Privacy Policy
Last updated: March 3, 2025
Your privacy and trust are important to us, and so is being clear about how we collect, use, and disclose information about you.
This Privacy Policy is provided on behalf of Clay Financial Inc. and its affiliates (“Clay”, “we” or “us”) in connection with your use of our website and our web application (collectively, the “Platform”). It applies to our website, our products and services available through our web application and any other interactions we have with our customers, both current and prospective.
This Privacy Policy will continue to apply for as long as we hold your information, including after the termination of any of your products or services with us. By providing us with your personal information, you are consenting to the collection, use and sharing of your personal information as set out in this Privacy Policy.
If we change our privacy practices, we will update this Privacy Policy. If you have an account with us, we will notify you via email if we consider any such changes to be significant.
What personal information we collect
Information automatically collected through your use of the Platform
When you use our Platform, we automatically gather information to improve your experience and enhance our services. This includes technical details about your device, such as your IP address, browser type, operating system and the pages you visit. We use tools like Google Analytics to collect data on user interactions. Google Analytics helps us understand how users navigate our website, the pages they view and their actions, encompassing details such as time spent on each page, links clicked and general browsing patterns.
Our use of cookies and similar technologies is also part of this data collection process. These technologies store small pieces of data on your device, aiding in tracking preferences and activities. They play a significant role in understanding user behavior, enhancing our services, and tailoring your experience on the Platform.
You have the ability to manage your cookie settings in your browser to accept or decline cookies. Additionally, you can opt out of Google Analytics by using the Google Analytics opt-out browser add-on from Google, available for Chrome, Safari, Firefox, and Microsoft Edge browsers. This add-on allows users to prevent their data from being used by Google Analytics when accessing websites.
The information gathered automatically serves internal purposes, enabling us to maintain, improve functionality, analyze usage patterns, and enhance user experiences within our Platform.
Personal information you provide us that enables you to use our services
When you create an account on our Platform, you voluntarily share essential information such as your name and email address. This data allows you to access and use various features on the Platform.
When you apply for a Home Equity Sharing Agreement (“HESA”) with us, you provide more detailed personal information about yourself and your home. This includes biographical information, property information, employment information and financial information.
Biographical information includes your name, email address and phone number.
Property information includes your home’s address, the identities of any co-owners, bills and statements relating to the property and information that you certify as being true regarding the property, such as that it is your principal residence.
Employment information includes your employment status and, if you are employed, the identity of your employer, the title of your role and your salary.
Financial information includes your annual income, documents you may provide to prove your income, direct deposit information and details of any debts or guarantees secured by your home, such as the lender, balance, limit, interest rate, payment amount and term.
If you have a HESA with us, you will provide further personal information over the lifetime of the HESA, such as property information pertaining to bills, renovations and services as well as financial information about any debts or guarantees secured against your property and other information we may collect in our annual questionnaire to monitor compliance with the agreement.
If you contact us with a question, comment or complaint, you may be asked for information that identifies you (such as your name, address or phone number), along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may record the conversation or retain this information to assist you in the future and to improve our customer service and offerings.
Personal information we collect from third parties
We collaborate with various trusted third-party providers to enhance our underwriting processes. These partnerships allow us to collect specific information critical for evaluating eligibility and assessing financial standing when applying for our services.
We use Didit to verify your identity during the HESA application processes. To confirm your identity and prevent fraud, we collect details provided by you, such as a copy of your government-issued photo identification (your “ID”), the details contained on your ID and a picture of you (a “selfie”). These details aid in confirming your identity and preventing fraud on our Platform. For more information on Didit’s security practices, you can review their security statement here.
We use Stripe for secure payment processing of certain expenses in select circumstances. As a PCI Level 1 certified provider, Stripe maintains the highest standards in payment security within the industry. While Stripe directly collects your credit card details, we do not have access to your complete card number or your card’s verification code. We may receive certain associated personal information to validate payment authenticity and ensure smooth transaction processing. Your information remains securely managed within Stripe’s system. To learn more about Stripe’s comprehensive security policies, you can refer to their security statement here.
During the application for our HESA, you may authorize us to obtain information from credit-reporting agencies in Canada. This data assists us in evaluating your financial standing and is used solely for underwriting your application. We may collect this information indirectly from credit-reporting agencies using service providers.
If you have applied for a HESA or have a HESA, we may receive information about your property from appraisers, home inspectors and similar professionals that we have arranged to visit your home in connection with our underwriting and servicing of your HESA. This information may contain valuations and details regarding the condition of your home, including images of the exterior and interior of your home. We collect this information directly from any professionals retained by us to provide such services. Except for valuations, we do not store this information on the Platform.
How we use your personal information
In addition to the purposes communicated before or at the time of collection, the personal information that we collect is used to provide you with tailored information about our products and services, open and service your account, verify your identity and other information that you provide to us, underwrite your application for any of our products and services, originate and deliver products that you have requested, service your products over their terms, provide services, manage risk, detect and prevent fraud and other illegal activities, personalize your experience on our Platform, anonymize your information for the purpose of analytics and reporting, meet legal and regulatory requirements, and as otherwise required or permitted by applicable law.
Automated decision-making
We may use automated decision-making systems to process your personal information. We may rely on decisions made by these systems when providing you with our products and services (e.g., verifying your identity, assessing risk or creditworthiness), providing customer service (e.g., using AI-powered chatbots) and detecting and preventing fraud or other illegal activities. You can contact us at the address listed at the end of this Privacy Policy about our use of these systems, including challenging a decision made about you.
Where we send your personal information
We do not sell your personal information.
In the course of providing our services and ensuring the functionality of our Platform, your data may be transferred or shared with various recipients or service providers, as outlined below.
Internal: Your personal information is securely transmitted and accessed within our internal systems, solely for the purposes of providing and improving our services. Access to this data is restricted to authorized personnel who are bound by confidentiality obligations.
Affiliates: Some personal information may be shared with our affiliates, such as our asset management arm, for the purpose of underwriting, originating and servicing the products that you have with us. Access to this data is restricted to authorized personnel who are bound by confidentiality obligations.
Third-party service providers: We may transfer your personal information to trusted third-party service providers who provide various services on our behalf such as identity verification, technology, administration, payment processing, printing, marketing and advertising, hosting, data analysis, legal and accounting.
Partners: We may share some personal information with partners that have referred you to us, such as your financial planner, mortgage broker, real estate agent or investment advisor, if we have a referral agreement with them. This information is limited to only those details required to identify their referral (e.g., name, date) and its status.
Legal: In certain circumstances, your personal information may be shared in response to legal obligations (e.g., in response to a search warrant or other valid legal processes), enforcing our rights or protecting against security threats, fraud or harm to our users, us or our affiliates.
How we protect your personal information
Safeguarding your personal information is a priority for us. We employ robust security measures and adhere to industry-standard practices to ensure the confidentiality, integrity, and availability of your data.
Encryption and secure transmission: Your data is transmitted securely using encryption protocols, such as Transport Layer Security (“TLS”), when you interact with our Platform. This encryption safeguards your information during transmission (between your browser and our server as well as between our server and those of any service providers), preventing unauthorized access or interception.
Secure data storage: We store your information using secure servers and employ industry-standard measures, including AES-256 encryption, to protect data at rest on our Platform and in our internal systems. Our servers are hosted on trusted platforms with comprehensive security certifications and standards.
Data segregation: Certain sensitive data, such as your credit report and images of your home provided by appraisers or home inspectors, are deliberately kept separate from our Platform. These confidential records reside securely within our internal systems, completely separate from our external-facing Platform. This practice ensures that highly sensitive information remains segregated, reducing exposure and further protecting against unauthorized access.
Access control: Access to your personal information is strictly restricted to authorized personnel who require access as part of their roles. We implement stringent access controls to prevent unauthorized access to our systems and databases.
Data minimization and retention: We adhere to data minimization principles, collecting only the information necessary for providing our services. We similarly only share the minimum data required with our service providers in order for them to provide their services. We retain personal information for the duration required to fulfill the purposes outlined in our Privacy Policy, to perform our contractual obligation to you and to meet other legal obligations.
Third-party security standards: When engaging third-party service providers, we rigorously assess their security practices to ensure they comply with industry-leading security standards and certifications, such as PCI DSS for payment processing. Our service providers receive only the information required to perform their designated functions and are committed to maintaining your confidentiality. Our service providers are not permitted to use your information for any unauthorized purpose. Your personal information may be maintained and processed by third-party service providers outside of Canada in the United States or other foreign jurisdictions. In the event personal information is transferred to the United States or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with the laws of those jurisdictions.
Password policy: We require all accounts on our Platform to adhere to our password policy requiring all passwords to be at least 12 characters and contain at least one capital letter and one number.
Steps you can take to protect your personal information
Alongside our commitment to safeguarding your data, there are measures you can take to further protect your personal information on our Platform. These recommended steps serve as proactive measures to enhance the security of your account and data. By following these guidelines, you can actively contribute to maintaining the confidentiality and integrity of your information.
Strong password: Create a robust password by combining letters, numbers and special characters. Avoid using easily guessable information like birthdays or names. Never share your password with anyone.
Software updates: Keep your software, including browsers and operating systems, up-to-date to benefit from the latest security patches.
Caution with links: Be wary of suspicious links or emails, especially those requesting sensitive information. Verify the authenticity of emails before clicking on links.
Public Wi-Fi awareness: Avoid sharing personal data when connected to public Wi-Fi networks. Wait until you are able to connect using a secure, private connection.
Limit access: Do not allow other people to use your computer, phone or browser.
Log out: If you are accessing the Platform on a shared device, log out of your account when you have finished.
Your rights over information
Individuals have the right to access, update and correct personal information in our custody and control, subject to certain exceptions prescribed by law. You may update certain profile information you have provided to us by logging in to your account and clicking “Profile”. Otherwise, if you wish to request access, updating and corrections of inaccuracies in personal information in our possession or control, you may send a written request to this effect to privacy@clay.financial. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
Marketing communications
From time to time, we may send you email, text messages and other communications about our products, services or events that may be of interest to you if you have opted to receive commercial electronic messages from us. You can opt-out of receiving such marketing and promotional communications from us by following the unsubscribe instructions contained in any such communication. Please note that you will continue to receive transactional emails regarding your account and transactions with us. Alternatively, you can unsubscribe from any of our marketing communications by contacting us at hello@clay.financial.
Contact us
Our Chief Legal Officer is responsible for ensuring that we adhere to our Privacy Policy. If you would like to make a request, file a complaint or ask a question about how we process your personal information, please contact our privacy team via email at privacy@clay.financial or via mail at:
Clay Financial Inc.
Attn: Chief Legal Officer
507 King Street East
Toronto, ON M5A 1M3