Whish Money Canada Inc., a corporation existing under the laws of Alberta (herein referred to as “we”, or “us”, as applicable) has developed this privacy policy (“Privacy Policy”) to explain how we may collect, retain, process, share and transfer your Personal Information when you visit us at https://www.whish.money (the “Website”), when you use our mobile application (the “App”, together with the Website, the “Platform”) or when you use our cross-border remittance services (the “Services”).
This Privacy Policy applies to our collection, retention, processing, sharing and transferring of your Personal Information on our Platform, or when you interact with us for the provision of our Services. It also applies when you communicate with us via email or other electronic messaging systems, including any other company or third-party website, or when you interact with our advertising and applications on third-party websites and services.
Please read this Privacy Policy carefully. If you do not agree with this Privacy Policy, your choice is to not use our Platform and Services. By accessing the Platform and by using our Services, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy.
This Privacy Policy may change from time to time (see the section Updates to This Privacy Policy). Your continued use of the Platform and the Services after we make changes indicates that you accept and consent to such changes.
If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us using the contact information provided in the Contact Us section of this Privacy Policy.
Personal Information We Collect
Information You Provide to Us. Personal Information you may provide to us through the Platform or otherwise include:
· Identity and Contact Information, including information that we can reasonably use to directly or indirectly identify you, such as your name, date of birth, mailing address (or proof of address), e-mail address, telephone number, account username or other similar identifier, social insurance number, government-issued ID card, banking information or other financial information (such as financial statements), any “know-your-client” information, including identity verification records required under applicable laws including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), regulations and policies made thereunder and other statutes and regulations that take legislative measures against money laundering, terrorist financing and against financial dealings with certain sanctioned individuals and entities, and any other identifier ("Personal Information");
· Business-Related Information, namely, information that relates to your business or business duties, including your title, duties, business address, corporate documents or information, business email address, or business telephone number;
· Communications Data, including your email address and when you contact us through the Website or the App, on social media, email or otherwise;
· Call Recordings. Calls between you and us, our affiliates, or our service providers may be recorded for quality assurance, training, compliance, and dispute resolution purposes. By engaging in such calls, you consent to the recording and use of such recordings in accordance with this Privacy Policy and applicable law.
· Marketing Data, such as your preferences for receiving our marketing communications and details about your engagement with them; and
· Other Data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-Party Sources. We may combine Personal Information we receive from you with Personal Information we obtain from other sources, such as:
· Public Sources, such as government agencies, public records, social media platforms, and other publicly available sources; and
· Data Providers, such as information services and data licensors that provide demographic and other information that we use to provide the Platform and Services.
Automatic Data Collection. We, our service providers, and our business partners may automatically log certain data about you, your computer or mobile device, and your interaction over time with the Platform, our communications and Services, such as:
· Device Data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 5G), and general location information such as city, state or general geographic area;
· Online Activity Data, such as pages or screens you viewed on our Platform, how long you spent on a page or screen of our Platform, the pages you visited before browsing the Website, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them; and
· Communication Interaction Data, such as your interactions with our emails, or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies and Similar Technologies. Some of the automatic collection described above is facilitated by the following technologies:
· Cookies, which are small text files that websites store on user devices to allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our service providers place;
· Local Storage Technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications;
· Web Beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked; and
· Analytics, which are technologies that we may use to process analytics information on our Platform. These technologies allow us to better understand how our digital services are used and to continually improve and personalize our services. Some of our analytics providers include Google Analytics. For more information about how Google uses your Personal Information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
We may use cookies to allow the technical operation of the Platform, enhance the functionality of the Platform, and help us understand user activity on the Platform (including which pages are most and least visited and how visitors move around the Platform, as well as user interactions with our emails).
When you first visit our Website, we will present you with a cookie consent banner that allows you to accept or decline non-essential cookies. Essential cookies that are necessary for the Website to function properly will be used regardless of your choice. You can change your cookie preferences at any time by:
· Adjusting your browser settings to block or delete cookies; or
· Contacting us using the information in the Contact Us section below.
Essential cookies include those necessary for security, authentication, and basic Platform functionality. Non-essential cookies include those used for analytics, marketing, and personalization purposes, which require your consent before being deployed. If you block or subsequently delete those cookies, some aspects of our Website may not work properly, and you may not be able to access all or part of our Website.
How we Use Personal Information
In general, we will only use Personal Information for the primary purpose(s) and applicable legitimate purposes for which it was collected (all of which will usually be identified to you at the time we collect it), or for purposes consistent with these primary purposes. We design our technological products and services to provide, by default, the highest level of privacy protection for your Personal Information. Beyond that, we may use your Personal Information for the following legitimate business purposes (or in other ways that we ask you for at the time we collect it):
Platform and Services Delivery and Operations. We may use your Personal Information to:
· provide, operate and improve the Platform and our business, along with our Services, features or functionalities;
· verify your identity;
· depersonalize or anonymize it;
· communicate with you about the Platform or Services, including by sending announcements, updates, security alerts, and support and administrative messages;
· process applications if you apply for a job with us;
· understand your needs and interests, and personalize your experience with the Platform and our communications; and
· provide support for the Platform and Services, and respond to your requests, questions and feedback.
Marketing. We and our service providers may collect and use your Personal Information to send you direct marketing communications. We may use Personal Information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns, text messages, custom audiences advertising, and “personalized advertising” or “targeted advertising,” including through cross-device tracking.
Compliance and Protection. We may use your Personal Information to:
· comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities;
· protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
· audit our internal processes for compliance with legal and contractual requirements or our internal policies;
· enforce the terms and conditions that govern the Platform; and
· prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including fraud, cyberattacks and identity theft.
With your Consent. In some cases, we may specifically ask for your consent to collect, use or share your Personal Information, such as when required by law, or when we have a new legitimate purpose for using your Personal Information that we did not contemplate at the time it was originally collected from you.
De-Identified and Aggregated Information. We may use Personal Information to create de-identified and/or aggregated information, such as demographic information, information about how you use the Platform, information about the device from which you access our Platform, or other analyses we create. De-identified and/or aggregated information is not Personal Information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes. De-identified and/or aggregated information will not be used to identify individuals.
How we Disclose Your Personal Information
In general, we only share or communicate de-identified or anonymized, aggregated information that does not directly or indirectly identify any individual. However, there are some exceptions to this, as explained below.
Sharing with Affiliates. We may share your Personal Information with our affiliates that help us provide customer support, account administration, identity verification, fraud prevention, and related business operations. This may include sharing KYC (know-your-client) documents and verification materials with our affiliates for identity verification and compliance purposes. These affiliates may access or process personal information outside your place of residence and outside Canada, including in Lebanon. We use contractual and other safeguards designed to protect personal information and require affiliates to use appropriate security measures.
Sharing with Third-Party Service Providers. We may share your Personal Information with third-party service providers and/or partners who provide us with website, application development, hosting, analytics, or other services who need to access or process your Personal Information in connection with the services they provide to us. In such cases, they are contractually bound to keep your data confidential and to comply with privacy laws. You may choose to share Personal Information or interact with third-party websites and/or third-party applications, including, but not limited to, third-party electronic wallet extensions.
Sharing with Employees. Our employees are bound by a duty of confidentiality. They only have access to your Personal Information in an anonymized or de-identified form, on a “need-to-know” basis or if reasonably required by their duties.
Sharing with Legal Authorities. We may also need to disclose Personal Information to comply with a legal obligation or to enforce our rights, including to government authorities and law enforcement agencies where required by applicable law.
Your Privacy Choices and Rights
Under certain circumstances and in accordance with applicable privacy laws, you may have a number of rights when it comes to the Personal Information you provide to us:
Access. Right to ask whether we hold Personal Information about you and the right to access that information.
Rectification. Right to request the rectification of any incomplete or inaccurate Personal Information we hold about you.
Withdrawal of Consent. Right to withdraw your consent to the disclosure or use of Personal Information collected.
Destruction Request. Right to request the destruction of the Personal Information we hold about you.
Request for Information. Right to request certain information relating to decisions based exclusively on the automated processing of Personal Information.
If you would like to exercise any of these rights or other rights, please contact us as set forth in the Contact Us section below. We will process such requests in accordance with applicable laws.
Protection of Personal Information
We follow generally accepted industry best practices and standards to protect the information transferred to us, including Personal Information. We maintain appropriate physical, technical, logical, and administrative safeguards, proportional to the sensitivity of the Personal Information, to protect it from unauthorized disclosure or access, accidental or unlawful alteration, loss or destruction, misuse, or other unlawful form of processing of the Personal Information in our possession.
Although we ensure that adequate safeguards are in place to protect Personal Information, data transmission over the Internet still comes with inherent risks. We cannot guarantee that third party actors will not maliciously attempt to hack our systems, and we are not responsible for third party interceptions of data in transit if they have managed to circumvent our security protocols in circumstances where there were no vulnerabilities or deficiencies in our systems. In those situations, we cannot be held liable for any misappropriation, interception, modification, deletion, destruction, or use of data provided through our Platform.
If you have reason to believe that any Personal Information has been compromised, please contact us as set forth in the Contact Us section.
In the case of a data security breach involving your Personal Information, we will notify you without undue delay after we become aware of such breach, and will work diligently to investigate, contain, and remediate the breach, all as required by applicable law.
Third-Party Websites
The Platform may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services that you use.
International Transfers
We may process, store, and transfer your Personal Information in and to a foreign country, 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 Personal Information through the laws of the foreign country. We conduct Privacy Impact Assessments as required by law before transferring Personal Information outside Quebec to ensure adequate protection measures are in place. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Privacy Policy and applicable Canadian privacy legislation.
You are welcome to contact us to obtain further information about our policies regarding service providers outside of Canada by following the instructions in the section Contact Us below.
Retention of Personal Information
We will retain Personal Information only for as long as necessary for the purposes set out in this Privacy Policy and to comply with our legal and regulatory obligations. To find out more about how long we keep Personal Information, please contact us as set forth in the Contact Us section below.
Updates to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to it, we will notify you through reasonable means, which may include updating the date of this Privacy Policy, posting it on the Platform, and/or sending you a direct notification at least 30 days before such changes become effective. Any changes to this Privacy Policy will be effective upon our posting of the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Platform and/or Services after the effective date of any modifications indicates your acceptance of the modifications. If you have any concerns with any modifications, please contact us to discuss them.
Contact Us
To exercise your rights, file a complaint, obtain information about our policies and practices or if you have questions or comments about this Privacy Policy, please contact our Privacy Officer by email at support@whishmoney.ca. The Privacy Officer is responsible for overseeing our compliance with applicable privacy laws, including Quebec's Law 25, and for handling privacy-related inquiries and complaints.
If you prefer not to receive marketing communications from us through any channel (including notifications, email, postal mail, or phone), please follow the unsubscribe instructions within the relevant communication, adjust your preferences in the settings, or contact us at support@whishmoney.ca. Please note that such requests may take a few days to become effective. In addition, if you ask us to remove your name and address from our email lists, we will maintain your name in a “do not mail” file to ensure that we can honour your request, but you may still receive important communications about your account.
