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PRIVACY POLICY

LAST UPDATE: August 16, 2021

INTRODUCTION

Zip Co Payments Canada ULC (“Zip”, “we”, “us” or “our”) respects your privacy and wants you to understand how we handle personal information.

This policy describes how we collect, use, disclose, and protect personal information when you visit our website www.Zip.co/ca-en (our “Website”), download or use our mobile application that links to this Privacy Policy (our “App”) or otherwise interact with us or use our services in Canada (together with the Website and App, the “Services”).

We may amend this Privacy Policy at any time by posting a revised version on our website (see Changes to Our Privacy Policy). The revised version will be effective as of the ‘last modified’ date above.  You will be deemed to have accepted the updated Privacy Policy if you continue to use the Zip Services after the new Privacy Policy takes effect.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use Zip Services.

INFORMATION WE COLLECT ABOUT YOU

When we refer to “personal information” we mean information about an identifiable individual. We collect personal information when you provided it to us directly.  We may also collect personal information automatically when you use the Zip Services and from third parties.

Information You Provide to Us

When you register to use Zip Services, we will ask you to provide personal information including:

  • your name, mailing address, e-mail address and telephone number;
  • date of birth;
  • billing and account information, such as your credit or debit card information;
  • social insurance number if you choose to provide it.
  • If you choose to sign up to receive information and offers from Zip, we will ask you to provide your name and email address.

If you participate in community discussions, chats or similar public areas of the Zip Service we will collect the personal information that you choose to provide.  Please be aware that these areas are viewable by everyone and any personal information that you choose to provide may be accessed, collected, used and shared by others for any purpose.  We are not responsible for the information that you choose to make available in these areas and we recommend that you exercise caution when doing so.

 

If you choose to participate in our contests or promotions, we will ask you to provide personal information such as your name and contact information.

If you contact us with questions or concerns, or participate in our surveys, we will collect the personal information that you choose to provide to us.  Please note that for quality assurance, training and record keeping purposes, Zip may monitor or record our telephone conversations with you or anyone acting on your behalf (you will be notified prior to any recording).

We may collect other personal information with your consent or as permitted or required by law.

Information we collect automatically when you use Zip Services

We collect details of the transactions that you carry out through Zip Services, the fulfillment of your orders and the searches that you conduct through the Zip Service.

We use automatic data collection and tracking tools to collect information about your use of the Website, App and other Zip Services, and for tailored advertising purposes.  Please see Cookies and Tracking below.

Information we collect from third parties

With your consent, we may collect information from other members of the Zip corporate family or other companies. This information may include personal profile data account transaction information, and other information that you have provided to those other companies or which they have collected or generated in their interactions with you.

With your consent, we obtain credit and identity information about you from third parties such as credit bureaus and identity verification services with whom we have contractual relationships.  We use this information to verify your identity, creditworthiness and eligibility for the Zip Services.

You may choose to provide us with access to certain personal information stored by third parties such as social media sites (e.g., Facebook and Twitter). The information we may receive varies by site and is controlled by that site and your privacy settings on that site.

HOW WE USE YOUR INFORMATION

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience with the Zip Services. We use information that we collect about you or that you provide to us, including any personal information to:

  • provide Zip Services and customer support
  • communicate with you regarding your account or the Zip Services, including to notify you of any updates or changes
  • respond to your requests or inquiries
  • process transactions and send notices about your transactions
  • verify your identity, including during account creation and password reset processes
  • resolve disputes, collect fees or other amounts owed to us, and troubleshoot problems
  • manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities
  • detect, prevent or remediate violations of policies or applicable user agreements
  • improve the Zip Services by customizing your user experience
  • measure, analyze and gain insights into the performance of the Zip Services and maintain or improve their content, design, delivery and layout
  • manage and protect our information technology infrastructure
  • provide targeted marketing and advertising, deliver promotional offers and solicit feedback, including through surveys
  • perform creditworthiness and solvency checks, compare information for accuracy and verify it with third parties
  • other business or operational purposes compatible with the context in which the personal information was collected
  • prevent fraud and other illegal activities
  • comply with applicable law
  • defend our legal rights

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information to:

  • Members of the Zip corporate family, to help detect and prevent potentially illegal acts and violations of our and their policies, and to guide decisions about their products, services, and communications. Members of our corporate family will use this information to send you marketing communications only if you have requested their services or otherwise expressly consented.
  • Financial institutions that we partner with to jointly create and offer a product that you have requested.
  • Credit bureaus and collection agencies to report account information, as permitted or required by law.
  • Banking partners as required by credit card association rules for inclusion on their list of terminated merchants.
  • Persons or companies who may invest or have invested in us, or with which we plan to merge, or which we are considering acquiring or being acquired by. (Should such a combination transaction occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information unless otherwise permitted or required by law.)
  • Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Zip or one of its affiliates; when we need to do so to comply with law or credit card association rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
  • Merchants and service providers as described below.
  • Other third parties with your consent or direction to do so.

How We Share Personal Information with Merchants

When transacting with merchants of goods and services (“Merchants”), we may provide those parties with information about you necessary to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction.

We do not share your bank account information or card account information with any Merchants.

We work with third parties, including Merchants, to enable them to accept or send payments from or to you using Zip. In doing so, a third party may share information about you with us, such as your email address or mobile phone number. We use this information to confirm that you are a Zip customer and that Zip as a form of payment can be enabled, or to send you notification of payment status. Also, if you request that we validate your status as a Zip customer with a third party, we will do so.

Please note that Merchants and other third parties from whom you buy or with whom you contract will have their own privacy policies, and although Zip’s user agreement does not allow the other transacting party to use any personal information we give them for anything other than providing Zip’s Services, Zip is not responsible for their actions, including their information protection practices.

Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you using Zip, or with the third parties that offer or use Zip Services, except with your express permission or if we are required to do so to comply with applicable credit card association rules, a subpoena, or other legal process.

Service Providers

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties (“Service Providers”) we use to support our business (such as analytics and search engine providers that assist us with Website 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.  Zip and its Service Providers may process personal information outside of Canada, including in the United States, Australia, the Philippines or the United Kingdom.  While outside of Canada, personal information will be subject to applicable foreign laws, which may permit governments, courts, law enforcement, or regulatory agencies of that country to access personal information in certain circumstances.

COOKIES AND TRACKING

We and our third-party providers use cookies and similar technologies to collect information about your activities on the Zip Services and across third-party websites or other online services. The technologies used include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Zip Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Zip Services.

Local Stored Objects. Certain features of our Zip Services may use local stored objects to collect and store information about your preferences and navigation to, from, and on our Website. Local stored objects are not managed by the same browser settings that are used for browser cookies.

Web Beacons. Pages of our Website and our e-mails 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 website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

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. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of Zip Services may not be accessible or may not function properly.

We use these tools to collect information such as: the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information. We use this information to helps us to improve our Zip Services and to deliver a better and more personalized service, including by enabling us to: estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our Zip Services according to your individual interests; speed up your searches; recognize you when you return to our Website.

When you download or use our App, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device’s setting’s menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.

Some content or applications on the Website, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Zip Services. 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 and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support our Zip Services.

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 here. 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.

DATA SECURITY

The security of your personal information is important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, no security measures can offer absolute security and therefore we cannot guarantee the security of your personal information transmitted to our Zip Services. Any transmission of personal information is at your own risk.

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

DATA RETENTION

The file containing your personal information is maintained on our servers or those of our service providers and will be accessible by authorized personnel who require access for the purposes described in this policy.  Except as otherwise permitted or required by applicable law or regulation, we will only retain your 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 de-identify your personal information so that it can no longer be associated with you. 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.

YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

You have the right to withdraw your consent to our collection, use or disclosure of personal information at any time, subject to contractual and legal restrictions.  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 with your decision.

You have the right to request access to and to correction of the personal information that we hold about you.  We may request 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 personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Please contact us as described in the Contact Us section below to request access to or correction of your personal information or to withdraw your consent.

You can also review and edit your personal information at any time by logging in to your account and reviewing your account settings and profile. You can also close your account.  If you close your Zip account, we will mark your account in our database as “Closed,” but may retain personal information from your account for a certain period of time in accordance with our record retention policies.

You can unsubscribe from our marketing communications at any time by using the unsubscribe mechanism at the bottom of our e-mails, logging into your account and going to the notifications section and updating your preferences or contacting us as described in the Contact Us section below.

THIRD PARTY SITES

If you open a Zip account directly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a Zip website) will be accessible to the owner of the third party website or application. These sites are governed by their own privacy policies, and you are encouraged to review their privacy policies before providing them with personal information. Zip is not responsible for the content or information practices of such third parties.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

CONTACT US

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices, including with respect to our use of Service Providers outside of Canada. Please contact our Privacy Officer at [email protected]