are a European Resident and have a concern about how we process personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you live.

9. California Privacy Rights

California law permits residents of California to request notice of how their information is shared with third parties for direct marketing purposes or to opt-out of such sharing. If you are a California resident and would like a copy of this notice or to opt-out, please email us at privacy@mttr.ca

Additionally, if you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to disclose the following information with respect to our collection, use, and disclosure of personal data.

9.1 Categories of Personal Data Collected

In the preceding 12 months, we have collected the following categories of personal data: identifiers; commercial information; demographic information (note that some demographic information may be considered characteristics of protected classifications under state or federal law); internet or electronic network activity; geolocation data; audio, electronic, visual, thermal, olfactory, or similar information; inferences; and other categories of personal data that relates to or is reasonably capable of being associated with you. For examples of the precise data points we collect, please see “Information We Collect” above.

9.2 Business or Commercial Purpose for Collecting and Using Data

We collect each category of personal data listed above for the business or commercial purposes described in the “How We Use Your Information” section above.

9.3 Categories of Sources of Personal Data

We collect each category of personal data listed above from you and the third-party sources described in the “Information we collect from other sources” section above.

9.4 Categories of Personal Data Disclosed

In the preceding 12 months, we have disclosed the following categories of personal data for business or commercial purposes: identifiers; commercial information; demographic information (note that some demographic information may be considered characteristics of protected classifications under state or federal law); internet and electronic network activity; geolocation data; audio, electronic, visual, thermal, olfactory or similar information; inferences; and other categories of personal data that relates to or is reasonably capable of being associated with you.

9.5 Categories of Third Parties With Whom We Share Personal Data

We may share each category of personal data listed above with the third parties as described in the “How We Share Your Information” section above.

9.6 Your Consumer Rights

California consumers have the right to request access to their personal data, additional details about our information practices and deletion of their personal data (subject to certain exceptions). California consumers also have the right to opt out of sales of personal data, if applicable. We describe how California consumers can exercise their rights under the CCPA below. Please note that you may designate an authorized agent to exercise these rights on your behalf by providing a notarized power of attorney evidencing that you have empowered the authorized agent to exercise your CCPA rights on your behalf. We will not discriminate against you if you choose to exercise your rights under the CCPA.

9.7 Right to Know

You may request access to the specific pieces of personal information we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected, the sources of collection, the purpose for collecting information, the categories of information we share, and the categories of third parties with whom we share information.

9.8 Deletion

You may request that we delete the personal data we have collected about you (subject to certain exceptions). Please note that we may retain certain information as required or permitted by applicable law. You may make these requests by emailing privacy@mttr.ca. We will verify your request by contacting you after receiving your request to verify your identity. If you request to delete your personal data, certain of our products and services may no longer be available to you.

9.9 No Sale of Personal Data

Matter does not and will not sell personal data as the term “sell” is defined by the CCPA.

10. Additional Information

We did our best to make this policy as easy to read and understand as possible. Here are a few more things you should know:

10.1 We may change this policy at any time

Because privacy concerns, business and legal requirements continually evolve, we may need to change this policy in the future. We will provide notice of material changes to this policy by posting a notice on our website explaining that the privacy policy has been updated. What if the policy has changed?

If this policy has changed, you will be governed by the updated version of the policy.

10.2 How to read and interpret this Policy on confidentiality and use of personal and business information

This policy is governed by the laws of British Columbia and Canada. This policy complies with the Privacy Act of Canada.

10.3 Did you understand everything? Contact us with any question

Feel free to contact us:

  • For questions or comments about this policy
  • For more information about how we deal with your personal information
  • To access or modify your personal information

Here is how you can contact us:

  • Email Us at privacy@mttr.ca

  • Call or text us at (778) 699-2161

  • Mail us a letter:

      Matter

      Attention: Privacy Team

      Suite 412, 9-3151 Lakeshore Road

      Kelowna BC V1W 3S9

      Canada