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Privacy Policy

Last updated: September 29, 2025

Wellbeing Financial Corp. ("Wellbeing Financial", "WBF", "we", "us", "our") provides a consumer fintech application (the "Service") that helps Canadians understand and compare mortgage and credit options. We are accountable for personal information in our control under the Personal Information Protection and Electronic Documents Act (PIPEDA).

We respect your privacy and are committed to protecting it. This Policy explains what we collect, how we use and share it, how we safeguard it, and the choices and rights you have.

1. Who we are & how to contact us

Controller: Wellbeing Financial Corp.

Mailing address: 91 Trail Boulevard, Springwater, Ontario, Canada

Privacy Officer: privacy@wellbeingfinancial.ai

General contact: Coming Soon

If you are not satisfied with our response to a privacy question or complaint, you may contact the Office of the Privacy Commissioner of Canada (OPC):

Website: https://www.priv.gc.ca | Phone: 1-800-282-1376
Mail: 30 Victoria Street, Gatineau, QC J8X 0A1

2. Scope

This Policy covers personal information we collect through our mobile/web applications, websites, and customer support channels. It does not cover third-party websites or services that have their own privacy policies (including licensed brokerages you choose to engage).

3. What we collect & why (data minimization)

We collect only what we need for specific purposes. Examples below are illustrative—not exhaustive.

Category
Examples
Purpose (why)
Legal basis
Identity & Contact
Name, email, phone, address, province
Create/manage your account; secure access; communicate service notices
Your consent when you sign up
Profile Inputs
Mortgage/loan/credit details; property info; preferences; stated income/employment
Generate educational comparisons and opportunity scores; personalize your experience
Your consent when you input data
Document Uploads
PDFs/images of statements, offers, pay stubs, T4s/NOAs, IDs (if provided)
Extract key fields (rate, balance, term, payments) via OCR/AI to reduce data entry burden
Your consent when you upload files
Bank-link Data
Account and transaction data via an open-banking/aggregator provider
Automate and keep financial data current (if you connect)
Your consent when you connect
Device & Usage
IP, device/OS, app events, crash logs, cookie IDs
Security/fraud prevention; diagnostics; product improvement
Implied consent; legitimate interests under PIPEDA

We do not sell personal information.

4. Automated scoring & AI use (agentic framework)

Our Service may generate automated, educational scores (e.g., an "opportunity score" on a 0–900 scale) and comparisons based on your inputs and market data. These outputs help you understand potential opportunities and are not mortgage advice. A licensed mortgage professional must provide suitability advice.

Your options: You can request a human review of any automated assessment or explanation by contacting privacy@wellbeingfinancial.ai. You can choose not to upload documents or not to connect bank accounts (some features may be limited).

5. How we use personal information (purposes)

6. When we share information

We share personal information only as needed, under contracts that require confidentiality, security, and limited use:

Service providers (processors):

At your request:

With a licensed mortgage brokerage/agent you choose for advice and application processing (separate controller with its own policy).

Legal/dispute/security:

As required by law or to protect rights, safety, or security.

Corporate transactions:

In diligence or completion of a financing/M&A, with measures to safeguard confidentiality.

We do not allow providers to use your information for their own marketing.

7. Cross-border transfers

We may process/store personal information outside Canada (e.g., the United States) using reputable providers. Contractual safeguards require comparable protection, but foreign laws may permit access by courts, law enforcement, or national security authorities. By using the Service, you consent to these transfers.

8. Retention (specific timelines)

We retain personal information only as long as necessary for the purposes set out here, then securely delete or de-identify it.

Data type
Retention
Account profile (identity/contact)
Life of account + 24 months (audit/legal)
Uploaded documents (original files)
Deleted within 30–90 days after successful field extraction (retain extracted fields per below)
Extracted financial fields
Life of account + 24 months
Bank-link tokens/records
While connection is active; deleted within 30 days of disconnection
Device logs & analytics
12–24 months
Support tickets & chats
24 months
Marketing consent records
While subscribed + 24 months after unsubscribe (compliance)

You may request deletion sooner (subject to legal obligations).

9. Your choices & rights

Under PIPEDA, you have the right to:

How to exercise: Email privacy@wellbeingfinancial.ai. We respond within 30 days unless a permitted extension is required (we'll notify you).

10. CASL (email/SMS) compliance

We send commercial electronic messages only with express consent (or valid implied consent) and include our identity and a functioning unsubscribe mechanism in every message. You can opt out anytime; service-essential communications (security, legal, account) may still be sent.

11. Security

We employ administrative, technical, and physical safeguards appropriate to the sensitivity of your data, including:

No method is 100% secure, but we continuously improve our controls. If we discover a breach creating a real risk of significant harm, we will notify affected individuals and regulators as required by law.

12. Children's privacy

The Service is intended for individuals 13+. We do not knowingly collect personal information from children under 13. If you believe a child has provided data, contact us to delete it.

13. Cookies & similar technologies

We use cookies, SDKs, and similar technologies for core functionality (e.g., sign-in, session management) and analytics. You may adjust browser or device settings to limit cookies; some features may not function properly without them.

14. Third-party links

The Service may link to third-party sites or services. Their privacy practices are governed by their policies, not this one. Review those policies before providing personal information.

15. Changes to this Policy

We may update this Policy to reflect changes in practices or law. We will post the updated date at the top and provide prominent notice for material changes (e.g., in-app banner or email). Continued use after the effective date means you accept the changes.

16. Contact & complaints

Privacy Officer — Wellbeing Financial Corp.

privacy@wellbeingfinancial.ai | 91 Trail Boulevard, Springwater, Ontario, Canada

If we do not resolve your concern, you may contact the Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca | 1-800-282-1376.

Appendix A — Referral to Licensed Brokerages (Transparency)

When you ask us to connect you to a licensed mortgage professional, we will share your contact and relevant profile information with the brokerage/agent you select. They operate under provincial licensing (e.g., FSRA in Ontario) and have their own privacy policy. If a referral fee is payable between entities, you will receive the disclosures required by provincial rules (identity of payer/recipient and how the fee is calculated). WBF does not provide mortgage advice; our outputs are educational.