LAST UPDATED: November 13, 2020

INTRODUCTION

Treasure Financial Inc. and our affiliates ("Company" or "We") respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

• How we collect, use, disclose, and protect the personal information of our customers and website and mobile application users ("you").
• The types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use the Treasure Financial mobile application or the https://www.treasurecard.com website (collectively, the "App").
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your and/or your family’s personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

This policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with this App.

This policy DOES NOT apply to information that:

• We collect offline or on any other Company apps, or websites you may access through this App. 
• You provide to or is collected by any third party (see Third-Party Information Collection).

Our websites and apps, and these third parties have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your and/or your family’s information. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you indicate that you understand, accept, and consent to the practices described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your and/or your family’s personal information. Note that you may be unable to use the App if you choose not to agree to a change to this Privacy Policy. 

SPECIAL NOTICE TO KIDS, TWEENS, TEENS AND THEIR PARENTS

Please note that if you are a “minor” (meaning you are less than 18 years old and live in Alberta, Manitoba, Ontario, Prince Edward Island, Quebec or Saskatchewan, or you are less than 19 years old and live in British Columbia, New Brunswick, Newfoundland, Northwest Territories, Nova Scotia, Nunavut or Yukon), we cannot enter into an agreement with you.  This means your parent or legal guardian will have to review and agree to this Privacy Policy and our Terms of Use (https://www.treasurecard.com/terms) so that you can use the App.  Please do not use the App until they do.  

Remember to be smart online. Do not give out your full name, e-mail address, home address, telephone number or any other personal information that would enable someone to contact you either online or offline, without first asking your parent or guardian for permission. 

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect information about you through:

• Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us. 
• Automated technologies or interactions, when you use the App, for example, usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies.

The types of information that we collect include:

• Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, date of birth, IP address, user name or other similar identifier, billing and account information (including bank account routing information), social insurance number, and any other identifier we may use to contact you ("personal information").

Parents share their user accounts with their children. We collect full names and dates of birth for minors from their parents.

We provide an opportunity for any user to unsubscribe from our mailing list or opt-out of contact for marketing purposes  on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails, or e-mailing to feedback@treasurecard.com.

• Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. We may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific app feature.
• Technical information, including your login information, device type, time zone setting, and usage details.

Information You Provide to Us

When you download, register with, or use this App, we may ask you to provide:

• Information by filling in forms in the App. This includes information you provide when registering to use the App, subscribing to our service, signing up for our mailing list, posting material, or requesting further services. We may also ask you for information  when you report a problem with the App.
• Records and copies of your correspondence, including email addresses and phone numbers, if you contact us.
• Details of transactions you carry out through the App and order fulfillment. We may require you to provide financial information before placing an order through the App.
• Your search queries on the App.

You may also provide information for publication or display ("posted") on public areas of websites you access through the App and/or the https://www.treasurecard.com website (collectively, "User Contributions"). You post and transmit User Contributions to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect. We cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we do not guarantee that unauthorized persons will not view your User Contributions.

Automatic Information Collection and Tracking Technologies

When you download, access, and use the App, it may automatically collect:

• Usage details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, logs, and other communication data and the resources that you access and use on or through the App. 
• Device information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
• Stored information and files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location information. This App does not collect real-time information about the location of your device.

 The technologies we use for this automatic data collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone or on the hard drive of your computer. It may be possible to refuse to accept cookies (or mobile cookies) by activating the appropriate setting on your smartphone or browser. However, if you select this setting you may be unable to access certain parts of our App. By allowing a minor to use the App, a parent agrees to the placement of cookies on the minor’s computer or device.
• Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).  By allowing a minor to use the App, a parent agrees to the placement of web beacons on the minor’s computer or device.

Other than your IP address, the information we collect automatically is statistical data and does not include personal information. 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. This usage information helps us to improve our App and to deliver a more personalized service, including by helping us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences and customize our App according to your individual interests.
• Speed up your searches.
• Recognize you when you use the App.

If you do not want us to collect this information do not download the App or delete it from your device. For more information, see Choices About How We Use and Disclose Your and/or Your Family’s Information.

Third-Party Information Collection

When you use the App or its content, certain third parties collect information about you or your device. These third parties may include: 

• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Your mobile device manufacturer.
• Your mobile service provider.

These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you use the App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps and other online services. They may use this information to provide you with behavioural advertising or other targeted content. You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties' tracking technologies or how they use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

HOW WE USE YOUR AND/OR YOUR FAMILY’S INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To provide you with the App and its contents.
• To provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided it or that were described when it was collected, or any other purpose for which you provide it.
• To provide notices about your account and/or subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights in any contracts with you, including for billing and collection or to comply with legal requirements.
• To notify you when App updates are available, and of changes to any products or services we offer or provide though it.
• To improve our App, products or services, or customer relationships and experiences.
• For marketing purposes.
• To allow you to participate in interactive features, social media, or other features on our App.
• To measure or understand the effectiveness of the advertising we serve to you and others.
• For any other purpose with your consent.

Usage information that we collect helps us to improve our App and to deliver a better and more personalized experience, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our App according to your individual interests.
• Speed up your searches.
• Recognize you when you use the App.

We may also use your and/or your family’s information to contact you about goods and services that may be of interest to you, as permitted by law. If you do not want us to use your and/or your family’s information in this way, please adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at feedback@treasurecard.com. For more information, see Choices About How We Use and Disclose Your and/or Your Family’s Information.

DISCLOSURE OF YOUR AND/OR YOUR FAMILY’S INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our affiliates.
• According to applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Treasure Financial Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Treasure Financial Inc. about our customers and users is among the assets transferred.
• To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may provide them with aggregate conversion data).
• To contractors, service providers, and other third parties we use to support our business, such as analytics and search engine providers that help us optimize and improve our services. We contractually require these third parties to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process personal information following the same standards set out in this policy.
• To fulfill the purpose for which you provide it.
• For any other purpose we disclose when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, according to applicable law.
• To enforce our rights arising from any contracts between you and us and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Treasure Financial Inc., our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.

TRANSFERRING YOUR AND OR YOUR FAMILY’S PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide us to contractors, service providers, and other third parties we use to support the App (such as analytics providers that assist us with App improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your and/or your family’s personal information in and to other countries with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your and/or your family’s personal information. Whenever we engage a service provider, we require that its privacy and security standards comply with this policy and applicable Canadian laws.

You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.

By submitting your and/or your family’s personal information or engaging with the App, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR AND/OR YOUR FAMILY’S INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your and/or your family’s information: 

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies some parts of this App may not be accessible or may not function properly. For more information about tracking technologies, see Automatic Information Collection and Tracking Technologies. 
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish for us to use your email address to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to feedback@treasurecard.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes.

We do not control third parties' collection or use of your and/or your family’s information to serve behavioural advertising. These third parties may provide you with additional choices about how they use your and/or your family’s information or ways to choose not to have your and/or your family’s information collected or used in this way. You can opt out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your and/or your family member’s device. Opting out of a network does not mean you will no longer receive advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

DATA SECURITY

The security of your and your family’s personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your and your family’s personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions and other financial information will be encrypted using SSL technology.

The safety and security of your and/or your family’s information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of our App, you are responsible for keeping it confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards, which any Website visitor can view.

Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your and your family’s personal information, we cannot guarantee the security of your and/or your family’s personal information transmitted through the App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any App privacy settings or security measures. 

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your and/or your family’s 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 or aggregate your and/or your family’s personal information so that it can no longer be associated with you and/or your family members. 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. 

MINORS

We will only collect personal information from a minor where necessary and only if we have the consent of the parent or legal guardian to do so. Parents should supervise the use of the App by minors.  There are many activities on the App that minors can participate in and enjoy without having to share personal information.

Parents can contact our Privacy Officer (as noted below) to request to review, amend, update or have deleted a minor’s personal information from our records, to withdraw their consent to our collection, use and/or disclosure of such personal information, or refuse to permit a further use of a minor’s personal information.

ACCESSING AND CORRECTING YOUR AND/OR YOUR FAMILY’S PERSONAL INFORMATION

It is important that the personal information we hold about you and/or your family members is accurate and current. Please keep us informed if your and/or your family’s personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you and/or your family members.

You can review and change your and/or your family’s personal information by logging into the App and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your and/or your family’s personal information you may also send us an email at feedback@treasurecard.com to request access to, correct, or delete any personal information that you and/or your family members have provided to us. We cannot delete your and/or your family’s personal information except by also deleting your account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your and/or your family’s personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your and/or your family’s personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your and/or your family’s personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their personal information or confidential commercial information.
• Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at feedback@treasurecard.com.

If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other App users. Proper access and use of information provided on the App, including User Contributions, is governed by our terms of use https://www.treasurecard.com/terms.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your and/or your family’s personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at feedback@treasurecard.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision. 

CHANGES TO OUR PRIVACY POLICY

We may update our privacy policy from time to time. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated. 

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at: 

Privacy Officer

Treasure Financial Inc., 48 Yonge Street, Suite 400, Toronto, Ontario Canada M5E 1G6 and/or feedback@treasurecard.com 

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

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