At Noma Financial Inc. ("Noma Financial", "we", "us", "our") we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Noma Financial collects from or about you on or through our website: 
www.nomafinancial.com, www.myeasybucks.ca, www.getweekly.ca or www.getflexi.ca, services and other means described in this Privacy Policy (collectively, the "Services").

This Privacy Policy also describes how we use and to whom we disclose your personal information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING OUR SERVICES, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY AND AGREE TO BE BOUND BY ITS TERMS. YOU CAN WITHDRAW YOUR CONSENT AT ANY TIME, HOWEVER, IF YOU CHOOSE TO DO SO, WE MAY NOT BE ABLE TO PROVIDE YOU WITH ACCESS TO OR USE OF THE SERVICES. 

By voluntarily providing us with your personal information, you are consenting to its collection, use and disclosure in accordance with this Privacy Policy. You acknowledge and agree that such personal information (i) may be transferred from your current location to the offices and servers of Noma Financial and authorized third parties referred to herein located in Canada; and (ii) may be accessed by the national security or law enforcement agencies in Canada.

Noma Financial may amend this Privacy Policy to reflect changes in our legal or regulatory obligations or in the way we deal with your personal information. We will post any revised version of this Privacy Policy on our website and mobile application and the revised version of the Privacy Policy will be effective at the time we post it. If we make material changes we will notify you as required by law, but we encourage you to refer to this Privacy Policy on a regular basis. Your continued use of the Services after an update signifies that you consent to the collection, use and disclosure of your personal information as described in the updated Privacy Policy.

1.1. What is Personal Information?
For the purposes of this Privacy Policy, personal information is any information about an identifiable individual.

1.2. The Personal Information that We Collect Directly.
We collect and maintain different types of personal information about the individuals with whom we interact. Before permitting you to use the Services, we may require you to provide us with certain personal information. For example, we collect information when you choose to create an account and use our Services, participate in any of our offers, promotions, programs and other initiatives, contact us or otherwise provide your personal information to us for any other purpose. The types of personal information that we may collect includes: (a) contact and identification information, such as your name, social insurance number (optional), address, telephone number, mobile number, email address, third-party application IDs and other similar contact and identification information; (b) financial information, such as bank account numbers, credit scores, checking account information, credit and debit card information and other similar financial or payment information; (c) your location and demographic information, including your age, date of birth; and (d) government IDs and identifying documents, including but not limited to your utility bill, bank statements, credit card statement, loan statement (or mortgage documents), passport, permanent resident card, identification card, BC services card (applicable to residents of British Columbia), answers to certain knowledge-based authentication questions, cell phone number and/or information about your wireless service provider. We may also collect information about you from any interactions you have with while accessing or visiting our Services or contacting our employees, such as, with our customer support team or in surveys.
 
1.3. Information that Noma Financial Receives from Your Use of the Services.
When you visit or use Services or view our online advertisements, we may also collect information related to these activities and your interaction with our Services, including any information that is sent to us by your computer, mobile phone or any other device, including your IP address and other device information, including unique device identifiers, name and type of your device, operating system, location, mobile network information and standard web log information. Information relating to your device settings, such as the type and version of your browser, application IDs, crash data, traffic data to and from our website, the pages you accessed on our website, and any other available information. We may also store information based on your usage history, including details of your purchases, content you viewed, event information and click stream information. We collect this information using the technologies described in section 1.4 below.

1.4. Cookies and Anonymous Identifiers.
We may also collect, use, and store information based on your usage history, including details of your purchases, content you viewed, event information, and clickstream information. We do this using various technologies such as cookies, web beacons, and anonymous identifiers. We may place a "cookie" on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to remember your passwords, actions and preferences with respect to our website. The cookie allows us to better understand your use of our website and to customize and tailor the website to better meet your needs. While most web browsers are set to accept cookies you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. You can also opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. It should be noted that if cookies are not accepted, you may not be able to access the Services.

We may also use the Facebook pixel, which is JavaScript code that is placed on the website. This pixel enables us to track whether you have clicked through to the website from one of our Facebook advertisements. This feedback helps us to target our marketing so that you see those Facebook ads for our Services that we believe may be most relevant to you. Facebook also deposits a cookie on our website that collects certain information. This information is sent back to Facebook in anonymize, hashed form where Facebook uses it to assist us in building targeted audiences for future ads, and in remarketing our Services to you if you have browsed through our website.

1.5 Call Recordings
We will record any phone call made or received through our customer help line for quality assurance and training purposes. You will be notified of our intent to record the call for this purpose before any substantive discussion begins. We will provide you with another means to communicate with us if you choose not to consent to this recording. You have the right to obtain a copy of this recording.
Noma Financial is not required to obtain consent to record your phone call if (1) Noma Financial is calling you for the purpose of collecting a debt; (2) the call is for the purpose of investigating potential fraud; or (3) your knowledge of our recording could hamper Noma Financial's ability to obtain accurate information.

1.6 Information Obtained from Third Parties.
You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook and Twitter). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By associating an account managed by a third party with your Noma Financial account and authorizing Noma Financial to have access to this information, you agree that Noma Financial may collect, store and use this information in accordance with this Privacy Policy.

In addition, from time to time, we may utilize the services of third parties such as merchant, credit bureaus and identity verification services, and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. For example, we may receive your personal information from third party service providers that perform identity verification services on our behalf. In these instances, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

We may also receive your information if you have authorized your wireless carrier to disclose information to us about your account, such as your name and address, subscriber status, payment method and device details, if available, for the limited purposes of identity verification, and fraud avoidance for the duration of your business relationship with us. This information may also be shared with our service providers to the extent necessary to support these purposes.

1.7 Why do we Collect Personal Information?
We only collect the necessary information from you to provide you with the products and services available through the Services and which enables us to manage, maintain, and develop our operations. For example, we collect information to:

• establish, maintain, and manage our relationship with you so that we may provide you with, or receive from you, the products or services that have been requested;

• enable you to register, access and maintain an account with us;

• allow you to participate in, subscribe to, or otherwise receive products or services from us;

• be able to review the products and services that we provide to you so that we may: (a) understand your requirements for our products and services; and (b) work to improve our products and services;

• be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);

• create analytical data and conduct research in connection with our business, services, promotions and operations;

• to make improvements to our product and Services. We may use your personal information to evaluate existing products and services, develop new products and services, drive strategy and improve the customer experience we offer. Information we collect is also valuable for our quality and servicing training programs;

• to understand your preferences and tailor offers, products and services to you based on these preferences;

• to send information to you about promotions, products or services of ours or our marketing partners that we believe may be of interest to you; to protect Noma Financial against error, fraud, theft and damage to our goods and property as well as to investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person;

• to enable us to comply with applicable laws or regulatory processes; and

• any other reasonable purpose to which you consent.

By accessing our Services or using our products, you consent to our collection of your personal information and you allow us to fulfill the purposes for which we collect your personal information. When we collect your information for research and development purposes, we ensure that any information used for our analysis and reports will be de-identified and aggregated in a manner that will not identify you. Notwithstanding anything to the contrary contained in this Privacy Policy, we may remove personal identifiers from your information and maintain and use it in a de-identified form that may be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information.

We will retain your personal information only for a time and to the extent necessary for the purposes for which it was collected as described in this Privacy Policy and for reasonable backup, archival, audit, or other similar purposes including requirements of the law.

1.8 Safety and Security Policies
Noma Financial stores and processes your information maintaining appropriate physical, electronic and procedural safeguards. We maintain physical security measures designed to guard against unauthorized access to systems and use safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings, and we authorize access to personal information only for those employees or agents who require it to fulfill the responsibilities of their jobs and in accordance with this Privacy Policy.

The security of your personal information is important to us and Noma Financial maintains security management protocols designed to ensure that your data is adequately protected. Please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

2.1 Our General Business Purposes
We share your personal information with employees, affiliates including Noma Financial, Inc., vendors, partners, merchant partners, marketing providers, and other third parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. For example, these services include, but are not limited to, processing transactions, data storage and processing, identity verification services, maintaining your account, marketing, advertising and promotion of Noma Financial's products and services, responding to court orders and legal investigations, complying with audits or other investigations, and reporting to credit bureaus. In addition, we may disclose your personal information: (a) as permitted or required by applicable law or regulatory requirements; (b) for the purposes of collection and/or as otherwise described in this Privacy Policy; and (c) for additional purposes for which we have obtained your consent to the use or disclosure of your personal information. We may also share your personal information with our financial, insurance, legal, accounting or other advisors that provide professional services to us.

2.2 With Our Affiliates
We may share your personal information with our parent company, Noma Financial Inc or subsidiary companies like Easybucks Inc. for the purposes of underwriting and processing loans provided to you under a loan agreement.

With Our Merchant Partners to Provide Personalized Offers.
We may also share your personal information with the merchants in connection with your use of Noma Financial's products and services and for marketing purposes. Noma Financial will advise a merchant when you are approved or declined to utilize Noma Financial's Services but will not share the reason for the decline with the merchant. We do this to help merchants personalize services and offers, so you can have a better experience. In addition, Noma Financial may share your personal information (including, but not limited to, your name, phone number, address and details about items purchased) with a merchant in the course of servicing your account or processing one of your transactions (including, but not limited to, by advising a merchant when you have contacted Noma Financial about a transaction). Noma Financial may also share with a merchant whether or not you have an active loan and/or the status of a previous checkout.

You’re able to revoke your consent at any time by following the steps outlined below. If you choose to do so, we will stop sharing your information with merchants from that point onward, except as necessary to complete transactions you initiate. To revoke your consent to information sharing with merchants for marketing, you can log into your Noma Financial, GetFlexi or other brand account and edit your Personalized Services preferences.

2.3 With Credit Bureaus and Other Service Providers
We may also share your personal information with the credit bureaus (including credit reporting agencies), wireless carriers and other third party services providers engaged by us in connection with your use of Noma Financial's products and services. In each case, we will use contractual or other reasonable means designed to ensure your personal information is protected and not used or disclosed for purposes other than as outlined in this Privacy Policy.

2.4 Business Transactions
In addition, personal information may be disclosed or transferred to another party and their professional advisors during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Noma Financial or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information. We do not rent or sell your personal information to third parties in Noma Financial's ordinary course of business.

2.5 Other Ways your Personal Information may be Disclosed
Your personal information may also be disclosed: (a) as permitted or required by applicable law or regulatory requirements; (b) to comply with valid legal processes such as search warrants, subpoenas or court orders; (c) as part of Noma Financial's regular reporting activities under applicable laws; (f) with national security or law enforcement agencies of those countries to which personal information is transferred; and (e) with your consent.

2.6 The Consequences of the Sharing of your Personal Information
Your personal information may be stored and processed at our corporate offices or with approved third parties within Canada. If a third party processes or stores information outside Canada, foreign governments, courts or regulatory agencies may therefore be able to obtain such personal information through the laws of the foreign jurisdiction. If you would like further information about our policies and practices regarding service providers located outside of Canada and further information about how these service providers, collect, use, disclose or store personal information, please contact our Customer Care team using the contact details below. By providing your personal information to us, you consent to our disclosure of this information to our service providers, merchants and other third parties as described in this Privacy Policy, including those that may be located outside of Canada, for the purpose of processing your order, marketing to you, providing services to us or to you, to operate our business and for the other purposes described in this Privacy Policy.

3.1. Your Consent is Important to Us
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied or express. We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information, for example when we intend to use the information for a purpose not previously identified. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will use our best efforts to advise you of that purpose before such use or disclosure. You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer. If you withdraw or vary your consent, we may not be able to provide you with the products and services you request through our Services. For example, if you want to place an order for our products or services, but do not provide the information required to purchase such products, we will not be able to fulfil your request.

Unless you advise us otherwise, through the access and use of our Services, or the purchase of any of Noma Financial's products and services, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Notifications
If you no longer wish to receive notifications about our Services, you may change your notification preferences and opt-out of receiving such notifications by logging into your account and adjusting your preferences or by following the directions provided with the communication or by calling Noma Financial's Customer Care at 1-855-562-6003. Noma Financial reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to provide the Services. You are still responsible for any amounts due to Noma Financial even if we close or limit access to your account. You also have the right to opt-out of receiving notifications and marketing directly from merchants and you should contact the merchant directly if you wish to exercise such opt-out rights.

3.2 SMS Messaging.
You can opt out of receiving SMS messages by calling us at 1-855-562-6003 or replying "STOP" to an SMS message you have received from us. Again, Noma Financial reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to perform the Noma Financial's Service. You are still responsible for any amounts due to Noma Financial even if we close or limit access to your account.

3.3 Openness and Access.
You can review and edit your personal information at any time by signing in to your account at www.nomafinancial.com or by submitting a privacy request.

Canadian data protection laws, such as the Personal Information Protection and Electronic Documents Act ("PIPEDA"), give Canadian consumers the right to receive certain information regarding the collection, use, and sharing of personal information as well as the right to know and access the personal information a company collects from or about them. If you would like to exercise such rights, please submit a privacy request.
Please note that when requesting access to your personal information, we will ask that you sign in to your Noma Financial account so that we can confirm your identity and right to access the personal information that we hold about you. If you need help preparing your request, please contact our

Privacy Officer at privacy@nomafinancial.com.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you why we are unable to grant you access, subject to any legal or regulatory restrictions.

General
3.4 Linked Websites.
Our Services may contain links to other websites that may be subject to less stringent privacy standards and policies. These links are provided for your convenience only and you assume all risk for clicking these links to other websites. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Noma Financial is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

3.5 Personal Information of Minors.
Our Services are not intended for minors. We do not knowingly collect personal information from minors. If you are considered a minor in your jurisdiction, do not access our Services, including on or through any of the features on the Website or App, use any of the interactive or public comment features of the Website or App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we become aware of any information we have collected or received from a minor without verification of parental consent, we will delete that information. If you believe we might have any information from or about a minor, please contact our Privacy Officer.

3.6 Interpretation.
This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore, where the word "including" is used, it shall mean "including without limitation".

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Noma Financial any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable laws. Should there be, in a specific case, any inconsistency between this Privacy Policy and applicable laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

3.7 Contact Noma Financial.
If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction. We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Noma Financial Inc.
10 Milner Business Crt,
Scarborough (Ontario)
M1B 3C6, Canada
Email: privacy@nomafinancial.com

If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending any personal or confidential information to us.