Privacy Policy

Including the above mentioned data, we may also collect some or all of the following personal information through our site or when providing our products or services:

- information establishing your identity and contact information, such as your name, address, telephone number, email address, date of birth and government issued identification such as a driver’s licence or passport;

- prepaid card information and transaction information, such as cardholder name, card number, account balance and transaction history (e.g., date, amount and place of each transaction);

- information to authenticate your identity, such as card number and password that you enter to log into your account or register your card on the Site and your Internet Protocol (IP) address;

- information you provide during interactions with us, whether online, by phone, in writing or otherwise, such as when you contact our customer services or receive customer support, which information may include feedback, opinions and issues you may have encountered;

- other personal information with your consent or as permitted or required by applicable law.

We may also collect or generate non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as statistical or aggregated information about use of the Site and/or our products or services, which we use to: (a) help us understand the interests of our customers, cardholders and users; (b) improve our Site, products and services; and (c) manage our risks and operations.

We may collect personal information directly from you when you interact with us or the Site, including when you:

- create, login to or update your member profile/account on the Site or register your card on the Site;

- subscribe to receive messages or news from us;

- apply or register for a product or service;

- make an inquiry, request information from us, or otherwise communicate with us, including for customer service or support purposes; and/or

- complete a form or survey.

We will always collect your personal information by fair and lawful means. We may monitor and record communications and correspondence with you including emails and telephone calls as permitted by law for quality assurance and training purposes and to detect or prevent fraud or other losses.

We sometimes collect personal information from you through third party service providers, including:

- our clients in the course of our contractual relationship with them – our clients, when using our products or services, may provide us with personal information about individuals to whom prepaid cards are to be issued such as the name of the individual, as well as the card number and the amount to be loaded onto the card;

- government agencies, registries or public records – we or our service providers may collect personal information about cardholders that is publicly available, including by searching publicly accessible government lists of restricted or sanctioned persons and other public records or databases; and/or

- our business partners, service providers and other participants in the payment card ecosystem including payment processors, card issuers, financial institutions and third party identity verification and fraud prevention service providers, in connection with your application or registration for and/or use of our products or services.

Whenever we collect your personal information, we will identify the purposes for which we will use that information and we will obtain your consent to such use. We may use personal information we collect about you or that is provided to us:

- to establish and verify your identity and/or register you for a product or service;

- to authenticate you such as when you contact us or log into your member profile/account;

- to provide you with the products and/or services requested;

- to process, record and/or manage transactions, disputes, replacement cards, renewals and other operations relating to the provision of our products and/or services;

- to respond to your inquiries and provide customer service and technical support;

- to notify you about changes to our Site, any products and/or services you have with us, and/or related terms, conditions, and policies;

- to send any alerts or messages that you signed up for;

- to understand your needs and preferences and send you information about new products or services that may be of interest to you (you may unsubscribe at any time from electronic marketing or promotional communications – see “Your Choices” below);

- to personalize your Site experience and/or improve our Site, products and/or services;

- to detect, protect against, and investigate security breaches, fraud and/or error;

- to comply with regulatory and legal requirements, including to verify your identity against money laundering, terrorist financing or similar watch lists established or enforced by government regulators, and to satisfy reporting requirements;

- to enforce our rights, including our terms and conditions; and/or

- for any other purpose with your consent or as permitted or required by applicable law.

Generally, we do not disclose your personal information, and where we do, we will identify to whom and for what purposes the disclosure will be made and will obtain your consent to such disclosure. In any case, we only disclose your personal information as permitted or required by law.

We may share your personal information:

- with our affiliates and subsidiaries for the purposes described in this policy;

- with business partners, contractors, service providers, and other third parties that support the operation of our business or assist us in providing our products and services, such as those that provide or assist with payment processing, identification and verification services, customer service, website hosting, information technology services, email delivery, data analysis, and other similar services, but only as necessary for such purposes. We require those third parties to keep your personal information confidential, to use it only for the purposes for which we disclose it to them, and to protect the personal information in a manner consistent with the standards set out in this policy and in accordance with applicable law;

- to comply with a subpoena, court order, lawful request, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;

- to protect against, investigate and/or take action regarding suspected or actual financial abuse, fraud, or other harmful, unauthorized or illegal activity;

- in accordance with applicable law, during negotiation and/or on completion of any merger, amalgamation, financing, securitization, or sale or other disposition of some or all of our business assets to another organization;

- to protect our property and enforce our rights, including our terms and conditions that govern our products and services;

- to protect the rights, property or safety of you or others; and/or

- with your consent or as permitted or required by applicable law.

We will collect, use or disclose your personal information with your consent, except as permitted or required by applicable law. In determining the appropriate form of consent, including whether it is expressed or implied, we will take into account the sensitivity of the personal information and the reasonable expectations you may have in the circumstances.

By using the Site, registering for or using one of our products or services, or otherwise providing your personal information to us in connection with the Site or our products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this policy. Your consent can be withdrawn at any time on reasonable notice, except in limited circumstances (see “Your Choices” below).

Your personal information may be stored or processed in Canada and other countries, whose privacy or data protection laws may or may not be equivalent to Canadian law. If your personal information is transferred to a country outside of Canada, we will take reasonable measures to protect your personal information with appropriate security safeguards, however, in such circumstances, the governments, courts, law enforcement, security and/or regulatory agencies of any such country may be able to obtain access to your personal information through the laws of that country.

If you would like to learn more about our policies with respect to our use of service providers located in countries outside of Canada, please get in touch with us at the address listed under “Contact Us” below.

When you access or use the Site, we may use cookies or other automatic data collection technologies to collect certain information about your device, browsing actions, and patterns, including:

- details of your visit to our Site, including traffic data, location data, logs, and other communication data and the pages and resources that you access and use on the Site; and

- information about your device and internet connection, including your IP address, operating system, browser type and internet service provider.

Cookies are small text files that websites send to your device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return and also help us provide a customized experience. In many cases, you can manage cookie preferences and opt-out of having cookies and certain other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available. Please note that if you choose to remove or reject cookies, this could affect some of the features and functionality of the Site.

Subject to certain legal and contractual restrictions and reasonable notice, you may refuse or withdraw your consent to the collection, use or disclosure of your personal information at any time by contacting us as described below (see “Contact Us”). If you choose not to provide us with certain personal information or if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the implications to you at the time to help you with your decision.

In addition, if you wish to opt-out of marketing or promotional communications in the form of emails or text messages from us, you can opt-out by following the unsubscribe instructions included in any such message or by contacting us as described below (see “Contact Us”). Please note that even if you opt-out of electronic marketing or promotional communications, we may still need to contact you with important transactional or administrative information about your account.

We use reasonable efforts designed to ensure that any personal information provided to us is maintained in a secure environment, regardless of the format in which the information is held. We have implemented and maintain reasonable and appropriate security measures to help protect your personal information against loss or theft, and from unauthorized access, disclosure, copying, use or modification while it is in our custody or under our control. These measures include physical measures such as restricted access facilities, technological measures such as use of passwords, encryption, firewalls, anti-virus and security software, and system security monitoring, and administrative measures such as limiting access to personal information on a need-to-know basis. The safeguards utilized may vary depending on the sensitivity, amount, distribution, format and method of storage of the personal information. Where we share your personal information with a third party business partner, contractor or service provider, we use contractual or other means to provide a comparable level of protection for your personal information.

The safety and security of your personal information also depends on you. Where we have given you, or you have chosen, a password which enables you to access certain parts of our Site such as your account, you are responsible for keeping that password confidential. Do not share your password with anyone.

Except as otherwise permitted or required by applicable law, we will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, accounting and/or reporting requirements. Under some circumstances we may anonymize or de-identify your personal information so that it can no longer reasonably be associated with you. We may use and disclose such anonymous and de-identified data for any legitimate business purpose, including research and analytics, without further notice to you or your consent.

Upon request, subject to limited exceptions under applicable law, we will provide you with access to the personal information we hold about you and provide you with an account of the use of that information and third parties to whom it has or may have been disclosed. You may challenge the accuracy and completeness of that information and, if you demonstrate that your personal information is inaccurate or incomplete, we will make reasonable efforts to amend that information as required and, where appropriate, transmit the amended information to third parties having access to the information in question. We may request specific information from you to help us confirm your identity and your right to access the personal information that we hold about you or to make your requested changes. If we are unable to provide you with access to some or all of your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. If you would like to request access to or correction of your personal information, please contact us as described below (see “Contact Us”).

If you are a cardholder, you can review and update or change your personal information in your member profile/account by logging into the Site and visiting your member profile/account page. You can also view your prepaid card balance, transaction history and get your personal identification number (PIN).

The Site may include links to third-party websites, plug-ins, services, social networks or applications that we do not manage or control and that are not governed by this policy. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. You should familiarize yourself with the privacy policies and practices of any such third party before providing them with your personal information. We do not accept any responsibility or liability for any such third party’s policies or information practices.

Our Site and products and services are not intended for children under 13 years of age. We do not intentionally collect personal information from children under 13. If you are under the age of 13, please do not use our Site or products or services. If you are the parent or legal guardian of a child under 13 and believe we might have any information from or about your child under 13, please contact us as described below (see “Contact Us”) and we will delete that information.

If you are 13 or older but under the age of majority in the province in which you reside (a “Teen”), you may only use our products and services with the involvement and permission of a parent or legal guardian. If we learn we have collected or received personal information from a Teen without verification of parental or legal guardian consent, we will delete that information upon request of the parent or legal guardian. Please contact us as described below (see “Contact Us”) to request deletion.

We may update or make changes to this policy from time to time. If we make any material changes, we will post the revised policy on the Site and we will update the effective date at the top of the policy. We may also notify you of changes by email, through a notice on the Site home page and/or any by other legal means. Please check the policy periodically for any changes. Your continued use of the Site and/or our products or services after the revised policy has been posted will indicate your acceptance of and consent to the changes to the policy.