Approval Pathway Privacy Policy

Effective Date: Feb 1, 2026

1. Introduction

Approval Pathway (“AP,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information when you use Approval Pathway’s commercial loan application platform and related services.

This policy is intended to comply with applicable privacy and data protection laws, including but not limited to the Personal Information Protection and Electronic Documents Act (PIPEDA), the British Columbia Personal Information Protection Act (BC PIPA), the General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA) as amended by the CPRA. Privacy rights and obligations may vary depending on your jurisdiction.

2. Information We Collect

Approval Pathway collects personal information necessary to provide and improve our services, including:

Contact Information: Names, email addresses, phone numbers, and mailing addresses.
Financial Information: Bank statements, financial statements, tax returns, income details, and other relevant financial data required for loan evaluation.
Business and Collateral Information: Business details, loan purpose, collateral information, and related underwriting information.
Technical and Usage Data: Device identifiers, IP address, browser type, log data, and usage information used to support security, performance, and platform functionality.

We collect only the minimum information necessary to support our services and legitimate business purposes.

3. How We Use Your Information

Approval Pathway uses personal information for the following purposes:

Facilitating Loan Applications: Enabling borrowers, brokers, and lenders to submit and manage commercial loan applications.
Loan Evaluation and Processing: Supporting lenders’ review and assessment of applications in a secure manner.
Platform Operations and Improvement: Operating, maintaining, securing, and improving our platform, including internal analytics using anonymized or aggregated data.
Communications: Responding to inquiries, providing service updates, and notifying users of issues or changes affecting their accounts.
Legal and Compliance Purposes: Meeting regulatory, audit, contractual, and legal obligations.

Where required under applicable law, processing is based on consent. In other cases, processing may be based on contractual necessity, legal obligation, or legitimate business interests.

4. Sharing Your Information

We share personal information only where necessary to operate our services and fulfill legitimate purposes, including:

Lenders and Brokers: With your direction or consent, we share relevant application information with lenders or brokers involved in the loan process.
Service Providers: We use third-party service providers such as Google Cloud for infrastructure, data storage, and processing of information. These providers process information on our behalf under contractual obligations that require appropriate confidentiality, security, and data protection measures.

Approval Pathway does not sell personal information and does not share personal information for cross-context behavioral advertising as defined under the CCPA/CPRA.

5. Consent

By using our platform, you acknowledge that your personal information will be collected, used, and disclosed as described in this Privacy Policy.

Where required by law, we rely on your consent. In other circumstances, personal information may be processed because it is necessary to perform a contract, comply with legal obligations, or pursue legitimate business interests.

You may withdraw consent where consent is the applicable legal basis. Withdrawal of consent may limit or prevent access to certain services. Requests can be submitted to privacy@approvalpathway.com.

6. Retention of Personal Information

Approval Pathway retains personal information only for as long as necessary to fulfill the purposes for which it was collected, including service delivery, legal and regulatory compliance, dispute resolution, enforcement of agreements, and internal record-keeping.

Personal information related to loan applications may be retained for up to five (5) years following loan closure or account termination where required to meet regulatory, contractual, audit, or operational obligations. After this period, personal information is securely deleted, anonymized, or otherwise rendered inaccessible, unless a longer retention period is required or permitted by law.

Approval Pathway may retain anonymized or aggregated data for analytical, statistical, security, or platform improvement purposes. Such data does not identify individuals and is not considered personal information.

7. Your Rights and Choices

Approval Pathway respects individual rights regarding personal information in accordance with applicable privacy laws. Depending on your jurisdiction, you may have the following rights:

Access: Request access to the personal information we hold about you.
Correction: Request correction of inaccurate or incomplete personal information.
Deletion: Request deletion or anonymization of personal information where it is no longer required for legal, regulatory, contractual, or legitimate business purposes.
Withdrawal of Consent: Withdraw consent where processing is based on consent.
Restriction or Objection: In certain jurisdictions, request restriction of processing or object to specific processing activities.
Data Portability: Where applicable, request a copy of certain personal information in a portable format.
Non-Discrimination: You will not be discriminated against for exercising privacy rights under applicable law.
Authorized Agents: Where permitted by law, you may designate an authorized agent to submit requests on your behalf.

Requests may be submitted to privacy@approvalpathway.com and will be handled within a reasonable timeframe and in accordance with applicable law.

8. Data Security

Approval Pathway implements appropriate administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

Encryption: Personal information is encrypted in transit and at rest where appropriate.
Access Controls: Role-based access controls and multi-factor authentication are used to limit access to authorized personnel.
Monitoring and Integrity Controls: Security practices are monitored and updated to address evolving risks and standards.

No system can be guaranteed to be completely secure; however, we take reasonable steps consistent with industry standards and security frameworks.

9. Breach Notification

In the event of a confirmed data breach involving personal information that poses a real risk of significant harm, Approval Pathway will take appropriate steps to contain, assess, and remediate the incident in accordance with internal incident response procedures.

Where required by applicable law, Approval Pathway will notify affected individuals and relevant regulatory authorities without undue delay, and will provide information regarding the nature of the incident, the types of information involved, mitigation steps taken, and recommended actions for affected individuals.

10. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or operational needs. Material changes will be communicated through appropriate channels, such as email or in-platform notifications.

11. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact our Privacy Officer at: privacy@approvalpathway.com