Protecting Your Privacy
The Interface Financial Group is taking protection of clients and partners privacy very seriously. We are meeting all privacy compliance requirements in all jurisdictions we are operating in.
Global Privacy Disclosure Statement
The Interface Financial Group (“IFG”, “we”, “us”, “our”) collects personal information (or personally identifiable information) about you for the purposes you agree to in this Global Privacy Disclosure Statement (“GPDS”). When you click the “I Agree” button below, you agree we can, consistently, collect, use and disclose personal information about you for those purposes listed below. Protecting your privacy is important to The Interface Financial Group. This GPDS provides information on how your privacy is protected through management of personal information, and how that information is collected and disseminated. This GPDS covers any applicants for financial services provided by IFG. The terms “we” and “us” used in this document refer to The Interface Financial Group.
Personal Information IFG Collects
IFG will only ask for personal information relevant to our business relationship with you and information required by government legislation and regulation. We do not collect information regarding: religious views, ethnicity, political positions, criminal records, personal health information or sexual preference.
IFG collects information:
We collect personal information about you:
- to determine whether we should provide a facility which includes the provision of commercial credit to you and, if we decide to provide it, to assist in the provision of the facility. This includes the assessment of the application, managing the account, recovering money and dealing with security you give; or
- to determine whether we should provide a facility which includes the provision of commercial credit to a company with which you are associated (for example as a director or shareholder) and to assist in the provision of the facility. If a guarantee may be given we are collecting the personal information to determine whether we should accept it and, when it is given, we collect the personal information to deal with or enforce our rights under the guarantee and any security which may be given to secure it.
- The main consequence for you if all or some of the personal information is not collected by us is that we may be unable to process your (or the company’s) application, and we may decide not to provide a facility or we may decide to restrict or end a facility.
We may collect personal information about you from someone other than you. The personal information could be collected from the company we have provided or may provide a facility to, a credit reporting agency, brokers and other introducers, and/or public registers.
We usually disclose personal information to a credit reporting agency; government authorities and others as required or authorized by law; your broker or other introducer; our and your legal, financial and other adviser or representative; persons who provide a service to us; insurers and underwriters; financiers and parties to a securitization arrangement; a potential or existing guarantor; a person who owes a debt which we have purchased (or have a security interest in) in connection with a facility we provide and that person’s advisers; and a corporate entity which is related to us. Generally, we do not disclose personal information to a person overseas although we may do so in some circumstances, such as if a related corporate entity, guarantor or debtor is overseas.
Information we may collect includes:
Contact Information – Name, address, phone, email, date of birth and/or Social Security Number or Social Insurance Number.
Financial Information – Financial statements, credit reports, tax file number, and information for creditworthiness. Information from general searches relevant to IFG service requested.
IFG may ask for personal information that we are required to collect for legal reasons to meet government laws and regulations; such as the Know Your Customer, Anti-Money Laundering, Counter-Terrorism Financing and other legal requirements to verify your identity; which could include a copy of your internationally valid identification. If you do not provide some personal information, IFG may not be able to provide you with the product or service you are seeking.
How Is Personal Information Collected?
Most of the information collected by IFG will come directly from you. This information may be collected through application forms, through telephone conversations, over the internet or during a personal meeting with you. We collect information from you when you register on our site, fill out a form, use Live Chat, open a Support Ticket or enter information on our site.
IFG may also collect information from other parties. This may happen with or without your direct consent. Sources of other information include:
- General searches
- Credit Reporting agencies
- Publicly available sources of information
- Accountant or legal representative
- Third party brokers
- Government agencies
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To improve our website in order to better serve you.
- To allow us to better service you in responding to your customer service requests.
- To quickly process your transactions.
- To send periodic emails regarding your order or other products and services.
- To follow up with you after correspondence (live chat, email or phone inquiries).
When is Personal Information Collected
We collect information from you when you register on our site, fill out a form, use Live Chat, open a Support Ticket, provide us with feedback on our products or services or enter information on our site.
Providing Information to Others
IFG may share your personal information with outside entities. This may be for reasons of providing you with a product/service beyond the capabilities of IFG. Other entities that we may provide your personal information to include:
- Other financial institutions
- Credit reporting agencies
- Debt collection agencies
- IFG accountants, auditors or lawyers
- Your personal representatives, such as: accountant, financial advisor or attorney
We may monitor and/or record communications between you and IFG for quality control, analytics, verification and training purposes.
We keep your personal data for as long as necessary for the purposes for which it was collected and to provide you with services, to conduct our legitimate business interests or where otherwise required by law. We will retain your data for the lifetime of your account with us and for a period thereafter within the confines of the applicable laws.
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide users with advance notice and gain consent. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release or disclose information when its release or disclosure is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety, or under other circumstances as discussed in this GPDS.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
IFG may use your personal contact information to provide you with information and updates concerning current products/services. It is our intent to only provide the information they need to perform their services to us or to provide products/services to you. These organizations must meet the privacy standards that we enact, and must comply with the applicable Privacy laws.
How do we protect your information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted viaSecure Socket Layer (SSL) technology. We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.
Disclosure of Personal Information Overseas
IFG may need to disclose information to our internal operations overseas or to service providers located overseas which provide services to IFG on IFG’s behalf. When your personal information is disclosed overseas, IFG is required to ensure that the information is treated in accordance with the policies and standards that apply in your account’s country of origin.
Managing and Accessing Personal Information
IFG takes every precaution to protect your personal information that has been collected from you or from outside sources. The information is protected from misuse, loss or access by unauthorized individuals or entities. Information is stored in paper form and electronically with appropriate security.
If your personal information should change, notify IFG immediately with the correct information. IFG will also ensure to the best of our ability that information that we retain is correct and current. If you deem that personal information that we maintain is incorrect, please notify us immediately so that we may take corrective action to ensure information is correct and current. In the event that we do not agree that information is inaccurate or out of date we will notify you in writing providing information on why we do not agree and will provide information on what you can do if dissatisfied with the response.
You may contact IFG to request information of what data has been collected and retained by us. Upon request, we will provide any copies of information that are held by us.
If you request a copy in a particular form (for example, in hard copy) we will, free of charge, take reasonable steps to give you a copy in that form. The latest version of our GPDS is available on our website.
The GPDS contains information about how you may access personal information about you, which we hold and seek the correction of that information. The GPDS also contains information about how you may complain about a legal breach, and how we will deal with the complaint.
The GPDS includes our policy about the management of credit information and credit eligibility information. It contains information about how you may access the credit eligibility information about you that we hold; how you may seek the correction of credit information or credit eligibility information about you that we hold; how you may complain about our failure to comply with any legal requirements for Privacy Protection; and how we will deal with such a complaint.
IFG does not generally report information to credit reporting agencies. However, IFG does request credit reports from various credit reporting agencies and uses this information for determination of creditworthiness. In requesting reports from a credit reporting agency, IFG will use personal information to identify you and possibly information from your application. If you are a guarantor, we may use information from a credit reporting agency to assess your ability to qualify as a guarantor.
Do we use ‘cookies’?
- Understand and save user’s preferences for future visits.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, some of the features that make your site experience more efficient may not function properly.
Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. Click here
We have not enabled Google AdSense on our site but we may do so in the future.
Notification of changes
If we change this GPDS we will post the amended Policy on our website so that you are always aware of how we collect, use and disclose your personal information.
In the event you believe that your privacy has been compromised, that IFG has not acted in protecting information or has not complied with the relevant privacy regulations, please contact us immediately so that the issue is resolved as quickly as possible. We will investigate your concern and where necessary will consult with others, such as a credit reporting agency. IFG will respond in writing with the results from our investigation and/or may provide information to you regarding outside dispute resolution.
If your concern is not satisfactorily resolved, you may contact the appropriate legal entity in your country for further assistance.
We can be contacted by e-mail at firstname.lastname@example.org or by phone through the main 800 # listed on your country specific site. You can also mail a letter directly to one of offices listed below to the attention of the IFG Privacy Office.
United States of America HQ
7910 Woodmont Avenue Suite 1050
Bethesda, MD 20814
8901 Woodbine Avenue,
Suite 207 Markham, ON L3R 9Y4
Level 32, 8 Exhibition Street
Melbourne VIC 3000
New Zealand HQ
PO Box 5427,
Wellesley Street Auckland 1141,
United Kingdom HQ
Riverside Business Centre,
Riverside House River Lawn Road Ton bridge Kent TN9 1EP
30 Upper Pembroke Street
Dublin 2, Ireland
Addendum – USA
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
- Within 7 business days
We will notify the users via in-site notification
- Within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CAN-SPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email, and we will promptly remove you from ALL correspondence.
According to California Online Privacy Protection Act, we agree to the following: Users can visit our site anonymously as long as they do not register for an account.
How does our site handle Do Not Track signals?
We will honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place when we can.
Does our site allow third-party behavioral tracking?
It’s also important to note that we do allow third-party behavioral tracking
COPPA (Children Online Privacy Protection Act) does not apply to IFG:
We do not collect information from children under the age of 13 years old or share such information with any third parties
Addendum – Canada
IFG follows all PIPA requirements as mandated by each province or territory.
To request your own personal information under PIPA, you must make the request in writing to our Privacy Office. The contact information has been listed at the bottom of this document.
Please keep in mind that information requested may be withheld if it meets any of the criteria below, as per PIPA requirements:
- information that could threaten the life or security of another individual
- information that would reveal personal information about another individual
- information that would reveal the identity of someone who provided an opinion about another individual in confidence, when that person does not consent to revealing their identity.
Addendum – European Union
The General Data Protection Regulation is an EU regulation that expands the protection of personal data of citizens in the European Economic Area (“EEA”).
Legal bases for processing
If you are an individual in the EEA, we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the financial services offered by IFG you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the financial services we offer, including to operate and process such services, provide customer support, personalize your experiences and protect the safety and security of the services;
- It satisfies our legitimate business interest (which is not overridden by your data protection interests), such as to improve our website to better serve you, to correspond with you regarding our order or other products and services and to follow up with you after any correspondence, to market and promote our services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data for legal reasons to comply with government laws and regulations.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the services we provide.
How long will the data be stored?
We will keep your personal data for as long as necessary for the purposes for which it was collected and to provide you with services, to conduct our legitimate business interests, resolve current disputes, for the establishment of defense of potential disputes, to enforce our agreements or where otherwise required by law. We will retain your data for the lifetime of your account with us and for a period thereafter within the confines of the applicable laws. After such time, the personal data will be blocked or erased in accordance with legal requirements.
International transfers of information we collect
Information you submit to us via the registration form on our website will be stored and processed in the United States through Amazon Web Services (“AWS”) and other third-party service providers. Because your personal information will be transferred to the U.S. which is not subject to an adequacy decision by the European Commission, we take steps to protect it. To support these transfers, we rely on the self-certification by AWS and, if applicable, our other third-party service providers of compliance with the EU-U.S. Privacy Shield as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU to the United States and other appropriate legal mechanisms to safeguard the transfer including EU approved standard contractual data protection clauses. We also rely on derogations for specific situations as set forth in Article 49 of the General Data Protection Regulation. When relying on derogations, we collect and transfer to the U.S. personal data only with your consent, to perform a contract with you, or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
We provide you the opportunity to opt-out of having your information used for certain purposes or to unsubscribe from receiving future emails, when we ask for the information. If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email, and we will promptly remove you from ALL correspondence.
Your rights in relation to personal information and how to exercise them under certain circumstances EEA users have the following rights:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific reasons, including legal reasons or in connection with current or potential legal claims, which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your data protection interests.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us. For more information about how to contact us, see “Managing and Accessing Personal Information” and “Contact Information” in this GPDS.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Addendum – Australia
IFG Network Australia Pty Ltd (“we”, “us”, “our”) collects personal information about you for the purposes you agree to in this Privacy Disclosure and Consent. When you sign below, you agree we can, consistent with Australia’s privacy and credit reporting laws, collect, use and disclose personal information about you for those purposes, including information in connection with a Credit Reporting Body (“CRB”).*
*A CRB can disclose any credit reporting information, other than repayment history information and credit reporting information which is derived from repayment history information, to us, at our request, for a commercial credit related purpose.
If you consent to the disclosure of personal information (other than credit eligibility information) to a person (other than a CRB) who is not in Australia, sub-clause 8.1 of Schedule 1 to the relevant privacy regulations will not apply to the disclosure, and you will be deemed as consented to that disclosure.