>Canada Privacy Policy & Cookie Notice

Effective as of October 1, 2024

This Privacy Policy (“Policy”) describes the privacy practices of Wagestream Canada, Inc. ("Wagestream," "we", “us” or "our") and how we handle personal information that we collect through www.wagestream.us, online products, mobile applications, and/or other digital properties (collectively, “Services”).

Wagestream operates a financial wellness platform, enabling employees of its Clients to access their earned wages, track and save their wages and access independent financial education. This Policy applies to our collection of personal information (i.e. information that may identify, relate to, describe, references, is capable of being associated with or could reasonably be linked, directly or indirectly, with you or your device). This Policy applies to employees of our Clients who use our Services and website visitors.

If you reside in the US, please see our US-specific Privacy Notice located here.

If you reside in Europe, please see our UK/EEA-specific Privacy Notice located here.

How Do We Collect Personal Information?

• From you. We may collect personal information and other information that you provide when you communicate with us, register for our Services, select marketing preferences, register for promotions, or otherwise use our Services.
• From your employer. If your employer is our Client, we may collect personal information and other information your employer provides to us about you in accordance with applicable law. Where required by law, we will obtain your consent in order to collect personal information directly from your employer.
• From devices you use when you interact with us online. This includes information collected through our Services and automatically from devices you use to connect to our Services. For more information about this, please see our “Cookies and similar technologies” section below.

We only collect personal information from you with your consent where such consent is expressly required by law. When you choose to sign up for Wagestream, you will be asked to provide your express consent to the collection, use and disclosure of your personal information in accordance with this Policy. While you are not obliged to provide your consent, if you refuse, we may be unable to provide you with certain Wagestream products or services.

The Types of Personal Information We May Collect From You

Depending on how you interact with us, we may collect the following information:

• Contact Information such as your name, home address, work address, email address, telephone number, or other similar identifiers.
• Biographic and Demographic Information such as date of birth, social insurance number.
• Financial and Payment Information such as debit card details, earnings and timecard information, gross and net pay, bank account number, financial institution, name of the owners of the bank account, payment preferences.
• Account Information such as a username and password for our Services, profile details you choose to provide, and feedback and reviews you may leave our Services.
• Internet Usage Information such as geolocation, IP address, interactions with our marketing materials, and any other Internet usage information our Services may record when you visit.
• Device information such as browser or device model and settings, operating system, and unique identifiers.
• Other Personal Information you provide during your communications with us, including interactions with us online, in-person, or on the phone.
• Professional Information such as employer and employment status, and any other information that may be obtained from employer background checks, and feedback.

How We Use Your Personal Information

We may use your information for the following reasons, depending on your relationship with us:

• To communicate with you, such as when we respond to your inquiries and send you communications, such as those regarding our products and services.
• To provide, market, and develop our products and services, including to provide our Services, maintain our websites, troubleshoot, provide customer and technical support, and conduct data analysis, test and research, and better understand the interests of our users who use our services and products.
• To facilitate wage payments and enable you to voluntarily access your third-party products such as any savings accounts you wish to link to our Services.
• To understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns).
• To maintain the safety, security, and integrity of our Services, for example by authenticating users and providing account security and fraud detection. We may also use your information to monitor, detect, and prevent fraud and improper or illegal activity.
• To send you news and/or marketing communications (by email, phone, or text) in accordance with applicable law and subject to your marketing preferences and choices, including information about us or third-party offerings we think may be of interest to you.
• To market and advertise, including through direct marketing and interest-based advertising.
• To conduct market research and develop quality assurance, including to study, develop, and improve our products and services. Where permitted by law, we may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any business purpose, including product development and improvement activities.
• To comply with legal requirements and/or to investigate or address claims or disputes relating to your use of the Services. This would include the use of your information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigations.
• To enforce the terms and conditions that govern our Services.
• To conduct internal business purposes, including for data analysis, audits, and enhancing our services. We may also use inferences drawn from personal information to create a profile reflecting your preferences so we can tailor our Services to you.

We may also use your information for additional purposes with your consent and will specifically ask in these instances for your consent to collect, use or share your personal information, such as when required by law. We may also use your information as required or permitted by applicable law.

How We Disclose Personal Information

We may disclose information collected from or about you with any of the following entities and for any of the following purposes:

• Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
• Your employer. We may provide personal information to your employer from which we obtained the information and with parties your employer directs us to disclose this information for the purposes of managing the service. Further, for quality control purposes, we may share support inquiries with your employer to ensure resolution of your support ticket.
• Service Providers and Advertising Partners. We may provide personal information to vendors, payment processors, contractors, banking partners, search engine providers, business and service partners, or other third parties, such as advertising partners who provide services to us including analysis firms, advertisers, and others.
• Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
• In connection with a merger, acquisition, or business transfer. In accordance with applicable law, if we sell all or a part of our company, are part of a merger, consolidation, restructuring, sale of company shares, and/or sale of assets or other corporate change, your information may be transferred.
• At your direction. We may disclose your personal information at your direction or with your consent.
• Business partners. We may share personal information with business partners with whom we jointly develop or promote our services, including sponsorships and co-branded opportunities and promotions.
• Aggregate Data. We may share your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you.

Cross-Border Transfers

The affiliates, service providers, and other third parties to whom we may transfer or disclose personal information (as described above) may be located outside of your home jurisdiction (including outside of Canada), and you acknowledge that personal information may be processed and stored in foreign jurisdictions. Applicable laws in those other jurisdictions might permit foreign governments, courts, law enforcement, or regulatory agencies to access the information in those jurisdictions. In these cases, we will comply with applicable local law requirements relating to the conditions for disclosure or release of personal information.

Children's Privacy

You must be 14 years or older to use our Services or have reached the age of consent/majority in your jurisdiction of employment or have obtained parental or guardian consent for the use of the Services where required by law. Our Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 14 years of age.

Links to Third Party Websites

We may provide links to websites and other third-party content (e.g., social media platforms) that are not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.

If you provide any personal information through a third-party site, your interaction and your personal information will be collected by and controlled by the privacy policy of that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

Advertising and Opt-Out Disclosures

When you use our Services, our third-party advertising partners, social media providers and analytics providers may collect personal information about your online activity on our Services and on third party websites.

These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver Wagestream advertisements to you when you visit third party websites within their networks. If you would like more information about this practice and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page (currently available at http://www.aboutads.ca) or the Network Advertising Initiative’s opt-out page (currently available at http://www.networkadvertising.org/choices/). Please note that you may continue to receive generic ads that are not based on your preferences.

Information Security

We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in our possession against loss, theft and unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.

Cookies and Similar Technology

We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, local Storage, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, other content you viewed, and search history.

We and our partners may use also use these technologies to gather personal information about how you view and use our Services and content, and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Services. The use of these technologies helps us serve you better by understanding what you're interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We may allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools. These approved partners each have their own privacy policy addressing how they use the information and any choices you have about their collection and use of information. We recommend that you review these policies.

Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies such as cookies. To find out more about cookies, visit www.aboutcookies.org. Also, certain versions of the Android operating system allow you to “Opt-out of Ads Personalization” in the system settings. Options you select are browser and device specific.

Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT or a common definition of “tracking,” we do not currently respond to the DNT signal on our websites. We do, however, respond to global privacy preferences when required by law.

Your Marketing Preferences

We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt-out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email. You may unsubscribe from text messages you previously consented to by following the prompt provided on our messages. We will work to comply with your request promptly and in any event in accordance with applicable laws.

There are certain service notification and other non-promotional emails that you may not opt-out of, such as notifications of changes to the Services or policies.

Your Rights

Depending on your jurisdiction of residence, you may have certain rights in relation to the personal information that we collect, use, disclose, communicate or otherwise process about you. These rights may include:

Right to be informed: You may have the right to be informed about the personal information that we collect, use, communicate, or otherwise process about you, and how it is handled. This information is conveyed through this Policy, additional policies and procedures, and by addressing specific questions and requests when you contact us.

Right of access: You may have the right to access and receive a copy of the personal information that we hold about you. Upon written request and confirmation of your identity, we will provide you with access to the personal information that we hold about you. We will also inform you upon request of the manner in which your personal information is being used and a description of the persons to whom that information has been communicated. To the extent permitted by applicable laws, a reasonable fee may be charged for the transcription, reproduction or transmission of such information.

Rectification. You may have the right to request that we update, complete, or correct inaccuracies in your personal information that we hold about you, if you demonstrate the inaccuracy or incompleteness of the personal information that we hold. If necessary and if required by applicable law, we will send the corrected personal information to third parties to whom the information has been communicated. If a request regarding the accuracy of the personal information that we hold about you is not resolved to your satisfaction and if required by applicable law, we will annotate the same with a note that a correction was requested but not made. If such a request is not granted, the request itself will be documented in your file.

Withdraw consent. You have the right to withdraw your consent to our use, communication, or further processing of your personal information at any time after you have consented. Please note that this may impact our ability to continue to provide certain products, services, or functionalities to you. Withdrawing consent does not affect the lawfulness of any use or communication of your personal information by us up to that point and does not oblige us to delete your personal information if we are otherwise allowed to retain it under applicable laws.

If you are a resident of the province of Quebec, you may also have the following additional rights:

Portability. You may have the right to obtain a machine-readable copy of your personal information that we hold or to have us transfer it to another third party of your choice.

De-indexation. You may have the right to request, in certain circumstances, that we cease disseminating your personal information or to de-index any hyperlink that allows access to that personal information by technological means, if such dissemination causes you harm or contravenes a court order or applicable laws.

Please contact us at [email protected] if you require any further information on the rights applicable to you or if you wish to exercise these rights.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). Where required by applicable law, we may need to ask you to confirm your consent to the processing of your personal information. In all other cases, your use of the Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

• Email: [email protected]
• Mail: 1201 Wilson Boulevard, Suite 25-135, Arlington, VA 22209