Approval Pathway Privacy Policy

1. Introduction

Approval Pathway (“AP,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy outlines how we collect, use, disclose, retain, and protect your information when you use AP’s commercial loan application platform.

This policy complies with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and the British Columbia Personal Information Protection Act (BC PIPA).

2. Information We Collect

AP collects the following types of information to facilitate the loan application and evaluation process:

• Contact Information: Includes names, email addresses, phone numbers, and mailing addresses.
• Financial Information: Bank statements, financial statements, tax returns, income details, and other relevant financial data.
• Business and Collateral Information: Business details, loan purpose, collateral information, and any other data required for loan underwriting.
• Technical Data: Information about your device and usage, such as IP address, browser type, and usage data, which helps us improve our platform’s functionality and security.

Note: We only collect the minimum information necessary to provide and improve our services.

3. How We Use Your Information

AP collects and uses your information to:

• Facilitate Loan Applications: Provide borrowers, brokers, and lenders with a streamlined commercial loan application process.
• Process Loan Evaluations: Allow lenders to evaluate loan applications securely and efficiently.
• Enhance Platform Services: Analyze anonymized, aggregate data for internal research, statistical analysis, and platform improvements.
• Communicate with You: Send updates, respond to inquiries, and notify you of changes or issues affecting your account.

4. Sharing Your Information

We share personal information with third parties only when necessary for the operation of our services:

• Lenders and Brokers: With your consent, we share relevant information with lenders or brokers to facilitate the loan application process.
• Service Providers: AP uses Google Cloud for data storage and processing, and OpenAI for our GPT-based assistant and evaluation features. These third-party providers are required to handle personal information in compliance with applicable privacy standards.

We do not sell or rent personal information to third parties. If additional third-party services are integrated, this policy will be updated, and you will be informed.

5. Consent

By using our platform, you consent to the collection, use, and disclosure of your personal information as outlined in this policy.

• Withdrawing Consent: You may withdraw your consent at any time. If you withdraw consent, certain features of our platform may become unavailable. Contact our support team at privacy@approvalpathway.com for further assistance.

6. Retention of Information

We retain personal information for a period of 5 years after loan closure to comply with regulatory and operational requirements. Beyond this period, all personal data is securely disposed of, unless otherwise required by law.

We may retain anonymized, aggregate data for statistical analysis and platform enhancements without retaining personally identifiable information.

7. Your Rights

AP respects your rights to access, update, and control your personal information:

• Access: You may access and view your information through your AP dashboard.
• Corrections: Update or correct your information as needed within your account.
• Deletion: You may delete your loan application and all associated data through the AP platform. For additional deletion requests, contact privacy@approvalpathway.com.

For questions or further assistance with accessing or updating your data, contact our support team at privacy@approvalpathway.com.

8. Data Security

We implement industry standard security measures and best practices to protect your personal information:

• Encryption: All personal data is encrypted both in transit and at rest.
• Access Controls: We use role-based access controls and multi-factor authentication to ensure that only authorized personnel can access your information.
• Data Integrity: Our security team monitors and regularly updates our security practices to adapt to evolving threats and standards.

While we strive to protect your data, please note that no method of transmission over the internet or electronic storage is completely secure.

9. Breach Notification

In the event of a data breach that may expose your personal information, AP will:

• Notify you and relevant regulatory authorities in a timely manner, including a description of the incident, the information involved, and any actions taken to mitigate the impact.
• Provide guidance on any steps you can take to protect yourself.

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10. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. If we make significant changes, we will notify you via email or an in-app message.

11. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact our Privacy Officer at: privacy@approvalpathway.com