Consumer Data Collection and Use Policy
SLATE FINANCIAL TECHNOLOGIES INC.
CONSUMER DATA COLLECTION AND USE POLICY
Effective Date: February 6, 2026
Last Updated: February 6, 2026
Important Notice
This Consumer Data Collection and Use Policy (“Policy”) explains how Slate Financial Technologies Inc. (“Slate,” “we,” “us,” or “our”) collects, uses, and discloses your personal information when you apply for and use our future earnings purchase services. This Policy is provided in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws, including the British Columbia Personal Information Protection Act (PIPA).
By submitting an application or using our services, you acknowledge that you have read, understood, and consent to the practices described in this Policy.
This Policy applies specifically to individual workers (“Workers”) who apply for or enter into Future Earnings Purchase Agreements (“FEPAs”) with Slate. If you are a business applying for receivables purchase services (Merchant Cash Advance), please refer to our Data Collection and Use Policy at /data-collection.
Nature of Our Services
Slate provides future earnings purchase services, not loans. When you use our services, you sell a portion of your future Platform Earnings to Slate in exchange for an immediate, upfront payment. This is a true sale of future earnings, not a debt or loan.
The terminology in this Policy (such as “underwriting” and “risk assessment”) refers to our evaluation of the quality and collectability of your future Platform Earnings, not creditworthiness for lending purposes. You are not borrowing money or incurring debt — you are selling future earnings at a discount.
1. Information We Collect
We collect the following categories of personal information in connection with your application and our ongoing services:
1.1 Identity Information
- Full legal name
- Date of birth
- Social Insurance Number (SIN)
- Government-issued photo identification (e.g., driver’s licence, passport)
- Biometric or liveness verification data (facial images captured during identity verification)
- Current residential address
- Email address
- Phone number
1.2 Financial Information
- Personal bank account details (institution, transit number, account number)
- Bank account transaction history (to assess income patterns and cash flow)
- Credit report and credit score from Canadian credit bureaus (TransUnion, Equifax)
- Existing debts, consumer proposals, or bankruptcy history
1.3 Platform Earnings Information
- Platform Partner identity and your account status
- Historical Platform Earnings (amounts, frequency, and duration)
- Work history and earnings history on the Platform Partner’s platform
- Platform ratings, reviews, or performance metrics (where available and relevant to earnings assessment)
- Projected future Platform Earnings
1.4 Transaction Information
- FEPA terms (Purchase Price, Purchased Amount, Factor Rate, Remittance Amount)
- Remittance payment history (PAD transactions, Direct Remittance records)
- Returned payment records
- Earnings Decline Adjustment requests and outcomes
- Communication records between you and Slate
1.5 Device and Usage Information
- IP address and approximate geolocation
- Browser type and operating system
- Device identifiers
- Pages visited on the Slate Platform and actions taken
- Date and time of access
2. How We Collect Your Information
We collect your personal information through the following methods:
- Directly from you: When you complete an application form, submit documents, communicate with us, or interact with the Slate Platform.
- From your Platform Partner: With your consent, we receive Platform Earnings data, work history, and account information from your Platform Partner to assess your eligibility and administer your FEPA.
- From credit bureaus: With your authorization, we obtain your credit report and credit score from TransUnion Canada and/or Equifax Canada.
- From identity verification providers: We use third-party identity verification services (currently Veriff) to verify your identity in compliance with PCMLTFA requirements.
- From your financial institution: With your consent, we may access bank account information and transaction history through secure banking integrations.
- Automatically: Through cookies, analytics tools, and similar technologies when you use the Slate Platform.
3. How We Use Your Information
We use your personal information for the following purposes:
3.1 Application Assessment and Underwriting
- Verifying your identity in compliance with PCMLTFA and FINTRAC requirements
- Assessing the quality, reliability, and collectability of your future Platform Earnings
- Evaluating your overall financial profile and creditworthiness for the purpose of assessing earnings risk
- Determining eligibility, Purchase Price, Factor Rate, and Remittance Amount
- Making approval or decline decisions on your application
3.2 FEPA Administration and Servicing
- Processing PAD collections and Direct Remittances
- Monitoring remittance performance and managing returned payments
- Processing Earnings Decline Adjustment requests
- Communicating with you about your FEPA status, upcoming payments, and account activity
- Enforcing the terms of the FEPA in the event of a breach
3.3 Regulatory Compliance
- Fulfilling our obligations under the PCMLTFA, including record-keeping and suspicious transaction reporting to FINTRAC
- Complying with credit bureau reporting obligations
- Responding to lawful requests from law enforcement or regulatory authorities
- Maintaining records as required by applicable tax laws
3.4 Risk Management and Improvement
- Monitoring portfolio performance and risk across our FEPA portfolio
- Improving our underwriting models and risk assessment processes
- Detecting and preventing fraud, identity theft, and financial crime
- Improving the Slate Platform, user experience, and service offerings
4. How We Share Your Information
We may share your personal information with the following parties, for the purposes described:
4.1 Platform Partners
We share limited information with your Platform Partner as necessary to administer your FEPA, including activating and managing Direct Remittance arrangements. We do not share your credit report, SIN, or banking details with Platform Partners.
4.2 Credit Bureaus
We share information about your FEPA and remittance history with TransUnion Canada and/or Equifax Canada, as authorized by you in the Credit Check Authorization Terms. This may include information about your account status, payment history, and any Events of Breach.
4.3 Service Providers
We use trusted third-party service providers who process personal information on our behalf, including:
- Identity verification: Veriff (identity document and biometric verification)
- Payment processing: ZumRails (PAD processing and bank verification)
- Electronic signatures: HelloSign (FEPA execution)
- Cloud hosting: Secure cloud infrastructure providers for data storage
- Analytics: Platform usage analytics tools
All service providers are contractually obligated to protect your information and use it only for the purposes we specify.
4.4 Affiliated Entities
Slate is a wholly owned subsidiary of Dropp Labs, Inc., a Delaware corporation. We may share personal information with Dropp Labs for corporate administration, financial reporting, and risk management purposes. When information is transferred to the United States, it is subject to U.S. laws, which may differ from Canadian privacy laws. We implement contractual protections to safeguard your information in such transfers.
4.5 Legal and Regulatory Authorities
We may disclose your personal information when required by law, in response to a valid court order, subpoena, or regulatory request, or to comply with our obligations under the PCMLTFA, tax laws, or other applicable legislation.
4.6 With Your Consent
We may share your personal information with other parties if you provide specific, informed consent for such disclosure.
5. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes described in this Policy, including:
- Active FEPAs: For the duration of any active FEPA, plus a reasonable period for account administration.
- Completed FEPAs: For a minimum of five (5) years after the completion or termination of the FEPA, to comply with FINTRAC record-keeping requirements and for legal and audit purposes.
- Declined applications: For a minimum of five (5) years to comply with regulatory requirements.
- Credit reports: Retained for the duration of the FEPA plus the legally required retention period.
- Identity verification records: Retained for a minimum of five (5) years in compliance with PCMLTFA.
After the applicable retention period, your personal information will be securely destroyed or de-identified.
6. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of personal information in transit and at rest
- Access controls limiting who within Slate can view your personal information
- Secure authentication and authorization mechanisms
- Regular security assessments and vulnerability monitoring
- Employee and contractor training on data protection and privacy
- Incident response procedures for potential data breaches
While we take reasonable precautions to protect your information, no method of electronic transmission or storage is completely secure. If you become aware of a potential security issue, please contact us immediately at admin@tryslatehq.com.
7. Your Rights
Under PIPEDA and applicable provincial privacy legislation, you have the following rights regarding your personal information:
7.1 Right of Access
You have the right to request access to the personal information we hold about you. We will respond to your request within thirty (30) days.
7.2 Right of Correction
You have the right to request correction of any inaccurate or incomplete personal information we hold about you.
7.3 Right to Withdraw Consent
You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions. Please note that withdrawing consent may result in Slate being unable to continue providing services to you, including the administration of an active FEPA.
7.4 Right to Complain
If you believe your privacy rights have been violated, you have the right to file a complaint with:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: www.priv.gc.ca
In British Columbia, you may also file a complaint with the Office of the Information and Privacy Commissioner for British Columbia (OIPC BC).
8. Cookies and Tracking Technologies
The Slate Platform uses cookies and similar technologies to improve your experience, analyze usage, and provide our services. For details on the types of cookies we use and how to manage your cookie preferences, please refer to our Privacy Policy at /privacy.
9. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. If we make material changes, we will notify you by email or through the Slate Platform at least thirty (30) days before the changes take effect. The “Effective Date” at the top of this document indicates when this Policy was last revised.
10. Contact Information
If you have questions, concerns, or requests regarding this Policy or how we handle your personal information, please contact our Privacy Officer:
Slate Financial Technologies Inc.
Attention: Privacy Officer
1322 West Broadway St Unit 1006
Vancouver, BC V6H 1H2
Canada
Email: admin@tryslatehq.com
Phone: (778) 653-9468
For our general Privacy Policy covering website visitors, please visit: /privacy
Document Version: 1.0 (aligned with FEPA v2.6 and Consumer Terms and Conditions v1.0)