In Charge may provide third party content or links to third-party web sites or applications. When you leave our Services or interact with a third-party feature, you should read the applicable third party’s privacy policies and terms of service to make sure you understand how they might collect and share information about you.
We do not share your Charge score, Credit Card Score, or reports with third parties (except agents acting on our behalf; as further explained below) and we do not share your Personal Information with third parties for their advertising or marketing lists without your consent.
COLLECTION AND USE OF INFORMATION
The ways we collect information about you include:
information you give us
information we collect about you based on your use of our Services
INFORMATION YOU GIVE US
You may give us information about you when you use our Services or by communicating with us. This includes information you provide when you create an account to build and track your financial standing. through various forms, provide us with feedback, participate in surveys, contests or promotions and when you contact us with a question or to report a problem.
The information you give us may include your name, contact information (such as mailing address and email address), date of birth, income, information about your rent or mortgage payments, credit-related information, your financial goals, referral source and your student loan information. You will not be asked for your social insurance number when signing up for the personal finance service.
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.
INFORMATION WE COLLECT ABOUT YOU BASED ON YOUR USE OF OUR SERVICES
Each time you visit our Website we may automatically collect certain information about how you access and interact with our Services. We and third parties may use various technologies to collect, use and store this information. These may include cookies, browser web storage, web beacons and similar technologies. The information we may automatically collect includes the following:
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number
technical information, including the Internet protocol (IP) address, device information, device operations, your login information, browser type and version, time zone setting, operating system and platform
location information, including your internet protocol (IP) address or other device information or information about your visit to estimate your location (e.g., your city or province).
See Cookies and Interest-Based Advertising below for more information
USE OF INFORMATION WE COLLECT
Some examples of how we use the information we collect:
provide you with Services, such as building your free budget.
manage your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message or other electronic means about your account
verify your identity as part of our identity authentication process and other information you have provided to us (including your credit card info, employment and income)
provide you with information, products and Services
notify you about changes to our Services
ensure that content from our Website is presented in the most effective manner for you and your device
aggregate it on an anonymous basis with other data for data analysis and reporting purposes
meeting legal and regulatory requirements
detecting and preventing fraud and other unauthorized or illegal activities
as otherwise permitted or required by applicable law.
If you have provided your consent, we may provide you with information about In Charge or other products and services we feel may interest you or be best for you based on information we have about you (including emails, text messages, and notifications).
You can opt-out any time by contacting us as set out under Contact Us below.
You can opt-out of receiving marketing emails at any time by clicking on the unsubscribe link included in our marketing email communications. Please note that you may continue to receive certain transactional or account-related emails from us.
SHARING OF INFORMATION WE COLLECT
We will not disclose, trade, rent, sell or otherwise transfer your Personal Information, without your consent, except as otherwise set out herein. We use information we hold about you to provide our Services to you and improve those services, manage your account and communicate with you and to use information on an anonymous basis for research, profiling and analytical purposes.
Service Providers: Your Personal Information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf. In Charge uses service providers (including its authorized sub-contractors) to provide services such as billing, administration, debt collection and advertising and analytics services, to verify information you have provided to us (such as your identity and bank account number) and to administer pre-authorized debit agreements. In Charge may use service providers to host the Website, send email, SMS text messages or other communications, or manage and analyze data and our advertising effectiveness. Your Personal Information may be maintained and processed by In Charge, affiliates and other third-party service providers in Canada 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. Service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose Personal Information for their own marketing or other purposes.
Business Partners: If you use certain Services we will share certain personal information we have about you (such as your contact information) with third party business partners. In these situations, we will confirm with you that we will be sending your information or we will send you to the business partner’s site or platform for you to provide the information directly to them.
Legal/Compliance: In Charge and its affiliates in Canada 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 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 or other law. 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: Personal Information may be transferred as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of In Charge or as part of a corporate reorganization or stock sale or other change in corporate 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 to 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 sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. Cookies may provide us and our service providers with information that we will use to personalize our Website in accordance with a user’s preferences. 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 the features of our Website.
We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. For more information or on opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.
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.
We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and third-party websites and Apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate our online advertising campaigns.
Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.
Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may, therefore, be less relevant to you and your interests.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
THIRD PARTY LINKS
SAFEGUARDS AND RETENTION
We maintain your Personal Information on a confidential basis on servers located in Canada. We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your Personal Information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.
We have Personal Information retention processes designed to retain Personal Information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements (which may extend beyond the end of your relationship with us).
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. You may request access, updating and corrections of inaccuracies in Personal Information we have in our custody or control by emailing us at the contact information set out below. You may also update certain contact information through our online portal. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records.
Please contact our Privacy Officer if:
you wish to access, update, and/or correct inaccuracies in your Personal Information, or
you otherwise have a question or complaint about the manner in which we or our service providers treat your Personal Information.
You may contact our Privacy Officer by email at email@example.com.