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Cross-Border Private Lenders Association

Policies

Privacy Policy

Cross-Border Private Lenders Association (“CBPLA” or the “Association”)

This policy is being finalized. The adopted version and its effective date will be published here.

This Privacy Policy describes how CBPLA collects, uses, discloses, and safeguards personal information in connection with membership, the CBPLA website, the member portal, the member directory, LendCheck and LendReady, events, and other CBPLA activities. This Policy is incorporated by reference into CBPLA's Membership Terms and Conditions.

1. Scope

This Policy applies to personal information CBPLA collects from applicants, Members, named representatives, Community Subscribers, event registrants, sponsors, and visitors to the CBPLA website. It applies regardless of whether the individual is located in Canada, the United States, or elsewhere, given CBPLA's cross-border membership.

2. Information we collect

Depending on your relationship with CBPLA, we may collect:

  • Identity and contact information — name, title, organization, email address, phone number, mailing address, LinkedIn profile, and country of residence.
  • Organization information — legal and trade name, organization type, year established, jurisdiction of formation, registration number, website, and business address.
  • Membership and eligibility information — membership category, business activities, jurisdictions served, lending or brokerage profile, licensing status, and (where applicable) proof of student enrollment.
  • Regulatory and disclosure information — information provided in response to licensing and regulatory history questions in the Membership Application, including any disclosed license actions, disciplinary findings, or convictions relevant to eligibility.
  • Payment information — billing contact details and payment method; full card numbers are processed by our secure third-party payment processor and are not stored directly by CBPLA.
  • Directory and communication preferences — what a Member has chosen to include in its public directory listing, and consent choices for the communication categories described in the Membership Terms and Conditions.
  • Course and event activity — LendCheck and LendReady enrollment, progress, assessment results, and issued credentials; event registrations, including for Elevate + Activate and the CBPLA Summit.
  • Technical information — standard website and portal usage data such as IP address, browser type, device information, and pages visited, collected through cookies and similar technologies.

3. How we collect information

We collect information directly from you — through the Membership Application, the member portal, event registration forms, and direct communications with CBPLA — and automatically through cookies and similar technologies when you use the CBPLA website or portal. We do not knowingly collect personal information from public sources to build directory listings; directory content is provided and controlled by the Member.

4. How we use your information

We use personal information to:

  • Process membership applications, assess eligibility, and administer active memberships, including renewals and billing
  • Operate the member portal, member directory, Cross-Border Connection Desk, and Cross-Border Lender Readiness Assessment
  • Deliver LendCheck and LendReady courses, track progress, and issue credentials
  • Register attendees for CBPLA events and the discounted Elevate + Activate conference benefit
  • Send communications consistent with the categories and consent choices described in the Membership Terms and Conditions
  • Review disclosed regulatory or licensing history for membership eligibility purposes, as described in Section 6 below
  • Maintain the security, integrity, and proper functioning of the CBPLA website and member portal
  • Comply with legal obligations and enforce CBPLA's governing documents, including the Code of Ethics and Professional Conduct

5. Disclosure of information

1. Directory information. CBPLA publishes only the directory fields a Member has affirmatively chosen to make public, consistent with the directory preferences described in the Membership Terms and Conditions. This published information is publicly accessible.

2. Service providers. We share information with third-party service providers who help us operate CBPLA — including payment processors, email and communications platforms, video/course hosting providers, and IT service providers — solely to the extent necessary for them to perform those services, and subject to confidentiality obligations.

3. Regulators and authorities. CBPLA may disclose information to regulators, professional bodies, or other authorities where required by law, or where reasonably necessary to address serious misconduct, fraud, public risk, or misuse of the CBPLA name, consistent with the Membership Terms and Conditions.

4. Business transitions. If CBPLA reorganizes, merges, or transfers its operations, personal information may be transferred as part of that transaction, subject to confidentiality protections at least as protective as this Policy.

5. We do not sell Member or applicant personal information to third-party advertisers.

6. Sensitive information and regulatory disclosures

Information disclosed in response to the Membership Application's licensing and regulatory history questions is treated as confidential and sensitive. Access is restricted to CBPLA personnel who require it to assess membership eligibility, and it is stored using access controls and encryption appropriate to its sensitivity. This information is used only for membership eligibility, compliance, and related governance purposes, and is not published, included in the member directory, or shared other than as described in Section 5.

7. Cross-border storage and transfer

Because CBPLA serves Members in both Canada and the United States, personal information may be stored, processed, or accessed in either country (or by service providers located there), and may accordingly be subject to the laws of that country, including lawful access requests by domestic authorities. By using CBPLA's services, you acknowledge this cross-border processing. CBPLA takes reasonable steps to ensure service providers protect personal information consistently with this Policy regardless of where it is processed.

8. Cookies and tracking technologies

The CBPLA website and member portal may use cookies and similar technologies to keep you logged in, remember preferences, and understand how the site is used, including through analytics tools. You can control cookies through your browser settings; disabling cookies may affect portal functionality such as staying logged in.

9. Data retention

We retain personal information for as long as needed to administer your application or membership, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Regulatory-disclosure information and records relevant to membership eligibility decisions may be retained for a longer period consistent with CBPLA's recordkeeping and governance needs. When information is no longer needed, we take reasonable steps to securely delete or anonymize it.

10. Security

CBPLA uses administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, or disclosure, including encryption of sensitive regulatory-disclosure data, role-based access controls, and secure processing of payment information through a PCI-compliant third-party processor. No system is completely secure, and CBPLA cannot guarantee absolute security.

11. Your choices and rights

1. You may request access to, correction of, or deletion of your personal information, subject to CBPLA's legal and legitimate business requirements (for example, retaining records necessary for membership governance or legal compliance).

2. You may withdraw consent to optional communications (regulatory/industry updates, event invitations, educational announcements, newsletters, approved sponsor or partner communications, and marketing communications) at any time through the member portal or by written request, without affecting administrative communications necessary to maintain your membership.

3. You may update your directory listing preferences at any time, as described in the Membership Terms and Conditions.

4. Depending on where you are located, additional rights may be available to you under applicable privacy law (for example, Canadian federal or provincial privacy legislation, or applicable U.S. state privacy laws). To exercise any right described in this section, contact CBPLA using the details in Section 14.

12. Children's privacy

CBPLA's services are intended for business and professional use by adults and are not directed to individuals under the age of majority in their jurisdiction. CBPLA does not knowingly collect personal information from children.

13. Changes to this policy

CBPLA may update this Policy from time to time by posting a revised version on its website. Material changes will be communicated to Members through the channels described in the Membership Terms and Conditions. Continued use of CBPLA's website, portal, or services after a change takes effect constitutes acceptance of the revised Policy.

14. Contact us

Questions, requests, or complaints about this Privacy Policy or CBPLA's handling of personal information may be directed to:

Cross-Border Private Lenders Association

Cross-Border Private Lenders Association · Jasmine Daya & Co. serves as legal counsel to CBPLA.