October 1, 2019

Who we are

SimpoPay is committed to protecting its visitors’ and Users’ privacy. The following Privacy Policy outlines the manner in which SimpoPay Inc. (hereafter “SimpoPay“, “we“, “our” or “us“) collects, uses, discloses and otherwise manages personal information, including in connection with our website www.simpopay.ca (the “Website“), our mobile customer application (the “App“) and our on-demand services (collectively, the “Service“). Please review the following carefully so that you understand our privacy practices.

If you have questions about this Privacy Policy or how SimpoPay handles your data more generally, please contact us at privacy@simpopay.ca

Definitions:

  • User/you: A person who has signed up and is registered with SimpoPay for the use or potential use of the Service.
  • Merchant: The local business having sole responsibility [Must be set out in Terms of Use] for receiving and preparing redemptions for the User

INFORMATION WE COLLECT ABOUT YOU

SimpoPay collects your personal information when you interact with us or use our Service, such as when you use our Website or App to place a redemption. We also collect information about you from other sources described below. We also look at how visitors use our Website to help us improve our Service and optimize customer experience.

In general, we collect information:

  • when you create an account with us or you change your account settings;
  • when you place a redemption with us and during the redemption process; and
  • when you browse and use our Website and App and in-store devices.

We also collect information from third party sites, such as advertising platforms and social networking sites.  

INFORMATION WE COLLECT FROM YOU

SimpoPay collects personal information to deliver our Service to you, including through our Website and App. We collect personal information from you, such as:

  • Account Information: We collect information when you create or update your SimpoPay account. This may include your name, email address, photo, birthday, country, language, currency, password, mobile phone number, social accounts should you choose to connect them, and limited banking information (including related point redemption verification information). We may also ask you about your preferences
  • If you interact with one of our in-store devices and enter your information into the device, we may also store this information in accordance with this Privacy Policy even if you have not created an account
  • Your Location: SimpoPay requires your consent to track geo-location for use of the App. When you use the App through your mobile device, we will track your geo-location information, on a real-time basis. Depending on which other products and services you use, we may also collect your precise or approximate location through your IP address or Wi-Fi.
  • SimpoPay collects location information when our App is running in the foreground (i.e. when you are actively using the App). If our app is running in the background, we will only collect your location information when it is required for the fulfillment of your redemption. For example, if you have a redemption in progress. Our geo-location tracking will stop once your redemption is complete.
  • You may use the App without enabling SimpoPay to track your location; however, this will affect the functionality available to you. For example, we would not be able to connect you to merchants near you.
  • Redemption Information: We collect details related to your use of our Service. This can include:
    • what you purchased;
    • date and time of the purchase;
    • amount paid for your redemption;
    • location information (such as distance and route);
    • your point redemption; and
    • used a promotion code.

INFORMATION WE COLLECT FROM OTHER SOURCES

SimpoPay may also collect and combine personal information about you from other sources. These other sources may include:

  • Users providing your information as part of a dispute;
  • business partners such as third-party providers, social media services, or other apps and websites that SimpoPay has integrated with;
  • publicly available sources; and,
  • marketing service providers.

From time to time, SimpoPay may also combine information from various sources with information it collects.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the purposes communicated to you at the time of collection or as otherwise stated in the Terms of Use, including:

  • Provide our Service to you: SimpoPay uses the information we collect to provide, maintain, personalize, and improve our Service.

We will use your personal information to:

  • Create and manage your account. This includes using your phone number or email address to verify your identity.
  • Show you Merchants near you. We use your location to allow you to view the Merchants in your area. Your location also allows us to provide a walk distance and to determine when a redemption should be placed.
  • Facilitate redemption fulfilment and pick up. If you place a redemption via SimpoPay, your redemption and profile information is shared with our Merchant partner for the purpose of fulfilling your redemption in accordance with our contract with you. This includes a photo, if you have chosen to upload one. The Merchant that is fulfilling your redemption uses this photo to verify your identity. 
  • Enable the various features of our product for our legitimate interests (further discussed below) where we have considered that these are not overridden by your rights.
  • Troubleshoot software bugs and operational problems.
  • If you upload a photograph to your profile, your photograph will be used by the merchant to identify you. This may include having your photograph visible on our in-store device when your redeem.
  • User content and communication: SimpoPay may use content you submit such as photos, to make recommendations to other Users and to facilitate the operations of our business. SimpoPay may also allow Users to communicate with others on their team or with Merchants. These messages, should you choose to participate, may be accessible by members of your team or Merchants and by us. SimpoPay may also allow Merchants to communicate with users. For example, a Merchant may contact you directly if there is a problem with your redemption.
  • Research and development: SimpoPay may use your personal information for testing, research, analysis, and development of our Services. This allows us, for our legitimate interests, to improve our Service improve the in store experience our merchants offer, and to determine where we should offer or focus our Service. We may share this information with third parties for industry analysis and statistics.
  • User support: We use your profile, account, and usage information to assist you when you contact User support. This allows us to direct your inquiry appropriately, investigate and assist you with your inquiry, and follow up to ensure the problem does not persist. We may also use your information to monitor and improve our User service responses.
  • We may also use your real-time geo-location information to address User or Merchant support, technical, or business issues that may arise in the course of your use of the App. If you contact SimpoPay User service while a redemption is in progress, and it is necessary to use your real-time geo-location information to address your question, our support personnel will seek your consent before consulting your location.
  • Communications from SimpoPay: SimpoPay uses your contact information to communicate with you about your activity, our Service, your account, and, if we have your prior consent, about SimpoPay news, special offers, and events. We may also contact you about studies and surveys, if you have permitted us to do so.
  • If you have placed a redemption through the App, we may send you push notifications to your mobile phone to let you know your redemption. If you do not want to receive push notifications, you can always withdraw your consent by changing your settings via the settings page of your mobile device.
  • We may also need to communicate with you about your account or SimpoPay’s Service. For instance, we may send you an email to verify your username and password or let you know when our Service is temporarily suspended for maintenance.  
  • Only where we have your prior consent to do so, SimpoPay may also use your contact details to send you general updates regarding SimpoPay news, special offers, promotions, and contests. If you have entered your information into one of our in-store devices, we may follow up with you regarding your inquiry. We may also display tailored advertisements on third-party websites and other platforms. You may opt-out of receiving these updates at any time by following the instructions in each of our communications.
  • Public forums: The Website and the App may offer publicly accessible blogs and community forums. We will use your personal information such as your name, email address, the messages or content you choose to post to administer and provide you with these services.

Security: We may deactivate your account if we suspect that you use our App or Website to commit fraudulent or illegal acts or if you violate our Terms of Use.

DISCLOSING YOUR PERSONAL INFORMATION

  • Sharing with our Service Providers: We may employ third-party companies and individuals in Canada, where SimpoPay is present to facilitate or provide certain services on our behalf, such as to provide User support, provide geo-location information to our Merchants, to host our job application form, to perform Website-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Website’s features) or to assist us in analyzing how our Service is used.

The file containing your personal information will be kept at our offices or on our servers or those of our service providers. Our employees and those of our service providers who require it for the purposes of their duties will have access to this file.  

These third parties have access to your personal information only to perform these tasks on our behalf and are contractually bound not to disclose or use it for any other purpose. For additional information about the way in which our service providers treat your personal information, contact us as set out below.

Your personal information may be transferred outside the jurisdiction in which you are situated and may become subject to the laws of the receiving jurisdiction, which may differ from the laws of your jurisdiction. By using our Service, you consent to the transfer of your personal information outside of your jurisdiction for the purpose of storing your personal information or processing it.  

If you would like more information about these safeguards, please contact us at privacy@simpopay.ca

  • Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of SimpoPay or as part of a corporate reorganization or other change in corporate control.
  • Legal Requests: SimpoPay, our Canadian businesses, and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or redemption, or to an organization in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian or English law. SimpoPay may also disclose your personal information to the extent that this is legally required, or necessary for the establishment, exercise or defense of legal claims and legal process; to investigate or prevent actual or suspect loss or harm to persons or property; to detect, prevent or suppress fraud; or in the event of an emergency pertaining to your health and/or safety; or to our auditors, legal advisors and other professional advisors.

COOKIES AND RELATED TECHNOLOGY

SimpoPay uses cookies and other related technology such as Google Analytics on the App and Website to distinguish you from other users.

Cookies are data files commonly stored on your device when you browse and use websites. They help to make your online experience faster and assist with things like personalization, reporting, and advertising. Cookies are not the only technology that enables this functionality. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. 

DIRECTION MARKETING

Where you have given your consent or where we have a justifiable reason for doing so (and are permitted to do so by law) we will use your information to let you know about our other products and services that may be of interest to you and we may contact you to do so. If you do not wish to receive direct marketing communications from SimpoPay, you can adjust your email preferences in the App or by clicking the unsubscribe link in our email message to you.

HOW LONG DOES SIMPOPAY RETAIN PERSONAL INFORMATION?

We will generally retain your personal information until you cancel your SimpoPay account in order to meet our contractual obligations to you or until it is no longer required for the purposes stated above or to otherwise meet legal requirements.

We will not retain your personal information for any longer than we think is necessary. Information we retain is for as long as needed to fulfill the purposes outlined in this Privacy Policy. When determining the relevant retention period, we consider:

  • our contractual obligations and rights in relation to the information involved;
  • legal obligation(s) under applicable law to retain data for a certain period of time;
  • statute of limitations under applicable law(s);
  • our legitimate interests where we have carried out balancing tests (see the section on ‘How we use your personal information’ above);
  • guidelines issued by relevant data protection authorities; and
  • other legal purposes.

Otherwise, we securely erase your information where we no longer require your information for the purposes collected. After the deletion of your account, we will anonymize your data, unless this data is necessary to comply with a legal obligation or resolve disputes. If you wish to cancel your SimpoPay account or request that we no longer use your information to provide you services, please contact us at privacy@simpopay.ca

HOW DOES SIMPOPAY PROTECT PERSONAL INFORMATION?

  • Our safeguards: SimpoPay takes appropriate technical, physical and organizational security measures to protect personal information in our custody and control against unauthorized access, use, modification and disclosure, and accidental loss, destruction and damage. For example, we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) as well as physical safeguards at the locations where data is stored. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Any transmission of information by you to SimpoPay is at your own risk. Where you have chosen a password that allows you to access our Website or App you are responsible for keeping this password confidential. We strongly recommend that you do not share your password with anyone.
  • Third-party links: Our Website or App may contain links to other sites that SimpoPay does not own or operate. Except as provided in this Privacy Policy, we will not give any of your personal information to these third parties without your consent. We provide links to third-party websites as a convenience. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

DOES SIMPOPAY USE AUTOMATED DECISION-MAKING PROCESSES?

Fraud detection is conducted in part using automated decision-making processes. We conduct fraud checks on all of SimpoPay’s customers. Where we believe there may be fraudulent activity, we may block you from placing a redemption and from using our Website or App. We also may also use automated decision-making processes to extend certain benefits or rewards to you such as discounts at particular Merchants. 

WHAT HAPPENS IF SIMPOPAY UPDATES OUR PRIVACY POLICY?

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email and by means of a notice on the Website. We encourage you to periodically review this page for the latest information on our privacy practices.

HOW DO I CONTACT SIMPOPAY?

Questions about how we treat personal information? Please contact our Privacy Officer by email at privacy@simpopay.ca if you have any questions or comments about this Privacy Policy, any question or complaint about the manner in which we or our service providers treat your personal information, or if you wish to exercise any of your rights in relation to your personal information, including any right to have access to the file containing your personal information and to request the correction of such information.