Privacy Policy

This privacy policy (the “Policy”) was last amended on November 2, 2026.

WE INVITE YOU TO READ THE POLICY CAREFULLY BEFORE USING OUR WEBSITE OR SUBMITTING A FINANCING APPLICATION THROUGH THE FINX SOFTWARE.

1. INTRODUCTION AND CONTEXT

At Flovver, we respect your right to privacy and to the confidentiality of your Personal Information. We undertake to collect, use, disclose, retain and destroy it in accordance with Applicable Laws and best practices for the protection of Personal Information.

1.1 About Flovver

We have developed and market technological solutions for businesses wishing to manage their financing activities. To this end, we provide our Clients, among other things, with the FinX Software, a platform that allows them to collect, consolidate, compile and use the Personal Information necessary to process your financing application. The FinX Software allows them to generate the required forms, contracts and other documents, keep track of your financing file and automate certain related operations.

When a financing application is submitted through the FinX Software used by one of our Clients, Flovver processes Personal Information to provide the Client with the functionalities necessary to manage that application. However, our Clients remain responsible for processing your financing application. As such, they are responsible for obtaining the consents required to collect, use and disclose your Personal Information in the course of their own activities.

1.2 Personal information agent

When a financing application is submitted through the FinX Software used by one of our Clients, Flovver also acts as a personal information agent within the meaning of the Act respecting the protection of personal information in the private sector, for its own credit bureau activities.

When you submit a financing application and accept the consent declaration, after having had the opportunity to review the Privacy Policy, you authorize Flovver to use the Personal Information collected in connection with your application to:

This consent applies whether your initial application is accepted or refused.

TO LEARN MORE ABOUT THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION BY FLOVVER AS A PERSONAL INFORMATION AGENT, SEE SECTION 6 AND THE FOLLOWING SECTIONS OF THIS POLICY.

2. THE POLICY

The Policy is governed by Applicable Laws. The following sections specify which Personal Information is collected in each context, and how and why it is collected. To find the information that concerns you, see:

3. DEFINITIONS

For the purposes of this Policy, the following terms have the meanings assigned to them below:

3.1 Applicable Laws: all laws, regulations and other legal requirements applicable to Flovver’s activities, including Québec and Canadian laws concerning the protection of Personal Information and respect for privacy, including the Charter of human rights and freedoms, the Civil Code of Québec, the Act respecting the protection of personal information in the private sector and the Personal Information Protection and Electronic Documents Act.

3.2 Personal Information: as defined in the Act respecting the protection of personal information in the private sector, any information which relates to a natural person and directly or indirectly allows that person to be identified.

3.3 Personal Information Agent: means, as defined in the Act respecting the protection of personal information in the private sector, any person who, personally or through a representative, carries on a business that involves creating files about other persons and preparing and disclosing to third parties credit reports concerning the character, reputation or solvency of the persons concerned by those files.

3.4 Client: means any person who, under an agreement entered into with Flovver, uses the FinX Software, engages Flovver’s credit bureau services, or benefits from both services.

4. WEBSITE, ELECTRONIC COMMUNICATIONS AND DEMONSTRATION REQUESTS

4.1 How is your Personal Information collected?

We collect your Personal Information when you:

4.2 What Personal Information is collected?

Depending on your use of our website or the nature of your communications with us, we may collect, among other things, the following Personal Information:

4.3 Why is your Personal Information collected?

When you visit our website or contact us, we may use your Personal Information to:

5. FINANCING APPLICATION THROUGH THE FINX SOFTWARE

5.1 How is your Personal Information collected?

When you submit a financing application to one of our Clients or send supporting documents through the FinX Software, we collect Personal Information:

5.2 What Personal Information is collected?

When you submit a financing application through the FinX Software used by one of our Clients, we may collect or process the Personal Information necessary to process your application, including:

5.3 Why is your Personal Information collected?

When you submit a financing application through the FinX Software, your Personal Information may be used to:

When processing a financing application, certain functionalities of the FinX Software may automate certain processing steps or facilitate the analysis of your Personal Information. However, the decision to grant or refuse financing rests with the Client using the FinX Software, rather than Flovver.

6. PERSONAL INFORMATION AGENT — CREDIT BUREAU SERVICES

6.1 How do we collect your Personal Information and what information is collected?

When you submit a financing application through the FinX Software used by one of our Clients and accept the consent declaration, after having had the opportunity to review this Policy, Flovver also acts as a personal information agent. In this capacity, we collect Personal Information to create credit files and keep them up to date. This information may therefore be collected:

The information collected includes, notably:

6.2 Why is your Personal Information collected?

As a personal information agent, we may use your Personal Information to:

6.3 Automated decisions

We plan to offer a tool that uses artificial intelligence to analyze your banking data, categorize your transactions, generate financial indicators and establish a risk score. Our Clients may use these analyses to assess your financial situation and solvency in connection with a financing application.

If a decision concerning you is based exclusively on automated processing of your Personal Information, you will be informed no later than when that decision is communicated to you.

You may then request information about the Personal Information used, as well as the reasons and the principal factors and parameters that led to that decision. You may also request that the information used be rectified and submit your observations to a staff member of the Client or Flovver who is able to review the decision concerning your financing application. Your other rights regarding your Personal Information are set out in Section 11 of this Policy.

6.4 Updating, accessing and rectifying Personal Information

The Personal Information contained in your file is updated with each new loan application, based on the information collected at that time. We provide you with a portal where you can log in to view all the Personal Information we hold about you.

To update or correct the Personal Information provided as part of your financing application, we encourage you to contact your lender first. You may also submit a rectification request directly to our Privacy Officer, in accordance with the procedures set out in Article 11 of this Policy.

Only our authorized Clients, meaning those who have signed an agreement with us governing access to and use of credit files, may obtain reports concerning your solvency by submitting a request through the FinX Software.

7. DISCLOSURE OF YOUR PERSONAL INFORMATION

Depending on the context, your Personal Information may be disclosed to the following categories of persons or organizations.

7.1 Our service providers

We may disclose your Personal Information to service providers who assist us in providing our services or operating our business.

We require these providers to protect the confidentiality of your Personal Information and to undertake to:

Notably, we use the following categories of service providers: hosting and information technology services, security, operations management and support, communications and marketing, identity verification, banking data verification and analysis, payment processing, and debt collection.

7.2 Our Clients

When you submit a financing application through the FinX Software, the Personal Information you provide is disclosed to our Client so that it can process your application and provide the services you have requested.

We may also disclose credit reports prepared from the files we create about you to Clients who engage the services we provide as a personal information agent. These reports contain Personal Information about you and allow Clients, in particular, to assess your solvency in connection with a financing application.

7.3 Legal and security obligations

We may disclose your Personal Information when a law, regulation, court order or competent authority requires or authorizes us to do so and it is necessary to:

7.4 Business transaction

In connection with a business transaction, such as a merger, acquisition, reorganization or sale of all or part of our business, we may disclose to the other party the Personal Information necessary to conclude that transaction, under the conditions set out in Applicable Laws.

Before making this disclosure, we enter into an agreement requiring the other party to:

After the transaction is concluded, the other party may continue to use or disclose your Personal Information only in accordance with Applicable Laws. If it wishes to do so, it must inform you, within a reasonable time, that it now holds that information as a result of the transaction.

7.5 Disclosure outside Québec

Some of our service providers or partners may be located outside Québec.

When your Personal Information must be disclosed outside Québec, we conduct a privacy impact assessment to ensure that the disclosure is made in accordance with Applicable Laws and that appropriate safeguards are put in place before it takes place.

8. RETENTION OF YOUR PERSONAL INFORMATION

We retain your Personal Information only for the time necessary to achieve the purposes for which it was collected, comply with our legal and regulatory obligations or exercise or defend our rights.

When your Personal Information is no longer necessary for the purposes for which it was collected and its retention is no longer required, we securely destroy it or anonymize it, in accordance with Applicable Laws.

In our capacity as a personal information agent, we also destroy any Personal Information collected more than seven (7) years ago, in accordance with Applicable Laws, unless an exception provided for in those laws applies.

9. PROTECTION OF YOUR PERSONAL INFORMATION AT FLOVVER

The protection of Personal Information is an integral part of how we design, develop and operate our products and services. Personal Information is protected according to its nature, sensitivity and the risks associated with its processing. Access to this information is granted only to authorized persons who need it to perform their duties.

We have implemented internal policies, procedures and security measures intended to protect your Personal Information throughout its life cycle and ensure that it is processed in accordance with Applicable Laws, including:

10. COOKIES AND PROFILING TECHNOLOGIES

10.1 Cookies

Our website may use cookies and other similar technologies to improve your browsing experience, ensure the proper functioning of the site and better understand how it is used.

Cookies are small files stored on your device when you visit a website. They allow, among other things, your browser to be recognized, certain preferences to be remembered and information about your use of the site to be collected (e.g., IP address, pages viewed, date and time of visits, browsing path, visit source or referrer, interactions with content, browser type, device type and operating system, cookie identifiers, and analytics data such as sessions, visits and bounce rates).

Except for cookies necessary for our website to function, you may accept, refuse or change your cookie preferences through our consent management tool or your browser settings, where that option is available. Refusing certain cookies may, however, limit access to certain functionalities of our website or reduce its performance.

10.2 Profiling technologies

When we use technologies with functions that allow you to be identified, located or profiled, those functions are disabled by default and are activated only with your consent. In the course of our personal information agent activities described in Section 6, profiling is intended, in particular, to analyze your financial situation and solvency. You activate these functions by checking the consent declaration presented when you submit your financing application, after having had the opportunity to review this Policy.

11. YOUR RIGHTS

Subject to the conditions and exceptions set out in Applicable Laws, you may exercise certain rights regarding your Personal Information.

You may, in particular:

Withdrawing your consent may, however, prevent us from providing you with certain products, services or functionalities.

When you take out a loan with one of our Clients, you have access to a portal where you can log in to view the Personal Information we hold about you.

11.1 Contacting our person in charge of the protection of Personal Information

To have other information rectified, exercise any of your rights or share questions or concerns with us, you may contact our person in charge of the protection of Personal Information using the contact information provided in Section 12 of this Policy.

If you believe that your rights have not been respected or that the handling of your request is unsatisfactory, you may file a complaint with our person in charge of the protection of Personal Information or with the Commission d’accès à l’information du Québec.

Subject to the exceptions set out in Applicable Laws, we will respond to your request within thirty (30) days of receiving it. Access is free of charge, subject to reasonable transcription, reproduction or transmission fees permitted by Applicable Laws, of which we will inform you in advance. Any refusal will state the reasons for it and indicate the applicable legal provisions, the available remedies and their time limits.

12. PERSON IN CHARGE OF THE PROTECTION OF PERSONAL INFORMATION

For any questions about this Policy, to exercise your rights or to file a complaint concerning the protection of your Personal Information, you may contact this person using the following contact information:

Jimmy Beauregard (CEO and co-founder)
info@flovver.com
4, Place Ville-Marie, 2nd and 3rd floors
Montréal (Québec) H3B 2E7

13. AMENDMENTS TO THE POLICY

We may amend this Policy to reflect changes in our practices, services or Applicable Laws.

The date of the last update is indicated at the beginning of this Policy. When amendments are made to the Policy, we will take reasonable measures to inform you.

The version of the Policy in effect is the one published on our website.