PRIVACY POLICY

easyhome Ltd., its affiliated companies easyfinancial Services Inc., RTO Asset Management Inc. and easyhome U.S. Ltd., and its and their franchisees (“easyhome”, “we”, “us” or “our”), have provided this Privacy Policy to describe our personal information handling practices, and to assure you of our continuing commitment to protect all personal information that we handle in the course of commercial activities. "Personal information", as used in this Policy, means information about an identifiable individual, but does not include an individual’s business contact information.

Purposes for Which easyhome Handles Personal Information

easyhome collects and uses personal information for purposes limited to those which are related to its businesses, which include providing household furnishings, appliances, and home electronic products to its customers under lease agreements, staging services, and financial services. We collect personal information primarily from you, for instance through applications and supporting information and documentation you provide. We may also collect personal information about you through your ongoing interactions with us, from references, employers and other financial institutions you have identified in your application as well as credit bureaus and other third party sources. For example, we may collect personal information from credit bureaus for the purposes of locating you to collect outstanding debts. In connection with loan agreements, we may also collect personal information from credit bureaus in order to verify your current and ongoing creditworthiness and other information you may provide to us.

We may collect personal information for purposes such as the following:

• To manage and promote the business activities of easyhome;
• To verify identity and other information provided by customers and to determine eligibility for products and services;
• To open, administer and service accounts and loans and to provide and administer any requested products or services;
• To evaluate current and ongoing creditworthiness and other requirements and to determine their eligibility or suitability for products or services offered by easyhome;
• To advertise, market and promote easyhome’s products and services to customers who have not opted out of such communications, including by mail, email and telephone and including by using automatic dialling and announcing devices;
• To establish relationships, provide quality service to and communicate with customers;
• To collect outstanding debts;
• To protect the business interests of easyhome and its customers, including to detect and prevent fraud and other unauthorized or illegal activities; and
• To maintain business records for reasonable periods to meet legal and regulatory records retention requirements; and
• For other purpose with your consent or as permitted or required by law.

Personal Information easyhome Collects

easyhome limits the amount and type of personal information collected to that which is necessary for our identified purposes, and we collect personal information by fair and lawful means.

Personal information that we collect includes:

• Customer name and contact information, including mailing address, telephone number, fax number and/or email address;
• Additional information for identity matching and credit check purposes, such as occupation, name of employer, names and contact information for references, assets, liabilities, income, previous address, number of dependents, Social Insurance Number (if provided), date of birth or driver’s license number;
• Information about the account or loan, such as current and historical account or loan information, balance and indebtedness, account transaction history and similar information, and records relating to the handling of any inquiries or complaints;
• Payment-related information, such as banking information; and
• such other information we may collect with your consent or as permitted or required by law.

Transfers and Disclosures of Personal Information

easyhome may disclose personal information in a number of circumstances, including:

• To credit bureaus, credit reporting agencies and to your current or future creditors for the purpose of maintaining your credit history and providing credit references;
• To financial institutions for payment processing purposes;
• To third parties as reasonably necessary:
  • to enforce your contracts with us and otherwise for the collection or payment of a debt owed to us;
  • for the purposes of detecting and preventing fraud;
  • in connection with audits;
  • for the purposes of meeting legal, regulatory, industry self-regulatory, risk management and security requirements;
• Unless you have opted out, to affiliates of easyhome to enable them to offer you additional products and services;
• Unless you have opted out, to easyhome’s insurance partners so that they may offer insurance products and services that may be of interest to you; and
• For other purposes with your consent or as permitted or required by law.

In addition to the above, personal information may be shared between easyhome affiliates (including affiliates located in the United States) for internal audit, management, billing or administrative purposes including defending and bringing legal actions.

In the course of fulfilling the purposes described above, easyhome may transfer your personal information to service providers, including affiliates or other third party organizations or individuals retained by easyhome to perform functions on its behalf, such as marketing, data processing, customer service, office, security, collections, insurance, financial and taxation services. When personal information is transferred to service providers, we use contractual or other means to ensure that a comparable level of protection is provided. Some of our service providers may be located in the United States and will be subject to applicable legal requirements in that country including lawful requirements to disclose personal information to government authorities in certain circumstances.

easyhome may also use and disclose personal information in connection with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of easyhome or our business or assets (including your loan or lease and any agreement to which it relates), for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of easyhome or our business or assets may use and disclose your personal information for similar purposes as those described in this Policy.

easyhome may disclose your personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law.

Safeguards

easyhome uses safeguards and other security standards to ensure that all personal information in its custody and control is protected against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. Safeguards will vary depending on the sensitivity, format, location, and storage of the personal information. Authorized employees, agents and mandataries of easyhome who require access to personal information to fulfill their job requirements will have access to personal information.

Access and Accuracy

easyhome may establish and maintain a file containing an individual’s personal information for the purposes described above, which will be accessible at our offices. Individuals have the right to request to access to or correction of their personal information that is held by easyhome. Requests must be made in writing, addressed to easyhome’s Privacy Officer. We will respond to written request within a reasonable time (generally within 30 days). Provision of copies of records containing personal information may be subject to a fee. We will use our best efforts to ensure that personal information is accurate, complete, and up-to-date. If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information as required. If we refuse access to personal information or disagree with an assertion that information held by us is incorrect, easyhome will provide a written explanation for such refusal. An individual’s right to request access to or correction of their personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.

easyhome’s Websites and E-Mail Communication

easyhome does not guarantee the confidentiality of any communications made by you via e-mail or otherwise through our websites. If you wish to provide information of a confidential or sensitive nature to easyhome, please contact us directly by telephone to arrange for delivery/transmission of such information by secure means.

We use cookies and other tracking technologies to improve your experience on our websites, to facilitate the online application process and for internal research and reporting purposes. A "cookie" is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences, such as your IP address and the pages of the website that you visit. You can set your browser to notify you when you receive a cookie or to refuse cookies altogether. However, if you refuse cookies, you may not be able to use certain features of our websites.

The easyhome websites may contain links to other websites of interest. These other website are not governed by our privacy policy and we are not responsible for any personal information which you provide while visiting other websites. We encourage you to read the privacy policy of every website you visit.

Consent

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express or implied. You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. By submitting personal information to easyhome or its service providers and agents, you consent to the collection, use and disclosure of such personal information as described in this Privacy Policy or otherwise at the time of collection. If you provide easyhome or our service providers and agents with personal information of another individual, you will be deemed by easyhome to have obtained consent from such person to enable us to collect, use and disclose such information for the purposes set forth in this Privacy Policy. Subject to legal or contractual requirements and reasonable notice, you may withdraw your consent at any time by contacting easyhome’s Privacy Officer. If you withdraw your consent, we may be limited or unable to provide you with certain services or information.

In certain circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual. These circumstances include but are not limited to: personal information that is publicly available as defined by regulation; where collection is clearly in the interests of the individual and consent cannot be obtained in a timely way; where disclosure is made for the purposes of collecting a debt owed to us; or to comply with a subpoena, warrant or court order.

Inquires or Further Information

easyhome has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. Any questions related to the Policy or the handling of personal information by easyhome can be addressed to the Privacy Officer who may be contacted at:

Privacy Officer, easyhome Ltd.,

33 City Centre Drive, Suite 510, Mississauga, Ontario, L5B 2N5, Canada

If you are not satisfied with easyhome’s response to a privacy-related matter, you may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or at www.privcom.gc.ca. easyhome reserves the right to modify this Privacy Policy at any time. If we make a change to this Policy, we will post such changes on our website (www.easyhome.ca) and make the revised Policy and changes available upon request to easyhome’s Privacy Officer.