Privacy Policy

1. Introduction

Wagepay Inc., and its subsidiaries (“we”/”us”/”our”) endeavour at all times to comply with the provincial and federal private sector privacy laws in Canada, including the BC Personal Information Protection Act (“BC PIPA”), the Alberta Personal Information Protection Act (“AB PIPA”) and the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) which together will be referred to in this policy as “Canadian Privacy Law.”

This General Privacy Policy applies to all persons accessing our website and mobile applications, dealing with us or from whom we otherwise collect personal information. For the purpose of this General Privacy Policy the term “personal information” means information about an identifiable individual. We also collect personal and credit information provided by persons applying for or receiving credit from us and, in doing so, endeavour at all times to comply not only with Canadian Privacy Law, in general, and, in particular, with the applicable provincial credit reporting regulations. By accessing this website or otherwise dealing with us you agree to our General Privacy Policy in relation to the collection of personal information by the website or mobile application.

2. The kinds of personal information we collect

The amount and type of personal information collected by us shall be limited to what is necessary to fulfill the identified purpose. Personal information shall only be used or disclosed for the purposes for which it is collected. Exceptions may be made with the consent of the individual or if authorized or required by law. As a result of your visit to our website or mobile application, through the use of other websites, software and internet tracking devices such as cookies, pixels, tags, anonymous identifiers and session variables. We may use tracking technologies, such as Google® Analytics in a variety of ways, including the following: keeping count of return visits to our site; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on website usage; and determining which features users like best.

Finally, your Internet browser has a feature called “cookies,” which stores small amounts of data on your computer about your visit to our site. Cookies tell us nothing about who you are, however, unless you specifically give us personal information. You do not need to have cookies turned on to visit our websites. You may also elect not to allow cookies to be collected by selecting certain options on your browser.

If we use any cookies for the purposes of marketing to you we will seek your consent before using these cookies.

Your internet service provider or the providers of your internet browser software may also collect such information for their own purposes. We are not responsible for the collection, storage and use of such information by these entities and refer you to their respective privacy policies.

As a result of your dealing further with us, whether as a prospective customer, an actual customer, a contractor, supplier or service provider or employee, we may collect, use and store personal information from you such as:

• your name or business information;
• address, previous addresses and how long you have lived at those addresses;
• date of birth;
• your email address;
• your telephone numbers;
• your employer, previous employers and how long you have been in such employment;
• your income, expenses, and debts;
• your payroll data;
• your bank account details and payment information;
• your social insurance number;
• your credit rating and credit information;
• Consumer credit liability information about the consumer credit accounts you hold whether with us or some other credit provider including:
  • type of account;
  • when it was opened and, if applicable, closed;
  • if a credit account, then the maximum amount of credit approved;
  • other specific terms and conditions of the account.
• Whether we made an information request about you to a credit reporting agency.
• Default information about your account;
• Payment information which discloses that you have made an overdue payment whether to us or to another credit provider;
• Court proceedings information about a judgment of any Canadian court that was made against you in relation to any credit that was provided to or applied for by you;
• Personal insolvency information ;
• Publicly available information about you that is not otherwise described above but which is relevant to your credit worthiness;
• Serious credit infringement information which relates to credit which we or some other credit provider has provided to you.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties

If you apply to us for employment, we may also collect and store personal and, in addition, sensitive information about you including your:

• education, training and other qualifications;
• work history;
• professional or trade associations or union membership;
• hobbies and other interests; and
• criminal history.

3. How we collect your personal information

We may collect personal information about you from your visit to our website through the use of technologies such as anonymous identifiers, session variables, and cookies. You may be able to set your internet web browser to block or limit cookies. Some features of our website may not work as efficiently or not at all if you have done so.

As a result of you dealing further with us, we may collect personal information directly from you and this may be in person, over the telephone, by mail, over the internet, by email or by completion of an application or consent form whether on-line or otherwise.

If you:

• apply to us for credit;
• receive credit from us;
• apply to us to vary the terms of your payments under your (consumer) credit contract on the grounds of hardship;
• request to receive your credit file;
• apply for a business account; or
• apply for employment with us

we may collect personal, credit and sensitive information about you from other sources when it is impractical or unreasonable for us to collect it directly from you. Among these other sources may be:

• a credit reporting body;
• someone authorised by you such as an agent, broker, accountant, solicitor, financial counsellor, or introducer;
• a referee;
• an employer;
• a government body;
• financial institutions;
• other lenders
• a professional or trade association or trade union

and we may collect that information directly from them in person, over the telephone, by mail, over the internet, by email or by completion of an application or consent form whether on-line or otherwise.

Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.

You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.

The purpose for collecting personal information is set out in this policy. Any necessary consents shall be obtained before personal information is collected, used or disclosed.

We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask you to provide your consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button).

4. How we protect your personal information

We use our best endeavours and take all reasonable steps to secure your personal information including:

• maintenance of a secure environment for storage of information whether in hard copy or in electronic form;
• requiring that access to such information be confined to authorised personnel only;
• using technology such as encryption and password protection to secure any information kept in electronic form.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL . Where you have chosen a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

5. The purposes for which we collect, hold, use and disclose your personal information

If you are a user of our website, a prospective customer, an actual customer, a business account holder, a contractor or supplier of goods and services to us, a job applicant or other person from whom we collect, hold, use and disclose your personal information we shall do so only for those purposes which are permitted by Canadian Privacy Law, are reasonable and necessary for:

• the administration of any contract of supply of goods or services to or by us;
• assess your credit application;
• the provision of our products to our customers;
• assessment and processing of any job application;
• consider any application for variation of your payments whether or not on the grounds of hardship;
• otherwise for the administration and management of our business;
• for the improvement of our website;
• collect any debt or otherwise enforce any rights whether by court proceedings or otherwise arising under your credit contract;
• assist you if we consider you may be at risk of default;
• participate in the credit reporting system and provide information to credit reporting bodies as described above;
• provide other additional services to you required by law;
• required in order to investigate or assist with any investigation into any complaint about the conduct of our business, in particular, under Canadian Privacy Law;
• to otherwise enforce any term of any contract or other right which arises out of our dealings with you.;
• to identify you and/or communicate with you if you have consented to receive such , by way of direct marketing and general advertising, information about our products and for other third parties to also to the same for our products services and their products and services;
• customer service;
• to search and/or register any security;
• as part of a prospective sale, transfer or restructure of our business; or
• to otherwise communicate with you or the purposes outlined above.

In addition, if you apply to us for credit or receive credit from us, we will collect, hold, use and disclose your personal information in order to:

• assess your credit application;
• manage your credit contract;
• consider any application for variation of your payments whether or not on the grounds of hardship;
• collect any debt or otherwise enforce any rights arising under your consumer credit contract;
• assess your application for a variation to the terms of repayment under your (consumer) credit contract on the grounds of hardship (‘hardship ’);
• explain our decision whether or not we agree to a hardship variation;
• administer, monitor and record any agreed hardship variation;
• consider any complaint about our decision to refuse a hardship variation;
• respond to any complaint about our decision to refuse a hardship variation; and
• manage our business including our responsible lending obligations and our systems for considering applications for hardship variations.

We may disclose your personal information, including credit and sensitive information, to other parties as part of a process of merger, acquisition, sale of our business or our other assets.

In order to obtain credit information about you from credit reporting bodies we may be required to disclose to them credit information about you which we hold. Those credit reporting bodies may then include that credit information about you in reports they provide to other credit providers.

This includes all the credit information described above with the exception of your financial information. It does, however, particularly include:

• Information to verify your identity
• Information to provide you free access to your credit file

The credit reporting bodies to which we may disclose your credit information are:

TransUnion

6. Data Transfer Outside Canada

We supply your personal information to the third party company that administers our information technology systems who are located in Australia, The United States of America and China. As such, your personal data may be accessible to law enforcement and national security authorities of these jurisdictions pursuant to applicable laws.

The level of information protection in countries outside Canada may be less than that offered within Canada. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable Canadian Privacy Laws. Where our third-party service providers process personal data outside Canada in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses.

7. How you may access your personal information held by us

You may request access to your personal, sensitive and credit information held by us by identifying yourself in person or by scanned attachments to an email and sending your request for access to us at: Privacy Officer, Wagepay Inc, Email: support.ca@wagepay.com; website www.wagepay.com/ca.

If we are unable to grant your access to personal, sensitive or credit information, we will give you our reasons in writing within a reasonable time. These may include where providing the information to you may:

• reveal personal information about another individual person;
• pose a threat to the health or safety of another individual person;
• not be permitted by law;
• where excluded from disclosure under applicable Canadian Privacy Law.

8. How you may correct any personal information we hold about you which is incorrect

If you believe any personal information which we hold about you is incorrect, please contact us in person by telephone, by email, support.ca@wagepay.com to identify yourself and tell us what information which we hold about you is, in your belief, incorrect and how you want it changed.

If we cannot agree to the change to the information which you have requested, we will give you reasons in writing in accordance with the time frames set out in the applicable Canadian Privacy Law.

9. How you may complain about how we deal with your personal information

If you are not satisfied with the reasons referred to above or otherwise have any complaint about how we collect, hold, use or disclose your personal information please contact our Privacy Officer who will then follow our Privacy Internal Dispute Resolution process and respond to your complaint within the time period required under applicable Canadian Privacy Law. Our Privacy Officer can be contacted at: Privacy Officer, Wagepay Inc, Email: support.ca@wagepay.com; website www.wagepay.com/ca

You can, of course, at any time, refer any complaint about the privacy of your personal information directly to:

Office of the Information and Privacy Commissioner for Alberta
#410, 9925 – 109 Street
Edmonton, Alberta
T5K 2J8
Phone: 780-422-6860
Toll Free: 1-888-878-4044

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
TTY: 819-994-6591

Office of the Information and Privacy Commissioner for British Columbia
PO Box 9038 Stn. Prov. Govt.
Victoria B.C. V8W 9A4
info@oipc.bc.ca
Telephone: (250) 387-5629
toll-free by calling Service BC requesting a transfer to (250) 387-5629

10. Changes to this Policy

From time to time, we may make changes to this General Privacy Policy because of:

• changes to the law;
• changes to technology;
• changes to our systems

We will notify such changes on our website. Where the changes may affect you in a particular way, and you have a (consumer) credit contract with us, we will notify you if required by Canadian Privacy Law.