PAYCASE CANADIAN PRIVACY POLICY

At Paycase Financial Corp. ("Paycase"), we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Paycase collects from or about you through our mobile application and website located at www.paycase.com (together, the “Website”), including the money transfer service (the “Service”), and through other interactions with you, as well as how we use and to whom we disclose that information. Please review this entire document carefully.

What Is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than an individual's business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities.

What Personal Information Do We Collect?

Registration on the Website: You do not need to register to visit the Website. However, in order to use the Service, you will be required to register and create an account on the Website and you will be asked to provide your name, email address, mailing address, phone number, occupation, date of birth, and a password that you select. Your registration information is used to provide and otherwise administer your account and the Service, and to establish, maintain and manage our relationship with you. We also use this information to verify your identity, to meet our legal and regulatory obligations and for fraud prevention purposes.

Money Transfer Service: When you use the Service, we collect information including your payment card information (including card number, CVC, and expiry date) and device identification information. We use this information (as well as your registration information) to verify and process your money transfer (including processing your payment), facilitate delivery of funds to the recipient, verify your identity and to meet our legal and regulatory obligations (which includes checking the identity of senders against anti-money laundering, anti-terrorist financing or similar watch lists established by applicable regulatory agencies or similar organizations). We also collect information about your friend of family member who is receiving the money transfer, including the recipient’s full name, country of residence, delivery method, the recipient’s bank and bank account number (in the case of transfers to a bank account) and the recipient’s address (for door-to-door delivery). We may use this recipient information in order to ensure delivery of the money. We rely on you to ensure that you have obtained your friend or family member’s consent to provide this information to us for the purposes of facilitating the money transfer.

In most cases, Paycase collects personal information directly from you (such as information you provide to us when you register on the Website or send a money transfer). We may also collect personal information from third parties such as consumer reporting agencies for identity verification and fraud prevention purposes.

Call Recording: We may monitor and record our telephone conversations with you for training and quality assurance purposes. You will be provided with a notice at the beginning of any call that is being recorded. If you do not wish to have your call recorded, please let us know.

Customer Service: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and product and service offerings.

Employment: In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). This information will be used for the purpose of processing and responding to your application for current and future career opportunities.

Survey and Customer Research: From time to time, we may offer you the opportunity to participate in one of our surveys or other customer research. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable form to help us understand our customers and to enhance our product and service offerings.

Contests and Promotions: From time to time, we may offer contests and promotions. When you enter a contest or participate in a promotion, we may collect your name, address, phone number, email address, and other information you provide. This information is used to administer your participation in the contest, sweepstakes or promotion.

How Do We Share Your Personal Information?

We will not disclose, trade, rent, sell or otherwise transfer your Personal Information, without your consent, except as otherwise set out in this Privacy Policy.

Service Providers: We may use third parties to provide services on our behalf, such as identity verification, anti-fraud verification, payment processing, facilitation of the money transfer, information technology, administration, printing, marketing and advertising, hosting, data analysis, legal and accounting. As a result, your personal information may be transferred (or otherwise made available) to our third party service providers and we may receive personal information collected by such third parties. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. Your personal information may be maintained and processed by Paycase and its third party service providers in the US or other jurisdictions. In the event Personal Information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.

Money Transfer Service: In order to process money transfer transactions, we disclose personal information about you to the recipient’s financial institution, delivery service or pawn shop so that they may facilitate the delivery. We may also be required to disclose certain of your personal information to intermediaries involved in the transfer (such as name, address, email or phone number) in accordance with requirements under applicable local law.

Legal/Compliance: We and our Canadian, US and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud or as otherwise required or permitted by applicable Canadian, US or other law (including reporting requirements under applicable anti-terrorism, anti-money laundering and similar laws and regulations). Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

Sale of Business: In addition, personal information may be disclosed or transferred to another party during a prospective business transaction including in the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Paycase or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

How is Your Personal Information Protected?

We maintain reasonable physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from theft, loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.

Your online access to certain of your personal information may be protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

The security of your personal information is important to us, please immediately advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Cookies, Interest-Based Advertising, and Additional Information about our Website

Visiting our Website

In general, you can visit the Website without telling us who you are or submitting any Personal Information. However, we and/or our service providers (such as Google Analytics) collect IP (Internet protocol) addresses from all visitors to the Website and other related information such as page requests, browser type, operating system and average time spent on our Website. This information is used to help us understand our Website activity, and to monitor and improve the Website.

Cookies, Tracer Tags & Web Beacons

Our Website uses a technology called "cookies". A cookie is a tiny element of data that our Website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our Website where you are prompted to log in or that are customizable. If you have registered with our Website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to deliver products and personalized services, and (3) will provide us and our service providers with information that we will use to personalize our Website in accordance with your preferences. We and our service providers (such as Google Analytics) also use cookies to help us understand our website activity, to improve our Website and provide better customer service. For more information about Google Analytics, see www.google.com/policies/privacy/partners/.

You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the features of our Website.

Our Website may also use a technology called "tracer tags" or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.

Interest-Based Advertising

We may use third parties to serve advertisements on our Websites and on other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our Websites and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant to you, both on and off our Websites. To learn more and to opt-out of having your information used by these companies for online behavioural advertising purposes, please visit youradchoices.ca/choices

Analytics Services

From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise.

We may use third-party web analytics services, including but not limited to those of Google Analytics and Mixpanel. These providers track user activity and help us analyze how users use our services. The information collected will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of our services. For more information on how Google Analytics collects and processes data, please click How Google uses data when you use our partners sites or apps. To prevent Mixpanel from using your information for analytics, you may also use Mixpanel’s opt out by clicking here. Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser's cookie file (including upgrading certain browsers) you may also clear the Mixpanel opt-out cookie.

Third Party Links

Our Website may contain links to other sites that we do not own or operate, including social media websites. Also, links to our Website may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information changes during the course of our relationship with you, please keep us informed of such changes by contacting support@paycase.com.

Access to Your Personal Information

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. If you want to access, review, verify or correct your personal information, please contact our Privacy Officer at the contact information set out below. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we or our service providers treat your personal information or to withdraw your consent to our personal information processing (subject to legal or contractual requirements), please contact our Privacy Officer in writing or by e-mail.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. The contact information for our Privacy Officer is as follows:

Paycase Financial Corp.
325 Front St. West
Suite 4
Toronto, Ontario
M5V 2Y1
legal@paycase.com

Revisions to this Privacy Policy

Paycase, from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we collect, use, disclose or otherwise treat your personal information. We will post any revised version of this Privacy Policy on our website, and we encourage you to refer back to it on a regular basis.

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