We recognise the need for appropriate protection and management of the personal and financial information you share with us. We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. For example, we protect personal information using secure socket layer (SSL) encryption technology and by limiting employee access on a need-to-know basis. We store data in encrypted form on computers and control access via secure web pages. We employ firewalls and other security technologies to protect our servers from external attack.
Our security systems meet or exceed industry standards and we are constantly monitoring internet developments to ensure our systems evolve as required. We also test our systems regularly to make sure our security mechanisms are up to date.
Collecting your data
In addition to the information we collect from your online application, we may also collect information about: your loan, such as your current and historical loan amount, payment history and similar information; any inquiries or complaints you make; and your online account. We may also collect information from outside sources such as credit bureaus, including information about your credit history and financial dealings, and other information with your consent or as permitted or required by law.
Additional online data collection
In addition to the personal and financial information you submit, we may collect information about your computer including, where available, your IP address, operating system and browser type - for system administration and to report aggregate information to our advertisers.
We may also collect statistical data about browsing actions and patterns. This information does not identify any individual. We may also obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies enable us to improve our service to you, estimate our audience size and usage patterns, store information about your preferences and recognise you when you return to our site.
Use of your data
We generally use your personal information for the purposes of administering our business including to:
- verify your identity and the accuracy and completeness of the information you provide to us;
- evaluate your loan application including assessing lending and other risks;
- open, administer and service your loan;
- remember you when you return to our website or apply for a subsequent loan, including to pre-populate fields in your loan application with information you previously provided to us;
- update our records and correct errors or omissions in your personal information;
- manage, administer, collect or otherwise enforce accounts and to defend and bring legal actions;
- carry out statistical analysis;
- develop and improve our products;
- understand your ongoing creditworthiness and financial and other requirements and to determine your eligibility or suitability for other products or services;
- identify and prevent fraud, money laundering and other criminal activities;
- carry out regulatory checks;
- conduct market research;
- provide you with information about products or services we offer, if you have asked us to (see “Contact from Wonga and third parties” section below); and
- maintain business records for reasonable periods to meet legal and regulatory records retention requirements.
We want to provide you with the best possible service, so calls to Wonga may be recorded and/or monitored for quality checks and staff training. Recordings may also be used to help us combat fraud.
We may also use your personal information for other purposes with your consent or as permitted or required by law.
Transfer of personal information to service providers
We may transfer personal information to outside agents or service providers (including affiliates acting in this capacity) that perform services on our behalf, for example loan processing (including obtaining credit reports), mailing, call centre, customer service, marketing, collections, information technology and/or data hosting or processing services or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Policy. Some of these service providers or affiliates may be located outside of Canada, including in the UK, South Africa and Switzerland, and your personal information may be collected, used, disclosed, stored and processed in the UK for the purposes described in this Policy. We have trusted relationships with these carefully selected third parties who perform services on our behalf. All service providers are bound by contract to maintain the security of your personal information. However, our service providers may be subject to applicable foreign and Canadian legal requirements, for example lawful requirements to disclose personal information to government, regulatory, national security and law enforcement authorities.
Selling and disclosing your data to third parties
We may disclose your personal information in a number of circumstances, including:
- to credit bureaus, credit reporting agencies, fraud prevention agencies and to your current or future creditors for the purpose of maintaining your credit history and providing credit references;
- to collection agencies to collect a debt owed to us;
- to financial institutions for payment processing purposes;
to third parties as reasonably necessary:
- to enforce your contracts with us and otherwise for the collection or payment of a debt owed to us;
- for the purposes of detecting and preventing fraud;
- in connection with audits;
- for the purposes of meeting legal, regulatory, industry self-regulatory, risk management and security requirements; or
- for any other purpose to which you consent or that is permitted or required by privacy law or any other applicable law.
If you opt-in, we may also share your data with selected third parties (including other lenders) who may use it to contact you by mail, telephone, email, SMS or other method as permitted by law in relation to offers they feel might interest you, whether or not we enter into an agreement with you.
In addition, we may disclose your personal information to a third party:
- In the event we sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such a business or assets)
- If our business or substantially all of its assets are acquired by a third party (in which case personal data held about customers will be one of the transferred assets)
- If we have a duty to disclose your personal data in order to comply with a legal request, or in order to enforce any of our terms and conditions.
Contact from Wonga and third parties
As part of the application process, we ask you whether we may contact you about our products and services by telephone, mail, email and SMS (or other reasonable method). If you ticked “yes” but no longer wish to receive such communications, please visit the My Account page, login and change your communication preference at any time, or follow the instructions in the message itself.
If you opt-in, we may disclose your personal information to selected third parties (see “Selling and disclosing your data to third parties” above). If you opted-in, but no longer wish to receive contact from a third party, you will need to follow the instructions about unsubscribing provided by the third party. Please note that we only partner with trusted companies who will respect your right to unsubscribe from any such marketing communications, but we will not be responsible for managing that process or any disputes.
Third party links
Our site may contain links to third party websites. If you follow a link to any of these websites, please note that these websites have their own terms and privacy policies and that we do not accept any responsibility or liability for them. By registering at Wonga, and unless you opt-out, you may receive follow-up contact and offers from third party companies and, while we only work with selected partners, we are not responsible for the services or representations of third parties.
To register with us you must be over the age of majority in your province or territory of residence. Minors are strictly forbidden from using the service
Access, Correction and Contacting Us
We may establish and maintain a file of your personal information for the purposes described above, which will be accessible at 401 Bay Street, Suite 1600, Toronto, ON, M5H 2Y4; or 1500-1055 West Georgia St., Vancouver, BC, V6E 4N7. If you wish to request access or correction of your personal information in our custody or control, you may write to the above address, attention Privacy Director. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections. If you wish to make inquiries or complaints or have other concerns about our personal information practices, you may write to us as described above, e-mail us at firstname.lastname@example.org or telephone us at 1-855-WONGA-CA (1-855-966-4222) toll free.