NovoCard Privacy Policy

About this Policy

The privacy and confidentiality of the personal information you provide is important to us. HorizonFlare Technology Limited, the company offers NovoCard services (“NovoCard”, “we”, “us” or “our”) is committed to protecting the privacy and confidentiality of personal information in our possession and control.

This Privacy Policy (“Policy”) sets out how we collect, use, maintain, disclose and otherwise treat the personal information of our users and all other individuals (“you”). For the purpose of clarity, this includes individuals who: (i) apply for our products or services; (ii) are currently our customers or who have been our customer in the past; (iii) use our website or mobile application (together referred to as “Digital Platforms”); or (iv) either directly or indirectly, communicate with us.

“Products” refers to products and services offered by NovoCard.

We update this Policy from time to time to ensure all individuals are aware of updates to our privacy practices, to streamline those practices and to comply with applicable laws. We will inform you of changes to the Policy by posting updates to it here and updating the Last Updated date. Please visit this web page regularly for updates.

Capitalized terms that are used but not defined in this Policy have the meaning given to those terms in the NovoCard User Terms.

1. Personal Information

Personal information is information about an identifiable individual as defined by applicable laws.

Examples of personal information include:

• Name, date of birth, age, mailing or residential address, phone number, email address, occupation, and marital status;
• Employment and educational information, including income;
• Financial information like credit bureau information, Social Insurance Number, assets and liabilities, tax forms, and transactional information;
• Biometric information like voice recording, fingerprints, facial images, signature, etc.;
• Behavioural information like click activity, apps used, etc.;
• IP address, device location, browser activity.

Please note that this Policy does not apply to information that is not considered personal information.

2. Accountability

At NovoCard, we are dedicated to protecting your privacy and safeguarding the personal information you have entrusted to us. We are responsible for personal information in our possession or custody, as well as personal information transferred to a third party for processing on our behalf.

We have appointed a Privacy Officer to oversee privacy matters. To contact our Privacy Officer, please reach out via the contact details provided in the Contact Us section below.

3. Collection

We collect, use and disclose personal information to operate our business and provide you various Products, in accordance with applicable laws. We collect most of the information with your consent when you interact directly with us, but we may also collect personal information indirectly and/or through third parties.

Connecting with us: We may collect information you provide, including when you: (i) visit or use our website or mobile application; (ii) register or apply for one of our Products; (iii) communicate, interact, transact with or through us; (iv) participate in special offers, enter contests or complete surveys; (v) contact us with questions, inquiries, complaints or suggestions; (vi) provide us with documents or other files or (vii) engage with us in any other way (including when you post content on or directed at us on social media).

Use of Products: If you use one of our Products, we may collect information about you and your use of our Products, including transactional information. Additionally, we may collect personal and financial information about you, including employment related information and credit history, from third party sources and credit bureaus. We may ask you for a copy of your eligible government ID and we may request that you send us a selfie to verify your government ID.

Digital and online information: We may collect information when you use or interact with us using digital or online channels, including our Digital Platforms. This may include browser name, type of computer and technical information used to connect to our website or mobile application, such as operating system and the Internet service providers utilized and other similar information. We use this information to understand how you interact with our Digital Platforms, and to make improvements.

Cookies and Similar Technologies: We use cookies (small computer files that a website’s server places on your computer) on our website to collect information about your online behaviour. We use cookies to enhance user experience, and to provide us and our partners with information about your use of our Digital Platforms. You can set your browser to reject cookies, but this may impair our ability to customize and test your experience, like remembering your preferred language or presenting province-specific information to you.

Our Digital Platforms may also use technologies like tracer tags or web beacons that allow us to understand which pages of our website or mobile application you visit. These technologies are used to help us organize and tailor our Digital Platforms for you and other future visitors.

We may use third parties to serve our advertisements on our Digital Channels or other websites. These companies may use technologies like cookies, tracer tags or web beacons to report certain information in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Digital Channels.

Third Parties and Public Sources: We may collect information about you from public sources and third parties that we have contracted with, who help us assess, process, collect on, make offers for and service your account, such as credit reporting agencies or affiliates. This includes credit bureaus, government institutions, program partners, other financial institutions, and third party identity verification providers.

Communication: When you have a telephone conversation with one of our representatives, your call may be recorded for quality and training purposes, as well as to resolve concerns. If you choose to contact us by email, chat or mail, we may retain your email address, the content of your communication and our response.

Other individuals: You may share information about other individuals with us, such as spouse, common law partner, dependant, landlord, etc. By providing this information, you confirm that you have obtained their consent to share their details with us and understand that their information will be handled in accordance with our Policy.

4. Identifying Purposes

We collect, use or disclose personal information for the purposes set out in this Policy or as may be disclosed to you at the time of or prior to the collection, use, or disclosure.

Provide Services: We will use your information in order to provide you access to our Products, including: (i) process your application for our Products; (ii) set up and manage your Products; (iii) establish and verify your identity; and (iv) resolve any issues you may have in relation to them.

Communicate with you: We will use your information in order to contact you by various methods, including mail, email, SMS message and telephone at the contact points you have provided to us. We will contact you to: (i) respond to your questions; (ii) send you marketing and servicing communications; (iii) proactively provide you with information about our Products; and (iv) update you on changes to our website, mobile app, and other digital services. When you communicate online or by email, you should be aware that sending information over the internet is not secure, as it can be intercepted and/or manipulated and retransmitted.

Authenticate You: We may use your information to confirm your identity or authenticate you, including by sharing your information with credit reporting agencies or other third parties. We may verify your identity: (i) when you apply for our Products; (ii) before we communicate with you or process your instructions; and/or (iii) when you visit us online or on our mobile app.

Assess your creditworthiness or eligibility: We may use your information to assess your creditworthiness and determine your eligibility for our Products. In order to do this, we may provide your information to and collect your information about you from credit reporting agencies or other third parties.

Automated Decision Making: We may, for certain purposes, render a decision based exclusively on automated processing of your personal information. For instance, in relation to your identity verification, we may use automated processing to validate your identity. We may also use such automated processing to review your account regularly for fraud prevention and to determine your eligibility for our Products. You may contact our Privacy Officer if you require more information on this practice.

Make Improvements: We may use the information we collect to: (i) conduct research and analysis; (ii) improve our Products, customer experience and Digital Channels; (iii) develop new products, services and features; (iv) customize our Products and offers; and (v) drive strategy. Information we collect is also valuable for ensuring quality of our service and for developing training programs.

Marketing Purposes: We may use your information to: (i) better understand your needs and preferences, in order to provide you with information and offers we believe may be of interest to you; (ii) identify you on a third-party platform and serve you ads through their marketing platform or use the algorithms of those platforms to find other people with similar characteristics; and (iii) provide targeted advertisements.

Manage our business: We may use the information to: (i) perform our everyday business and operations, including meeting our contractual obligations, record keeping, and internal reporting; (ii) understand and manage our business better; (iii) conduct business transactions, such as fund raising, joint ventures, partnerships, etc.; (iv) administer referral arrangements; (v) ensure the security of our networks and IT infrastructure, and (vi) insure, reinsure or otherwise protect our interest.

Other Purposes: We may use the information for other legitimate purposes in compliance with applicable laws and this Policy, including fraud detection, ensure compliance with applicable laws, and to enforce our rights.

5. Sharing of Information

We may use or disclose personal information for the purposes we identify and as required by applicable laws. These include the following:

Service Providers: We may disclose personal information to our service providers that perform services on our behalf. These providers may include identity verification providers, payment processors, financial institutions, fraud detection companies, collection agencies, cloud storage providers, and other companies that help manage our operations. These providers are required to keep your information secure.

Advertising Partners: We may disclose personal information to our advertising partners who help us run our advertising campaigns, analyze our site, run contests, special offers, or other events or activities, and track metrics on our behalf or in connection with our Services.

Credit Bureaus: We may disclose your personal information (including payment history) to credit bureaus for the purposes of updating, accessing and maintaining your information in their records, undertaking credit checks, assessing your creditworthiness and making decisions in relation to your use of our Products.

Merchants: We share your information with merchants in connection with your payments. For example, when you use NovoCard to initiate a purchase with a merchant, we will provide the merchant your information for the merchant to process and fulfill your transaction.

Affiliates: We strive to give you streamlined services and eliminate repetition and annoyances. To help manage your total relationship with us and to ensure we provide you with the best Products, we may share your information with affiliates of NovoCard (except where the law doesn’t allow it).

Partners: We may share your personal information with other trusted partners to help us provide, improve, and personalize our products and services.

Corporate Changes and Securitisation: We may disclose personal information in connection with proposed or actual: (i) financing, capital raise, securitization or insurance transaction; (ii) merger, sale, assignment or disposal of all or part of NovoCard’s business or assets; and/or (iii) transactions being entered into by NovoCard with a third party. Assignees or successors of NovoCard or our business or assets may use and disclose your personal information for similar purposes as those described in this Policy.

Compliance with Laws: We may share your personal information if required to do so by law or in response to valid legal processes, such as subpoenas, court orders, or government investigations. We may also disclose information to protect our legal rights or comply with applicable legal obligations.

Other purposes: We may share your personal information with third parties for other purposes, if you have provided your consent to do so.

Aggregate Data: We may share aggregated, anonymized, or de-identified data that does not personally identify you with third parties for research, analysis, marketing, or other purposes.This information cannot be linked to a specific or identifiable individual.

When sharing information, we ensure that appropriate safeguards are in place to protect your data. This may include the use of encryption, secure data transmission, and contractual measures that require the compliance with applicable data protection laws. The recipient of the data is also obligated to handle your data responsibly and in accordance with applicable privacy laws and regulations.

6. Other Jurisdictions – Transfer

We may transfer personal information we collect about you to jurisdictions other than the jurisdiction in which the information was originally collected and your personal information may be processed and stored outside of your jurisdiction of residence, including outside of Canada. Those jurisdictions may not have the same data protection laws as your jurisdiction of residence.

If you wish to obtain further information about sharing of your personal information to parties outside of Canada, please feel free to contact us.

7. Protecting Information

We have established policies and procedures, and have adopted appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of personal information. Personal information is maintained on our servers or those of our service providers and is accessible to authorized employees, representatives, and agents who require access in connection with their job responsibilities.

If you are a customer, your online access to certain of your personal information is protected with a password you select. We also recommend that you use unique and strong passwords for your online account(s) and change them as often as required. You must not disclose your password to anyone as it may lead to financial harm and identity theft. We will never ask you for your password in any unsolicited communication (such as letters, phone calls, or email messages). If we learn of a breach, where required, we will inform you and the appropriate authorities of the occurrence of the breach in accordance with applicable law.

While NovoCard takes all reasonable measures to protect data and safeguard your personal information, there is always inherent risk when providing personal information, which can include financial harm caused by bad actors and identity theft. Risks may also arise from human error such as accidentally sending an email containing personal information to an unauthorized individual. As such, you can help us safeguard your information too. If you contact us through email or social media, you should avoid sending highly sensitive information, such as your banking information or full card number. If someone who states that they are representing NovoCard contacts you and requests your personal or financial information, and you are suspicious, you can always contact us to confirm that the request was legitimate.

8. Consent

You consent to the collection, use and disclosure of your personal information as described in this Policy by: (i) using our website or mobile application; (ii) applying for or using our Products; (iii) interacting with us in any manner; and/or (iv) providing us with personal information.

If we want to use your information for a purpose that was not disclosed at the time of initial consent or under this Policy, consent will be sought at the time of processing for this new purpose.

9. Your Rights and Choices

You can exercise a number of rights under Privacy laws, but these rights may vary depending on the jurisdiction where you reside. We will respond to your request to exercise your rights within thirty (30) days.

Withdrawing Consent: You can withdraw your consent for use and disclosure of your personal information, other than that which is necessary for us to: (i) maintain your account (ii) provide Products for which you were approved; (iii) meet our legal and contractual obligations; and (iv) to exercise our rights. Withdrawing consent may impact your ability to use our website, mobile app, and Products.

Access, Update and Rectify: You have the right to access, correct, and update the personal information we hold about you. We’ll make reasonable efforts to process your request in a timely manner. In certain cases, we may charge a nominal fee to cover the costs of providing access to your information. We will inform you of the cost in advance in that case.

Deletion: You have the right to request the deletion of your personal information that we hold. We will process your request in accordance with applicable laws, though certain information may be retained as required for legal or business purposes.

Marketing Opt Out: You may ask that we not use your personal information for marketing purposes by using the unsubscribe feature found within our marketing communications, where applicable. Please note that if you ask us not to use your personal information for marketing purposes, you may still see certain types of ads from us (for example, online), but these will not be tailored to your interests.

Portability: You may ask us to transfer computerised personal information that we hold about you in a structured, commonly used and technological format.

Unless otherwise specified, to exercise these rights, please send a written request to our Privacy Officer using the contact information as set out in the Contact Us section below. Please note that your rights are subject to contractual and legal restrictions and reasonable notice.

We may take reasonable steps to verify your identity before processing your request.

You may also contact our Privacy Officer if you have any complaints about our Privacy practices or the information contained in this Privacy Policy.

10. Retention

We retain information for a variety of business and legal purposes, including retention of data to comply with anti-money laundering legislations. Please be aware that this period of retention may extend beyond the end of your relationship with NovoCard. NovoCard will destroy or erase personal information once it is no longer required to fulfill the identified purposes or to satisfy legal or regulatory requirements.

11. Third Party Links

Our website or mobile app may contain links to other websites that we do not own or operate. Also, links to our website or mobile app may be featured on third party websites on which we advertise. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, 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.

12. Children’s Privacy

Our website and mobile application is not directed to individuals below the legal age of majority in their respective province (18 or 19 years old, as defined by provincial regulations) and we do not knowingly collect information from children under the age of eighteen. Subject to applicable laws, if we become aware that we have inadvertently received information from a visitor under the age of eighteen on our website or mobile application, we will delete the information from our records.

13. Changes to Policy

NovoCard may update or change this Privacy Policy at any time. When we do, we will revise the updated date. We encourage you to frequently check this page for any changes to stay informed about how we handle personal information. You acknowledge and agree that it is your responsibility to review this Policy periodically and become aware of modifications.

Your continued use of our website, mobile app or Products following the posting of changes to this Policy will be deemed your acceptance of those changes.

14. Contacting Us

For privacy-related requests, to raise a privacy concern, or for more information about our Privacy policies and practices, please contact our Privacy Office at privacy@novocard.ca. Please note, this email address will only be monitored for privacy-related requests.

NovoCard

www.novocard.ca

This document was last updated on February 2, 2025.