LAST UPDATED: November 13, 2020
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:
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:
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.
SPECIAL NOTICE TO KIDS, TWEENS, TEENS AND THEIR PARENTS
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:
The types of information that we collect include:
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 email@example.com.
Information You Provide to Us
When you download, register with, or use this App, we may ask you to provide:
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:
The technologies we use for this automatic data collection may include:
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:
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:
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:
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:
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 firstname.lastname@example.org. 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.
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:
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.
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.
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.
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 email@example.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:
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at firstname.lastname@example.org.
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 email@example.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.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
Treasure Financial Inc., 48 Yonge Street, Suite 400, Toronto, Ontario Canada M5E 1G6 and/or firstname.lastname@example.org
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.