") sets out the manner in which Hello Network Inc ("we
") collects, uses, discloses and otherwise manages the personal information of our applicants, cardholders and other users of its products and services ("you
"), our mobile application (the "App
") (collectively the "Sites
"), and through other interactions with you.
Collection and Use of Personal Information
You consent to the collection of personal information from you directly, such as information provided in your Hello Visa* Prepaid Card (the "Card") application and when you connect your Card using the App, as well as from third-party identity verification service providers and affiliated partners that offer reward programs.
Card Application: When you apply for a Card, we ask that you provide us with your first name, last name, date of birth, address, phone number, mobile number, email address and occupation. We or our authorized service providers collect and use your personal information for the purposes of verifying and confirming your identity. If we cannot verify your identity with our authorized identify verification service providers, you may be asked to provide additional information in the form of original documents (e.g. hydro bill, telco bill, bank statement, etc.). We or our authorized service providers also use the information you provide to assess your Card application, approve the opening of your Account, administer, service and enforce the Cardholder Agreement (including detecting, suppressing and preventing fraud and other unauthorized or illegal activities), as well as to comply with applicable legal, regulatory and security requirements, managing risk, administering our anti-money laundering program and as otherwise permitted by applicable law.
Account: If you create a Hello Account ("Account") by connecting your Card through the App, we may ask you to provide your Card’s reference ID and the last 4 digits of your Card’s number, as well as the password you create. We use this information to authenticate you and administer your Account.
Activity Information: We collect transactional information about your Card usage, including purchases, account balances and payment history, for the purposes set out above, and to provide you with services in relation to the Card and the App, including providing rewards programs. You agree that we may also use this information to provide you with tailored promotions and communications.
Loading Funds: Different funding options will be offered, allowing you to add funds to your "open wallet" (see Cardholer Agreement for details) and which may require the collection of different types of information. Within the App, you will be provided a list of available funding options. The funding option you choose will dictate what information we will collect and use.
Rewards Programs: Upon your Card application being approved you may be enrolled in rewards programs offered by Hello and any of our affiliate partners and merchants in relation to the use of the Card. We collect information about your purchase transactions made using your Card (i.e. amount spent at a specific merchant) for the purposes of administering your participation in the rewards programs and in communicating with you. From time to time, we may supplement your personal information with information from publicly available sources and information collected by our affiliate partners in order to better understand your preferences and interests in order to tailor the promotions and rewards provided to you. For more information about such programs, please consult our Terms and Conditions available on the Website.
Email, Mobile Push Notifications, SMS Text Messaging and Other Marketing Communications: We may provide you with the opportunity to sign up for various types of marketing communications, such as information about our products and services, rewards programs or marketing promotions from our affiliate partners. These communications may be conveyed by email, mobile push notification, SMS text messaging, telephone or direct mail and may be tailored to your interests, preferences and purchase behavior. You may opt-out of receiving future marketing and promotional communications at any time by clicking on the unsubscribe link included in our email communications, replying STOP in any SMS text message communication or by managing your communication preferences in the App. Please note that if you unsubscribe from marketing communications, you may still continue to receive certain transactional or account related electronic communications from us.
Activity Alerts: You will receive alerts (such as transaction activity alerts, account update or fraud alerts, or general account information alerts) by email, mobile push notification or SMS text message. We collect your preferred email address or mobile phone number in order to deliver the alerts and administer your participation in the alerts program. You can change your alert notifications or unenroll at any time in the App.
Customer Service: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) as well as additional information necessary to validate you are the person you say you are (i.e. your Card’s reference ID), in order for us to answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and product and service offers. Please refer to Safeguards and Retention section for more information.
Information and Analytics on our Sites
In general, you can visit our Sites without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Sites and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand activity on our Website, to provide you with content relevant to your jurisdiction and to monitor and improve our Website. If you download and install our App, we also collect information about your mobile device. This data includes the type of device hardware and operating system, unique device identifier (such as MAC address), IP address, language settings, and the date and time the App accesses our servers. We use this data in order to enable our App to function on your device, to provide the services you request and to improve our App. We may also use third parties to help us gather and analyze information about the areas that you visit on our Sites in order to evaluate and improve the customer experience and the convenience of our Sites. We or our service providers may collect information using tracking technologies, including: cookies, tracer tags, web beacons, physical beacons and GPS.
Our Website may also use a technology called "pixel tags", "tracer tags" or "Web Beacons". This technology allows us to understand which pages you visit on our Website in order to help us optimize and tailor our Website for you and other future visitors to our Website. We may also use this technology in emails to help us confirm the receipt of and response to our emails, the time our email is viewed, and "click through" information such as what email links you click.
Location Based Services: If you consent, we may collect your actual location while you are using our App in order to provide you with the location-based service you requested (such as to show you nearby promotions). To disable the collection of location data, visit the settings in the App or the settings of your device.
Online Ads/Interest Based Advertising
To learn more about online behavioural advertising or to opt out of having your information collected and used for online behavioural advertising purposes by companies participating in the Digital Advertising Alliance of Canada, please visit https://youradchoices.ca/en/tools
and select either WebChoices or AppChoices (to control interest-based advertising across mobile apps). 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). When you opt-out, it 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. Please note that if you opt-out of Online Behavioural Advertising (OBA), you may still receive online advertising from us, but it will not be based on online behavioural information about you.
Links to Other Sites
Disclosure and Sharing of Personal Information
We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out herein.
Service Providers: Personal information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf. For example, we use service providers for transaction and payment processing, printing and mailing cards, verifying or authenticating your identity and information you have provided us, administering our anti-money laundering program, fraud detection and suppression, sending email, mobile push notifications, SMS text messages or other communications, hosting our website or managing and analyzing data and our advertising effectiveness. Our 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. Personal information may be maintained on servers located in the United States ("US") and processed by us, our affiliates and other third-party service providers in the US or other jurisdictions.
Rewards Programs: We may exchange personal information about your account or your participation in the rewards programs with other parties as required to administer the program, such as affiliate partners and merchants.
Non-Personally Identifiable Information: We may disclose or share information that does not allow or provide the ability to identify you or a specific person ("Non-Personally Identifiable Information"). For example, we may share aggregated demographic information or use third party service providers to track and analyze Non-Personally Identifiable Information related to usage and volume to gather statistical information from our users. Such data is collected on our behalf and is owned and used by us.
Legal Compliance: We, our affiliates and our Canadian, US and other foreign service providers may provide personal information in response to a search warrant or other legally valid inquiry or order (which may include disclosure to Canada, US or any other courts, law enforcement and government authorities in accordance with the laws of those jurisdictions), or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing of preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law. Personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Safeguards and Retention
You must use appropriate measures to protect your personal information
We protect personal information in our possession or control against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The safeguards employed by us to protect your personal information depend on the sensitivity, amount, distribution, format and storage of the personal information. We employ around the clock monitoring systems and controls in compliance with industry standards to detect and prevent fraudulent activity. We also build fraud prevention measures into our due diligence processes and regularly update our fraud detection/prevention methods. While we take reasonable precautions to protect your personal information, you agree that no security system is completely secure from a breach. If we become aware or suspect that a security breach has occurred, we agree to take action promptly, to investigate the actual security breach, to identify and mitigate the effects of any such security breach and to implement reasonable and appropriate measures in response to such security breach, including, but not limited to, immediate remedial action designed to prevent any future such occurrence.
We have personal information retention processes designed to retain your personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.
Upon written request and subject to proof of identification, you may access and/or rectify the personal information we have collected, used or disclosed, as permitted or required by Applicable laws.
Governing Law and Jurisdiction
You are also advised that information we collect on you is retained in cloud-based servers which may be located in Canada, the United States and/or other jurisdictions. You acknowledge and agree that: (i) by providing information to us you consent that such information be transferred through and to the third party services providers selected by us at our absolute discretion, and shall be treated in accordance with the laws of Canada, which may offer less stringent consumer rights than the jurisdiction in which you reside, and (ii) for commercial and security reasons, the location of the servers storing information at any given time is deemed to be confidential information of us and will not be disclosed to you.
Hello Visa Prepaid Card is issued by Peoples Trust Company pursuant to licence by Visa Int.
*Trademark of Visa International Service Association and used under licence by Peoples Trust Company.
Effective: December 1st, 2019