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Last Modified: October 19, 2018
To establish an account with us, we collect your personal and business information including, but not limited to, your:
To the extent you provide us with, or upload data that includes the personal information of another person, you represent and warrant that you have their authorization to provide us with that information.
Our Service may use location services made available online and by iOS, WatchOS, Android and other platforms. Location services allows location-based apps and websites to use information from internet service providers, cellular, Wi-Fi, Global Positioning System (GPS) networks, and iBeacons to determine your approximate location. To learn more about the use of Location Services in iOS please click here.
We use location services to verify you are using our Service, or, registered for our Service from within Canada. You can turn off location services on your mobile device if you are using our mobile app, and in your internet browser if you are accessing the Service via our web application.
As referenced in our Terms and Conditions of Use, to facilitate depositing and withdrawing funds and the ordinary use of our Service, we use a third-party providers, including Flinks and Plaid. Flinks and Plaid use an application programming interface (“API”) and other integration features to connect with your bank to provide us with your bank account information, including for example, the name associated with the bank account, the institution, transit and account numbers, account balance, as well as other information. This information is used to facilitate the verification of your identity and the deposit and withdrawal of funds from your bank account. Flinks and Plaid may also send us your (i) account balance to ensure you have a sufficient balance in your account to withdraw funds pursuant to a request made by you; and (ii) up to six (6) months of your bank account transaction history, which we use in a small number of cases as part of our fraud prevention measures.
We may also use your personal information to confirm your identity with Trans Union of Canada, Inc., Equifax Inc. and their related and affiliated entities (the “Credit Agencies”). To confirm your identity, we use personal information you provide us, for example, your name and date of birth, to obtain reports and information from the Credit Agencies about you. We cross reference the information obtained from the Credit Agencies about you with the information you provide us. To access your personal information on file with the Credit Agencies, for the purpose of confirming your identity and matching it with other personal information you provide to us, we may use the services of Trulioo Information Services Inc. (“Trulioo”), who in turn, may conduct the relevant searches with the Credit Agencies. If we cannot verify your identity in reference to information provided by Trulioo and the Credit Agencies, we may refuse to allow you to register for an account on our Service or remove your account access.
The collection of your personal information may also be used to:
IN ADDITION, WE RESERVE THE RIGHT TO PROVIDE YOUR CONTENT AND INFORMATION (INCLUDING BUT NOT LIMITED TO YOUR PERSONAL AND BUSINESS INFORMATION) UPLOADED OR COLLECTED BY OUR WEBSITE, SERVICE OR OTHERWISE TO THIRD PARTIES IF REQUIRED BY LAW (SUCH AS IN RESPONSE TO A SUBPOENA, COURT ORDER OR OTHER LEGAL PROCESS IN ANY JURISDICTION), AND TO COOPERATE WITH LAW ENFORCEMENT AUTHORITIES IN THE INVESTIGATION OF ANY CRIMINAL OR CIVIL MATTER.
IF WE ARE REQUIRED BY LAW TO MAKE ANY DISCLOSURE OF YOUR CONTENT OR PERSONAL OR BUSINESS INFORMATION, WE MAY (BUT ARE NOT OBLIGATED TO) PROVIDE YOU WITH WRITTEN NOTICE (TO THE EXTENT PERMITTED BY LAW) PRIOR TO SUCH DISCLOSURE SO THAT YOU MAY TAKE APPROPRIATE ACTION.
We do not sell your personal information.
However, we may share personal and business information with our employees, advisors and partners to use that information in connection with one or more of the purposes for which that personal information was collected.
We also operate the Website and Service in conjunction with our independent contractors. Our independent contractors may have access to your personal information in providing services to us, or, providing you with access to the Website and Service. We may use a variety of service providers, servers and employees in locations both inside and outside of Canada, which may make your personal information the subject of foreign laws and foreign legal proceedings.
We may also disclose your personal information to our successors (if our business or the Website and Service are acquired by another legal entity) or any assignee of our assets relating to the Website and Service.
WHILE WE TAKE MEASURES TO PROTECT PERSONAL INFORMATION, YOU AGREE THAT, TO THE FULLEST EXTENT PERMITTED BY LAW, IN NO EVENT WILL WE, OUR AFFILIATES, OFFICERS, DIRECTORS, SHAREHOLDERS, EMPLOYEES, CONTRACTORS, ADVISORS OR AGENTS, BE LIABLE, HOWSOEVER CAUSED, FOR THE LOSS OR THEFT OF YOUR PERSONAL INFORMATION OR ANY DAMAGES CAUSED AS A RESULT THEREOF, SO LONG AS WE WERE NOT GROSSLY NEGLIGENT IN THE PROTECTION OF SAID INFORMATION.
We keep your personal information for as long as it is required for the purpose for which it was collected. There is no single retention period applicable to the various types of personal information collected.
We use "cookies" to collect information about you and your activity across our site. A cookie is a small piece of data stored on your computer and accessed each time you visit our Website and Service, so we can understand how you use our Service and serve you content or save setting you have specified.
Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. timezone, notification preferences and usernames), and to personalise your content.
Cookies set by the website you are visiting are normally referred to as "first-party cookies", and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called "third-party cookies" and can be used to track you on other websites that use the same third-party service.
Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, and payment processing. We use essential cookies to enable certain functions on our Website and Service.
Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience's overall website experience. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use performance cookies on our Website and Service.
Functionality cookies are used in collecting information about your device and any settings you may configure on the website you are visiting (like language and time zone settings). With this information, websites can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use functionality cookies for selected features on our Website and Service.
Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you are visiting (first-party) or by third-party services. Targeting/advertising cookies set by third parties may be used to track you on other websites that use the same third-party services. We use targeting/advertising cookies on our site.