
Finmo
Privacy Policy (US) – Finmo
Last Updated: February 26, 2025
Lendesk Technologies ULC (“Lendesk”, “we” or “us”) is committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy policy is to inform you about how we collect, use and disclose personal information when you interact with our website www.lendesk.com (the “Website”) and with our products and services, including Lendesk and Finmo, (the “Services”). This privacy policy relates to all of our activities, unless we have provided you with a separate privacy policy for a particular product, service or activity.
In this Policy, we use the word “Client” to refer to anyone who has subscribed to or paid for use of our Services. We use the word “you” to refer to any other individual user of our Services, such as an employee or user of a Client, or an individual browsing or using our Website and web-based resources.
This Privacy Policy does not apply to the extent we process personal information in the role of a processor or service provider on behalf of our Clients. It is that Client’s privacy statement that applies; we conduct such activities strictly in accordance with our Client’s instructions and pursuant to our contractual arrangements with the Client. If you are an end user or consumer with an existing relationship with one of our Clients, you should refer to the Client’s website to understand their privacy practices and policies.
Please review this privacy policy carefully. By submitting your personal information to us, by using our Website, or by otherwise accessing or using the Services, you consent to our collecting, using and disclosing your personal information as set out in this privacy policy.
What This Privacy Policy Covers
This Privacy Policy covers the following topics:
- Personal Information
- Your Consent to the Collection, Use and Disclosure of Your Personal Information
- Our Collection of Personal Information
- Our Use of Cookies
- How We Use Your Personal Information
- How We Share Your Personal Information
- Opting Out of Marketing Communications
- Retention, Storage, and International Transfer of Personal Information
- Information Security
- Accessing and Updating Your Personal Information
- Third-Party Websites and Services
- Changes to this Privacy Policy
- Contact Us
- Supplemental Notice for US Residents
Personal Information
Personal information does not include information where there is no serious possibility that it can be used to identify an individual, whether on its own or in combination with other information, or personal information that has been anonymized or aggregated such as to be considered anonymized information or no longer personal information under applicable laws. Lendesk reserves the right to use anonymized or aggregated information at any time in its sole discretion.
Your Consent to Collection, Use and Disclosure
The primary basis on which we collect, use and disclose your personal information is with your consent, unless otherwise permitted or required by law. How we obtain your consent will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this privacy policy.
Typically, we will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.
You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information within our Website. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services. Please also note that certain data will remain within the Services for us to fulfill our contractual obligations, even after you withdraw your consent.
If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect such information from you, and to use and disclose his or her information as described in this privacy policy.
Our Collection of Personal Information
How we collect Personal Information
We collect Personal Information from you in the following ways:
- Through your use of the Services, whether directly uploaded and created by you, or automatically collected by us as you or our Client uses the Services. This includes individuals who use the Services in their organization or at the direction of their employer and who input information about their customers. This information is referred to herein as “Client Data”.
- Through your engagement with our Website, including information submitted by you within a website form or obtained from us through cookies or similar technologies. This information is collectively referred to as “Website Data”.
- From other third-party sources, such as our partners and service providers.
Types of Personal Information we collect
We collect the following types of information from you:
- Account and Profile Information: we collect your contact information to facilitate the purchase of our Services and to manage our relationship with you. This includes information such as your name, e-mail address and other contact information, as well information about your account opening, registrations and any addition account information provided by you. If you are using the Services through an organization, we may also collect information about your job title, job function and work product.
- Other Basic Personal Information: we collect additional personal information such as name, contact information, marital status, living history, and income level.
- Mortgage Information: we collect information required to complete your mortgage application, including your credit history, desired mortgage goal, medical information, property, subject property, assets, education, employment information and social insurance numbers.
- Third Party Information from other users: Other Clients may provide information about you when they submit content through the Services. Similarly, your employer may provide your contact and employment information when they add you as a user or designate you as the billing or technical contact on your organization’s account.
- Information from linked accounts: We may receive information about you when you integrate or link a third-party service with our Services. You may also integrate our Services with other services you use, so as to allow you to access, store, share and edit certain content from a third-party through our Services. The information we receive when you link or integrate our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our Services.
- Usage and Technical Information: We collect usage information relating to your use of the Services and how you interact with our Website. Such information may include your Internet protocol address, information about your device, browser and operating system, how you are using our Services, and the date and time of your visit.
- Payment Information: We collect certain payment and billing information when you register for the Services. For example, we may ask that you designate a billing representative, including name and contact information, upon registration.
- Website Forms: We collect information that you submit to us on our Website, including your name, e-mail address and other contact information. We will also collect any feedback you provide about our products and services.
Our Use of Cookies
A “cookie” is a small text file that contains information and is stored on your computer. We use cookies and similar tracking technologies, such as web beacons and pixels, to automatically collect information about your use of our Website and your interaction with our emails. Information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, internet service provider and/or mobile carrier, pages and files viewed, searches, operating system and system configuration information, and date/time stamps associated with your usage.
We use this information to facilitate the use of our Website, for our business or analytical purposes (including to assess website traffic and track search criteria), and to personalize web pages according to your choices and interests.
We may also use this information to engage in interest-based advertising (also known as targeted or behavioral advertising) in connection with your use of our Website, and across third-party websites or service offerings when you leave our Website. Interest-based advertising means that your preferences and interests are collected through cookies or similar technologies and then used to provide you with advertising and marketing materials that are relevant to you, based on those preferences and interests.
If you do not wish to accept cookies, you can adjust your web browser settings so that you automatically deny the storage of cookies or are informed each time a website requests to store a cookie. Previously stored cookies can also be deleted through your web browser. Please refer to your web browser’s help pages for more information. Some areas or features of our Website rely on cookies and may not work if you delete or decline cookies. For more information about cookies generally please visit www.allaboutcookies.org.
Google Analytics and Facebook
Our Website utilizes Google Analytics, a service from Google, Inc. (“Google”) that uses cookies. The information collected by the cookies (which includes your IP address) is transferred to Google who stores and processes the information in the United States. Google uses the information to provide us with an analysis of your use of our Website, as well as the overall use of and traffic on our Website. You can opt out of Google Analytics by downloading and utilizing the Google Analytics Opt-out Browser Add-on. By using our Website, you understand and acknowledge our use of Google Analytics.
Facebook, Inc. (“Facebook”). We may use Facebook’s advertising services from time to time. You can opt-out of interest-based advertising from Facebook by visiting their website.
How We Use Your Personal Information
We may use your personal information and other information that we collect to provide the Services, to comply with our contractual obligations, and to support our legitimate interests in maintaining, improving and advertising the Services. Below are the specific purposes for which we use the information we collect about you.
- to provide you with our Services and to support your use of our Services, including but not limited to providing mortgage planning advice and tracking your mortgage application;
- to connect you to your mortgage professional, or if you’re a mortgage professional to connect you to a borrower;
- to respond to your inquiries, complaints or requests;
- to communicate with you through our newsletter or other member communications;
- to monitor, maintain, and improve our Services, and to develop new products and services;
- to manage our business and our arrangements with our clients, including to detect and prevent errors and fraud;
- to investigate legal claims and protect our rights, operations or property;
- for such other purposes as you may consent to from time to time; and
- as otherwise required or permitted by law.
How We Share Your Personal Information
Sharing with our Clients and other Professionals
We make tools that facilitate collaboration between various users and organizations. When you use the Services, we may share information with other Clients and their users.
- To Clients: For the purposes of administering your mortgage application, we will share your personal information with our Clients and as applicable, any appropriate third-party lending institution. To provide a bit more context on how information is processed by Finmo, please refer to the text below:
{yourmortgage professional}.mtg-app.com (website) → Finmo → Filogix (Finastra) → Credit Pull → Lender
Alternatively, some mortgage professionals may choose to bypass Finastra’s Filogix and submit to lender directly from Finmo.
{yourmortgage professional}.mtg-app.com (website) → Finmo → Credit Pull → API → Lender
- Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organization, certain information about you including your name, profile picture, contact info, content and past use of your account may become accessible to that organization’s administrator and other Service users sharing the same domain. If you are an administrator for a site or group of users within the Services, we may share your contact information with current or past Service users, for the purpose of facilitating Service-related requests.]
Sharing with Third Parties
We share your personal information with third party service providers who perform some functionality within the Website and Services on our behalf, such as client services, technical support, hosting, data storage and processing, conducting audits, and research and analytics. We also share your information with third party service providers who provide products and services that we use to operate our business, such as payment processing, email services, marketing campaigns, job applications and alerts, employee management, surveys and contests. For example, we may share information with a property aggregator to receive information about a subject property being purchased. Or, at the request of a user we may share banking information with a third party for easier document collection. Or, at the request of the user we may share First Name and Last Name with a third party for e-signature.
If we provide your information to service providers for our provision of the Services, then we require that service providers maintain the confidentiality of your personal information and keep your personal information secure. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes. If you would like more information about our service providers, please contact us using the contact information on our Website.
Other Disclosures
Additionally, we may disclose your information when we believe such disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.
If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure and obtain your consent.
Opting Out of Communications
If you no longer want to receive marketing-related emails from us, you may opt out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt out by contacting us directly using the contact information on our Website.
We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.
Retention, Storage, and International Transfer of Personal Information
We will maintain your personal information for as long as they are needed, or as required by applicable laws, regulations, or government orders. After the relevant amount of time has passed, we will delete your information. Please note that Clients are able to add, update, or delete certain information within the Services at their own discretion. Some Client Information may be retained by Lendesk to fulfill contractual obligations to our Clients, or as otherwise required by law.
Client Information is currently stored on AWS in the Canada region. We may transfer your personal information outside of Canada to fulfil the purpose for which we collected it, including for processing and storage by service providers. For example, Intercom stores Client names and emails for customer support in the United States. While your personal information is outside of Canada, it is subject to the laws of the country in which it is located, which may have different data protection laws than Canada. Those laws may require disclosure of your personal information to authorities in that country. For more information about our policies and practices regarding service providers outside of Canada, contact us using the contact information in the “Contact Us” section below.
Security of Personal Information
We have implemented commercially reasonable physical, organizational, contractual and technological security measures with a view to protecting your personal information from accidental or unlawful destruction, loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. In the case of a breach of security safeguards, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.
You are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of our Website and/or the Services. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them, and you should use caution in selecting the personal information you provide to others through our Website or the Services. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through our Website or the Services. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information on our Website.
Your Rights Regarding Your Personal Information
Individuals have a number of rights concerning their personal information under global privacy laws. You may make a written request to access, correct or delete any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required. If you provided personal information to a Client and believe it is being processed by us on behalf of that Client, please make any requests or queries regarding that personal data to the Client directly.
Where applicable, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing; (ii) the right to object to unlawful data processing, under certain conditions; (iii) the right to erasure of personal information about you, under certain conditions; (iv) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your personal information is inaccurate; (v) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vi) the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions.
Please note that such rights are 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 data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
When you exercise your right to deletion of your personal information, we will delete your personal information, subject to some instances where your personal information will be maintained for us to fulfill our obligations under contract to our Clients. This information includes historical posts and content contained within Client Data.
You also have the right to lodge a complaint with the relevant data protection or privacy authority, such as the Office of the Privacy Commissioner.
We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose. We will not charge you any fees to access your personal information in our records without first providing you with an estimate of the approximate fees, if any.
For US residents, please see the Supplemental Notice for US residents regarding your additional rights.
Third Party Websites and Services
This privacy policy applies only to our products and services. This privacy policy does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third party websites or products or services.
Privacy Policy Updates
This privacy policy is current as of the “updated” date which appears at the top of this page. We may modify this privacy policy from time to time. When changes are made to this privacy policy, they will become immediately effective when published in a revised privacy policy posted on our Website, unless otherwise noted. We may also communicate the changes through our Services or by other means. By submitting your personal information to us, by registering for or using any of the Services we offer, by using our Website, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this privacy policy, you consent to our collecting, using and disclosing your personal information as set out in the revised privacy policy.
Contact Us
All comments, questions, concerns or complaints regarding your personal information or our privacy practices should be sent to our Privacy Officer at the following email address: usersupport@finmo.ca or at:
Lendesk Technologies ULC
Attn: Lendesk Privacy Officer
PO Box 48299 Bentall
Vancouver, BC, V7X 1A1
Supplemental Notice for US Residents
This Notice supplements the information contained in the Privacy Policy and applies solely to individuals who reside in the States of California, Virginia, Connecticut, Colorado, and Utah (the “Supplemental States”). We adopt this Notice to comply with the California Consumer Privacy Act (as amended by the California Privacy Rights Act), the Virginia Consumer Data Protection Act, the Connecticut Data Privacy Act, the Colorado Privacy Act, the Texas Data Privacy And Security Act, or the Utah Consumer Privacy Act (the “State Privacy Laws”) and any terms defined in those laws have the same meaning when used in this Notice.
Shine the Light
Pursuant to Section 1798.83 of the California Civil Code, California residents may request certain regarding and/or opt-out of our disclosure of personal information to third parties for their direct marketing purposes. Please email supportus@lendesk.com with such requests and note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
Retention Period
We only maintain your information as long as necessary to fulfill our legitimate business purposes and as required by applicable law.
Collection and Use of Personal Information
We collect, use and disclose the personal information collected in accordance with our Privacy Policy.
Sensitive Information
We may collect, use and disclose the following sensitive personal information as defined under the CCPA:
- Citizenship information, social security, driver’s license, passport number or state identification as provided by you or your Mortgage Professional.
Your Rights
If you are a resident of the Supplemental States and have provided personal information to Lendesk, you can request:
The Right to Know
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
- The specific pieces of information we have collected about you;
- The categories of Personal Information we have collected about you;
- The categories of sources of the Personal Information;
- The categories of Personal Information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of Personal Information we have sold and the categories of third parties to whom the information was sold;
- The business or commercial purposes for collecting or selling the Personal Information
The Right to Request Deletion
You have the right to request the deletion of Personal Information we have collected from you, subject to certain exceptions.
The Right to Correct/Rectify
In certain circumstances, you have the right to request correction of any inaccurate personal information. Upon verifying the validity of a valid consumer correction request, we will use commercially reasonable efforts to correct your personal information as directed, taking into account the nature of the personal information and the purposes of maintaining your personal information.
The Right to Opt Out of the Sale of Personal Information
You have the right to opt-out of the disclosure or sale of your information to certain third parties.
The Right to Access
You have the right to access personal information that we may collect or retain about you. If requested, we shall provide you with a copy of your personal information which we collected as permitted by the applicable State Privacy Law.
You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another entity (“data portability”).
The Right to Limit How Your Sensitive Personal Information is Disclosed
You have the right to limit how your sensitive personal information is disclosed or share with third parties.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process Personal Information, we may no longer be able to provide you our products and services or engage with you in the same manner.
Note: We will not provide information if doing so would violate a duty of confidentiality owed to our customers or any applicable laws and regulations.
Right to Appeal
Users have the right to appeal our decisions and may contact us at supportus@lendesk.com to exercise this right.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will not discriminate against you for exercising any of your rights under California law.