Paays Privacy Policy

Last update: January 31, 2022

This is the privacy policy (“Policy”) for Paays Financial Technologies Inc. (“Paays”, “we”, “us” or “our”). It outlines what personal information is collected by Paays, including from individuals who interact with the PreQ pre-qualification and PreQ ID Verifier applications (the “Apps”), and the PreQ website at www.PreQ.ai (the “Website”) (the Apps and Website referred to collectively as the “Platform”), how that information may be used, and with whom it may be shared.

By visiting the Platform or providing us with personal information you consent to Paays collecting, storing, using and disclosing your personal information in accordance with the terms of this Policy. Updates to the Policy will be posted on the Website.

The Paays Website is made available for, and intended for use by, Canadian residents only. If you are not a resident of Canada, you may not apply for Paays services.

If you do not agree with the terms of this Policy, do not access the Website or provide us with personal information. If you are under the age of majority in the province where you reside, you may not use the Platform or our services or submit personal information to Paays. By creating an Account you are consenting to and agree to be bound by the terms of this Policy.

1. Consent

By providing Paays with your personal information, you consent to the collection, use, disclosure and retention of that information by Paays in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to Paays, but then you might not be able to proceed with your intended interactions or transactions with Paays or otherwise receive the full benefit of Paays’s products and services.

2. Data Collected

Paays collects information about you as an identifiable individual (“Personal Information”) when you engage with the Platform.

Paays may also collect information about your interactions with us on the Platform, such as transactions on your Account.

Paays may also collect information from third party sources with your consent, such as credit reporting agencies and from other technology partners to verify the information provided by you.

3. Personal Information: Collection, Retention and Use

The type of Personal Information that Paays collects depends on the nature of your interaction with us but may include:your name, address, telephone number, and email address;Country of residence, whether your rent or own your home, household income, and employment statusVehicle information, which may include the vehicle you currently finance and/or vehicle that you are looking to purchaseA digital copy of your Canadian provincial or territorial driver’s license1Social Insurance Number (if you choose to provide it) and date of birthInformation about the products or service you are financing and your transactions made with merchants through the AccountCredit score and credit history provided by a credit bureau(Trans Union or Equifax)Social information (if you connect through Facebook or GooglePlus)

Personal Information is used by Paays to register you to receive information about the Paays Platform, process your application for a pre-qualification of a car loan, verify your identity and the information provided in your application and your current and ongoing creditworthiness, create, maintain, collect on and enforce your account, populate and maintain your profile, including your personal preferences, and provide information to you or otherwise communicate with you for each of these purposes.

Personal Information is also used by Paays for customer service and marketing purposes, including to let you know of new products and services, and notify you of any special offers. You may opt-out of email- based marketing communications at any time by sending an email with “Unsubscribe” to the email address provided in the marketing communication. You may opt-out of receiving special merchant offers in the Paays mobile app by disabling “Receive merchant offers” in the account profile menu of the Paays App.

To help establish your identity, Paays has partnered with Yoti Limited (Yoti USA Inc in the USA). When you submit your ID document, Yoti extracts data from it. If you are asked to submit a selfie then Yoti uses biometric technology to check that the selfie is of a real person and that your selfie matches the photo on the ID document. Yoti then sends us the results of the checks. Yoti does not do anything else with the data and Yoti deletes it after 7 days. The information provided to Paays by Yoti and other 3rd party data providers, is passed along to the Dealer Partner requesting the information (ID Verifier) or a Dealer Partner Paays has matched you with, based on the information you have provided us (PreQ).

4. Information Collected Automatically

When you visit or interact with the Website certain information is collected automatically through cookies or similarly purposed technologies, including technical and statistical information such as your IP address, your location based on your IP address, mobile device identifiers, operating system, and page views and duration.

This primary use of this information by Paays is to detect and reduce instances of fraud or organized DDOS attacks against the Platform. The information collected may also be used by Paays for its business operations and planning, including the operation and improvements to the Site and App, debugging, product research, evaluation and development.

This information may also be further used for online behavioural advertising, re-targeting, and custom audience type marketing.

5. Disclosure of your Information

PreQ pre-qualification: If you apply for pre-qualification of financing through PreQ, your Personal Information will be provided to specialized Paays service providers and Paays lending partners for the purposes of these partners evaluating and adjudicating your pre-qualification request, which may include verifying your identity, creditworthiness and the accuracy of the information provided on your application.

If Paays refers you to an independent business (ie, a car dealer or lender), for a proposed transaction (eg. Car loan), then Paays may provide a part of, or all, information collected to that independent business. Paays may also collect from that independent business information regarding the transaction to update your confidential profile for use by Paays as set out in this Privacy Policy.

Each service provider and lending partner is contractually bound with Paays to keep the information that it receives confidential. If you enter into a loan agreement with a lending partner, that lending partner’s privacy policy will govern how the lending partner processes your Personal Information.

PreQ ID Verifier: If you complete the PreQ ID Verifier process, a verification report is sent to the Dealer Partner who initiated the ID Verifier request, confirming the authenticity of your identity document(s) submitted. This report may contain a digital copy of your Driver’s License, along with other text-based identity information, extracted and verified by PreQ ID Verifier. This information is passed only to the Dealer Partner who initiated the request. The Dealer Partner may pass this information on to their Lender Partner(s) as part of a deal package submitted to Lender Partners, through one of the auto financing portals (DealerTrack or RouteOne).

Our employees, representatives and agents will have access to your Personal Information as necessary in connection with their responsibilities.

Paays may share your Personal Information with companies providing related services to Paays, such as data hosting and processing, analytics, marketing, identity verification. Some of these service providers may be located outside of Canada, including the United States.

Paays may share with any third party that it deems appropriate, aggregate anonymized information regarding the Platform and users of the Platform, such as demographic information about, and geographic territory of, end users (as a group), customer preferences (as a group), technical performance and usage statistics. These third parties may include, for example, business partners or companies who assist Paays in providing or supporting the Paays platform.

Paays may share Personal Information where permitted or required by law (including as required by foreign laws applicable to Paays service providers), if it believes it is required to do so in order to comply with an order of a court of competent jurisdiction or other legal requirements of any governmental authority, it if believes doing so would potentially mitigate its liability in an actual or potential lawsuit, if it believes it is necessary to protect its rights or property, or if Paays sells the Site or its business to a third party. Paays shares Personal Information with credit reporting agencies as necessary to maintain the integrity of the credit granting system.

6. Data Protection and Security

Paays takes your privacy and the protection of your Personal Information seriously and takes commercially reasonably measures to ensure its security. However, no transmission of Personal Information over the Internet can be guaranteed to be uninterrupted or completely secure, and accordingly Paays cannot, and does not, guarantee that your Personal Information will not be unlawfully accessed by a third party. PAAYS DOES NOT WARRANT THE SECURITY OF ANY INFORMATION YOU TRANSMIT ELECTRONICALLY, AND YOU DO SO AT YOUR OWN RISK.

7. Governing Law and Jurisdiction

Paays Financial Technologies Inc. is domiciled and provides its services in the Province of Ontario. Consumers from countries and jurisdictions outside of Canada are advised that this Policy, and the collection, retention, and use of your Personal Information, shall be construed in accordance with and governed by the laws of the Province of Ontario and the federal laws of Canada as applicable.

You are also advised that Personal Information is retained in cloud-based servers which may be located in Canada, the U.S.A. and other jurisdictions. The laws of these jurisdictions may offer less stringent privacy and consumer rights than the jurisdiction in which you reside.

8. Changes to this Policy

Paays may revise this Policy from time to time. The updated Policy will be published on the Platform, and identified by the publication date. Please review the Policy frequently during your use of the Platform and Paays services to ensure that you are aware of the most up to date Policy. Your continued use of the Site or the Paays Platform following the publication of an update to this Policy confirms your acceptance of the then updated Policy terms.

9. Opting out of Marketing Communications

To opt-out of marketing communications please send an email with “Unsubscribe” in the subject line to the email address provided in the communication. To opt-out of receiving special merchant offers in the Paays mobile app by disabling “Receive merchant offers” in the account profile menu of the Paays mobile app.

10. Your rights

If you have a Paays account in the App, you may close your account and withdraw your consent for the collection and use of your Personal Information at any time, subject to contractual and legal restrictions. Paays is unable to provide the Account services without your authorization to use your Personal Information in accordance with this Policy. You may close your Account from within the App (under “Settings”). You may also close your Account by sending an email to paayssupport@paays.com.

You have the right to request access to or correction of your Personal Information in our custody or control by writing to us at the email address below. We will take appropriate steps to verify your identity before providing access or making corrections.

11. Contact Paays

Should you have any questions regarding this Policy or the processing of your data, please contact Paays’s Chief Privacy Officer at Paays Financial Technologies Inc., 79 Glenview Avenue, Toronto, ON, M4R 1P7, us at paayssupport@paays.com.


1. Applies only to PreQ ID Verifier. Use of PreQ ID Verifier is through an integration with our verification partner Yoti. In addition to consenting to the Paays Privacy Policy, each user of PreQ ID Verifier also consents to Yoti’s Privacy Policy. Digital copies of Driver’s Licenses are stored on secure Yoti servers. Yoti is AICPA SOC2 and ISO 27001 Certified, and trusted by regulators for adhering to the highest standards of security.