“Personal Information” is information that identifies you or could be combined by the Company or the Company’s services providers or affiliates with other information to identify you.
TYPES OF PERSONAL INFORMATION COLLECTED
The Personal Information the Company collects about you will depend on the manner in which you access or use the Web Services or any content on or through the Web Services and may include information you provide directly (e.g. through a form or email that is sent to us) and information that is collected by us (e.g. through observation of your web-browsing behaviour):
Directly Provided Information:
- your name, age, gender, spoken language, or contact information, such as your mailing address, telephone number, or email address, employment, education, salary, or other similar information associated with you;
- your banking information, including bank and online account information, credit card information, user names and login details;
- your government issued ID, including ID numbers, pictures and other information stored on or in your ID;
- billing or account information, financial purchase history; and any other Personal Information that you choose to submit to us (the "Directly Provided Information").
- your location, time-zone setting network information, device type, browser type, version and history, browser plug-in types and version, operating system and platform, language, standard web log data, and Internet protocol (“IP”) address used to connect your computer to the Internet or other similar identifier, or the equipment you use to access or use the Web Services and usage details;
- browsing history, search history, and data on the pages, services, or content you access or use on or through the Web Services, including the amount of time you spend on certain pages, products or services you viewed, searched for, or purchased (including information about those products or services, such as prices and the point of sale), clickstreams to, through, and from the Web Services, page response times, downloads and download errors, page interactions, or methods used to browse away from the Web Services; and
- your financial transaction history. (the "Collected Information")
The Web Services and any content provided on or through the Web Services is not directed to any person who is not the legal age of majority under applicable law. The Company will not knowingly collect Personal Information from any person who is not the legal age of majority under applicable law.
METHODS FOR COLLECTING PERSONAL INFORMATION
How Information is Directly Provided to the Company by You
Personal Information the Company collects from you on or through the Web Services and as a result of your access to or use of the Web Services or any content accessed on or through the Web Services may include Personal Information you provide the Company directly, for example by:
- submitting, posting, publishing, displaying, or otherwise transmitting content, material, or information to the Web Services or to other users or persons through or using the Web Services (“User Generated Content”);
- filling in forms, making search queries, or corresponding with the Company on or through the Web Services, or otherwise communicating with the Company by any means including by phone or email;
- if applicable or available through or on the Web Services: creating or registering for an account; subscribing, purchasing, or requesting information on a service or product, or entering a contest or promotion;
- carrying out transactions through our website;
- downloading and installing mobile and desktop applications from the Google Chrome Store or Firefox;
- interacting with our advertising and applications on third-party websites and services;
- observing user practices and completion of optional surveys through the extension.
Any User Generated Content that is published or displayed by you on the Website is posted on and transmitted to others at your own risk. Although we limit access to certain pages and/or you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Generated Content. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Generated Content.
How Information is Collected by the Company Through Technological Means
This Collected Information, including Personal Information, we collect automatically, including when the Company scans government issued ID and connects to bank accounts when you provide the Directly Provided Information during the account creation process, and we may maintain it or associate it with Personal Information we collect in other ways, that you provide to us, or receive from third-parties. We may use this Personal Information in the manner set out below under the section entitled “Using and Disclosing Personal Information”.
This information also helps the Company improve the Web Services and the content available on or through the Web Services and otherwise improve the services of the Company by:
- helping the Company understand audience sizes and usage patterns on the Web Services;
- allowing the Company to tailor the Web Services to your preferences and interests; and
- recognizing you when you visit the Web Services multiple times.
To help the Company verify your ID and link our Web Services to your bank account, the Compnay uses a third party service provider called Inverite Verification Inc. ("Inverite"). To learn more about Inverite, their services, and how they handle any personal information of yours, check out their website at https://www.inverite.com and https://www.inverite.com/bank-verify
USING AND DISCLOSING PERSONAL INFORMATION
Use of Personal Information by the Company
The Company collects Personal Information to provide you with a secure, smooth, efficient, and customized experience through or on the Web Services or any content on the Web Services. The Company may use your Personal Information to:
- provide you with content, services, or products on or through the Web Services;
- customize, measure, and improve the Web Services or content provided on or through the Web Services, or otherwise analyze or manage the Company’s business operations or Web Services performance;
- deliver targeted marketing, service update notices, or promotional offers base on your communication preferences;
- send you things in the mail or through other channels, such as products or services that you have requested;
- register you for, or authenticate you when you sign into, an account or online services or when you purchase a product or service, or to provide you with notices about such accounts, subscriptions, or purchases;
- facilitate a potential introduction to you by a third-party, as described below under “Third-Party Transfers”;
- otherwise fulfill the purposes for which you have provided Personal Information or that were described when such Personal Information was collected; or
- carry out other purposes to which you consent or which are otherwise permitted or required by law.
The Company may combine all the Personal Information the Company collects, including yours, in order to analyze and understand aggregate trends.
The Company may transfer your Personal Information to third-parties that assist the Company with the use of Personal Information described in “Use of Personal Information by the Company”, above, such as data centres, or email service providers. Some third-parties may be located outside of Canada and may accordingly be subject to laws that are different from those in Canada.
The following Personal Information, if anonymized, pseudonymized or de-identified, may be transferred to a third party without your further consent to facilitate a potential introduction:
- browsing history, search history, and data on the pages, services, or content you access or use on or through the Web Services, including the amount of time you spend on certain pages, products or services you viewed, searched for, or purchased (including information about those products or services, such as prices and the point of sale), clickstreams to, through, and from the Web Services, page response times, downloads and download errors, page interactions, or methods used to browse away from the Web Services;
- your location, time-zone setting network information, device type, browser type, version and history, browser plug-in types and version, operating system and platform, language, standard web log data, and IP address used to connect your computer to the Internet or other similar identifier, or the equipment you use to access or use the Web Services and usage details;
- device information;
- your age range (but not your precise age);
- your gender;
- anonymized and pseudonymized data that does not identify you;
- your spoken language; and
- your time zone.
The Company requires that all third-parties that the Company uses to deliver its Web Services that receive any Personal Information from the Company use the same standards as the Company in using, maintaining, disclosing, and protecting such Personal Information.
The Company may also share aggregated, non-personally identifiable information publicly to show trends about the general use of web services, or any content, services, or products provided on or through the Web Services.
Other Disclosures of Personal Information
The Company may transfer information about you, including Personal Information, in connection with a merger or sale (including any transfers made as part of an insolvency of bankruptcy proceedings) involving all or part of the Company’s business or as part of a corporate reorganization or stock sale or other changes in corporate control.
ACCESS AND CORRECTION
The Company will provide you with access to your Personal Information in accordance with applicable privacy legislation, and may decline to provide you access to your Personal Information on the basis that such Personal Information is:
- protected by solicitor-client privilege;
- part of a legal proceeding, government or regulatory investigation or process, or otherwise part of a formal dispute resolution process;
- information that would reveal Personal Information about another individual or confidential commercial information; or
- prohibitively expensive to provide.
Where the Company is unable to provide you with access to your Personal Information, reasons will be provided, subject to any legal or regulatory restriction.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
The Company strives to provide you with choices regarding the Personal Information you provide to us. The Company has created mechanisms to provide you with the following control over your information:
- You may turn off access to your banking information and browser history by using the toggle button under "Settings" in the Extension.
- You may turn off the Company's access to any of the Directly Provided Information and the Collected Information by using the toggle button under "Settings" in the Extension or on the Website.
- You may decline to complete any surveys or forms distributed by the Company during your use of the Web Services.
- You may provide or decline to provide your consent to any Company request prior to the Company transferring further information regarding your identity in connection with your anonymized and encrypted information.
The security of your Personal Information is important to the Company. The Company protects your Personal Information by maintaining physical, organizational, and technological safeguards against unauthorized access, unauthorized disclosure, theft, or misuse appropriate to the sensitivity of such Personal Information. Personal Information collected by the Company may only be accessed by persons within the Company who require access to provide you with access to, use of, or content, services, or products provided on or through the Web Services. The Personal Information the Company collects is maintained within databases located in Canada.
The safety and security of your information also depends on you. Where the Company has given you (or where you have chosen) a password for access to certain parts of our Web Services, you are responsible for keeping this password confidential. The Company asks you not to share your password and/or private encryption key with anyone.
Although the Company takes precautions against breaches of or unauthorized access to your Personal Information, no company can fully eliminate the risks of such breaches or unauthorized access and no website is completely secure. The Company cannot guarantee that unauthorized access, hacking, data loss, or breaches of the Company’s security systems will never occur. Accordingly, you should not transmit Personal Information to the Company by any means if you consider that Personal Information to be sensitive.
Except as otherwise permitted or required by applicable law or regulation, the Company retains Personal Information that it collects only as long as necessary for the purposes for which such Personal Information was collected. The Company reserves the right to use anonymous and de-identified information, including anonymized or otherwise de-identified Personal Information, for any legitimate business purpose without further notice to you and without your Consent.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE