Privacy Policy

This Privacy Policy explains how Approved2Drive ("Approved2Drive," "we," "us," or "our") collects, uses, discloses, and protects personal information when you visit approved2drive.ca (the "Website") or use our auto financing application and matching services (collectively, the "Services").

Approved2Drive was formerly known as NewKeys Link. If you previously interacted with us as NewKeys Link, this Policy now governs how we handle your information going forward, and it supersedes our prior NewKeys Link privacy policy.

We are committed to protecting your personal information in accordance with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable Ontario law. By using the Website or Services, you agree to the collection and use of your information as described in this Policy. If you do not agree, please do not use the Website or Services.

1. Who We Are

Approved2Drive is a lead-generation and matching service that connects drivers across Ontario, Canada — including applicants with bad credit, no credit, or newcomer status — with dealer and lender partners who can offer auto financing. We do not ourselves extend credit; we help you get in front of the right specialist.

Approved2Drive is a sole proprietorship operating out of Mississauga, Ontario, L5K 2R4.

2. Information We Collect

We collect information in three ways:

a) Information you give us directly

When you submit our quick contact form or our full financing application, we collect information such as your name, phone number, email address, date of birth, Canadian immigration/residency status, driver's licence or government ID information, home address, housing status, employment status and income, and your vehicle preferences and budget. We collect only what is reasonably necessary to assess and route your application — we never ask for full bank account numbers, passwords, or a Social Insurance Number through the Website.

b) Information collected automatically

Like most websites, we automatically log technical information such as your IP address, browser and device type, pages visited, and time spent on the Website, through Google Analytics and similar tools, and through cookies described in Section 7 below.

c) Information from your interactions with our AI assistant

The Website includes an AI-powered voice and chat assistant ("Sophia"), provided through our technology partner ElevenLabs. If you choose to speak or chat with Sophia, we collect what you tell it — including your name, phone number, email, driver's licence status, and the vehicle you're looking for — for the same purposes described in this Policy. Conversations may be transcribed and, where reasonably necessary, used to improve the quality of the assistant. See Section 6 for more detail.

3. How We Use Your Information

We use the personal information we collect to:

• Assess your application and match you with an appropriate dealer and/or lender partner
• Contact you by phone, SMS, WhatsApp, email, or through our AI assistant about your application
• Pre-fill your application if you return using a personalized link (e.g., a link texted to you)
• Operate, secure, and improve the Website and Services, including measuring which pages and ads are effective
• Comply with legal, regulatory, and record-keeping obligations related to consumer credit referrals
• Detect and prevent fraud, spam, and abuse (including through Google reCAPTCHA)

We rely on your consent (given when you submit a form or agree to be contacted), the necessity of processing your information to provide the Services you requested, and our legitimate interest in operating and securing our business, as the legal bases for this processing.

4. How We Share Your Information

Our Services only work if we can introduce you to a dealer or lender. When you submit an application, we share the relevant information in it with:

• Dealer partners and qualified automotive/financing specialists in our network, so they can follow up about your application
• Banks, credit unions, and other lenders who may be able to offer you financing

We also share limited information with service providers who help us run the Website, under agreements that restrict them to using it only to provide their service to us:

• MongoDB, Inc. — secure database hosting for application data
• Twilio Inc. — sending SMS and WhatsApp messages
• ElevenLabs — powering our AI voice/chat assistant
• Google LLC — analytics (Google Analytics), advertising measurement (Google Ads), and spam protection (reCAPTCHA)
• n8n (workflow automation) — routing your application internally to our team
• Vehicle inventory data providers, to show you relevant vehicle information

We do not sell your personal information, and we do not share it with unrelated third parties for their own marketing purposes. We may disclose information if required by law, court order, or to protect the rights, property, or safety of Approved2Drive, our users, or the public.

5. Our AI Assistant

When you interact with Sophia, our AI assistant, you are speaking or chatting with an automated system, not a live employee, unless we tell you otherwise. Voice conversations may be transcribed to text and processed by our AI service provider (ElevenLabs) and, where applicable, underlying AI model providers, solely to respond to you and to improve the assistant. Do not share full financial account numbers, passwords, or government identification numbers with the assistant.

6. Cookies and Tracking Technologies

We use cookies and similar technologies for:

• Essential functionality — remembering your progress through the application form
• Analytics — Google Analytics, to understand how visitors use the Website
• Advertising measurement — Google Ads conversion tracking, to understand which ads lead to completed applications
• Security — Google reCAPTCHA, to detect automated/bot submissions

You can control or delete cookies through your browser settings. Blocking cookies may affect the functionality of the application form.

7. SMS, WhatsApp, and Electronic Communications

If you provide your phone number and consent to be contacted, we may send you SMS and/or WhatsApp messages about your application, including a link to resume an incomplete application. These messages are sent in accordance with Canada's Anti-Spam Legislation ("CASL"). You can ask to stop receiving messages at any time by replying to any message or contacting us using the details in Section 13. Standard message and data rates may apply.

8. How Long We Keep Your Information

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including matching you with a dealer or lender, responding to follow-up questions, and meeting our legal and record-keeping obligations related to consumer credit referrals — generally for up to seven (7) years following your last interaction with us, consistent with standard record-keeping practices in the financial services industry. If you ask us to delete your information sooner and we have no legal obligation to retain it, we will do so.

9. How We Protect Your Information

We use reasonable administrative, technical, and physical safeguards — including encrypted data transmission and access-controlled database hosting — to protect your personal information. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security. If we become aware of a data breach that creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by law.

10. Your Rights

Under PIPEDA, you have the right to:

• Know what personal information we hold about you and request access to it
• Request correction of inaccurate or incomplete information
• Withdraw your consent to our collection, use, or disclosure of your information, subject to legal or contractual restrictions and reasonable notice
• Ask us to delete your information, subject to Section 8 above
• File a complaint with us or with the Office of the Privacy Commissioner of Canada

To exercise any of these rights, contact us using the details in Section 13. We will respond within the timelines required by applicable law.

11. Children's Privacy

Our Services are intended for individuals who are at least 18 years old, as auto financing applications require legal capacity to enter into a contract. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal information, please contact us and we will delete it.

12. Third-Party Links

The Website may link to dealer, lender, or partner websites that we do not control. This Policy does not apply to those third-party sites — please review their privacy policies separately.

13. International Data Transfers

Some of our service providers (including Twilio, ElevenLabs, and Google) may process or store information on servers located outside Canada, including in the United States. Where this occurs, your information may be subject to the laws of that jurisdiction, and we take reasonable steps to ensure it continues to receive a comparable level of protection.

14. Changes to This Policy

We may update this Policy from time to time. We will post the revised version on this page and update the "Last updated" date above. Material changes will be highlighted on the Website. Your continued use of the Website after a change takes effect means you accept the updated Policy.

15. Contact Us

If you have questions, concerns, or wish to exercise your privacy rights, contact us:

• Phone / SMS: +15488000505
• Email: privacy@approved2drive.ca