This is the Privacy Policy (“Policy”) for Hutsy Financial Corp. (“Hutsy”). It outlines what information is collected by Hutsy from individuals who interact with the Hutsy website at https://hutsy.ca/ (the “Website”), and the Hutsy mobile application (the “App”), and how that information may be used, and the express authorizations required in order for Hutsy to provide services to you in relation to the App.

By visiting the website in order to receive information about the Hutsy platform, or create an account on the App, you consent to Hutsy collecting, storing, using and disclosing your personal information in accordance with the terms of this Policy. Updates to the Policy will be posted within the App and on the website.

If you are under eighteen years of age, you may not submit Personal Information to Hutsy. By creating an account in the App or website you are consenting to and agree to be bound by the terms of this Policy.

If you have a Hutsy account and you chose to close your account, you withdraw your consent for the collection and use of your personal information. Hutsy is unable to provide the Account services without your authorization to use your Information in accordance with this Policy. You may close your Account from within the App (under “Personal Settings”). You may also close your Account by sending an email to [email protected]. This Policy shall apply in respect of all Information received prior to the account being closed.

Data Collected

Hutsy collects certain information that can be used to identify you as a specific individual (“Personal Information”) and non-personally identifying information (“Non-Personal Information”) (both together, “Information”) when you register to receive information from Hutsy, register to join the launch, download the App, and when you submit Information to Hutsy in order to apply for and create an Account.

Hutsy collects sensitive information and non-sensitive information. This information is collected when you register for the following:

• To receive information from Hutsy.
• Upon joining the launch.
• When you create an account on the app.

Personal Information: Collection, Retention and Use

Hutsy will only use your Personal Information for the purposes set out in this Policy.

Hutsy collects Personal Information when you provide it to sign up to receive information from Hutsy, create an account, complete your profile, access, and use the website, and when you communicate with Hutsy. Personal Information is collected when provided by you, and includes at least your name, address, telephone number, email address, account information and transaction information, and through the Account.

Personal information is used by Hutsy to create your account, populate and maintain your profile, and provide information to you or otherwise communicate with you for each of these purposes.   

Personal Information is also used by Hutsy for customer service and marketing purposes to let you know of new products and services and notifying you of special merchant offers. You may opt-out of email-based marketing communications at any time by sending an email with “Unsubscribe” to the email address provided in the marketing communication or by clicking on the unsubscribe link at the bottom of the marketing communication. You may opt-out of receiving special merchant offers in the Hutsy mobile app by disabling “Receive merchant offers” in the account profile menu of the Hutsy mobile app.

Reporting

We may keep the information described above along with other information about you in our records, even after your account is closed for the purposes of complying with legal and regulatory obligations. We may use your contact, identity, financial, transaction, counterparty, and third-party information to meet our legal and regulatory obligations including reporting tax, anti-money laundering and sanctions screening, and communicate this information to our banking partners, credit reporting agencies and governmental or regulatory agencies as permitted or required by law.

Due to financial regulations, Hutsy is required to retain personal information for 5 years after your Hutsy account is closed.  After the retention period, Hutsy will delete and purge personal information from its database.

Non-Personal Information: Collection, Retention, and Use

Hutsy will only use your non-personal information in accordance with the current Policy.

Non-personal information is collected when you visit the website through cookies or similarly purposed technologies, including technical and statistical information such as your IP address, mobile device identifiers, operating system, and page views and duration.

Non-personal information is used by Hutsy providing related services for its business operations and planning, including the operation and improvements to the website, debugging, product research, evaluation and development. While this information is related to you, it is not personally identifying information.

Disclosure of your information

Hutsy will not disclose your personal information to any third party in a way that is personally identifiable to you or any other specific user other than as specifically outlined in this Privacy Policy. Hutsy does not sell your Personal Information to any third party.

Hutsy may disclose and share your personal information with any third party as required to process your requests and the transactions requested by you, and with companies providing related services to Hutsy.

Hutsy may share with any third party that it deems appropriate, aggregate anonymized information regarding the website, Hutsy’s mobile app, users of the website, and users of the Hutsy mobile app such as demographic and geographic territory of end users, customer preferences, technical performance, and usage statistics. These third parties may include, for example, business partners or companies who assist Hutsy in providing or supporting the Hutsy platform.

Hutsy may share any personal or non-personal information if required by law, if it believes it is required to do so in order to comply with an order of a court of competent jurisdiction or other legal requirements of any governmental authority, it if believes doing so would potentially mitigate its liability in an actual or potential lawsuit or if it believes it is necessary to protect its rights or property.

Data Protection and Security

Hutsy takes your privacy and the protection of your Information seriously and takes commercially reasonably measures to ensure its security. However, no transmission of Information over the internet can be guaranteed to be uninterrupted or completely secure, and accordingly Hutsy cannot, and does not, guarantee that your Information will not be unlawfully accessed by a third party.

Hutsy does not warrant the security of any information you transmit electronically, and you do so at your own risk.
Changes to the Policy

Hutsy may revise this Policy from time to time. Changes and the updated Policy will be published on the website and identified by the publication date. Hutsy will notify you of any material updates to the Policy which have a direct impact to you. 

Please revisit this page and review the Policy during your use of the website and Hutsy services to ensure that you are aware of the information collected, retained, and used, and the authorizations granted by you pursuant to this Policy. Your continued use of the app following the publication of an update to this Policy confirms your acceptance of the updated Policy terms.

Representation of Age

By submitting personal information to Hutsy, you represent that you are over eighteen (18) years of age and that you authorize the collection, use, and disclosure of your personal information by Hutsy as described in this Policy, and any subsequent revisions to this Policy that we may publish on the Hutsy website. If you are not at least eighteen (18) years old, you may not submit personal information to Hutsy. The Hutsy platform is restricted to Canadian residents who are the age of majority in their province or territory of residence.

Opting out of Marketing Communications

To opt-out of marketing communications, Please click on the unsubscribe link at the bottom of the page to opt out of receiving emails. To opt-out of receiving special merchant offers in the Hutsy app by disabling “Receive merchant offers” in the account profile menu of the Hutsy mobile app.

Consent

If you apply for a product or service, communicate with us, or provide personal information to us in any way, you acknowledge your consent for personal information collection, use and disclosure as set out in this Policy, applicable laws and industry standards. If we want to use your information for a purpose that was not disclosed at the time of initial consent, consent will be sought at the time of this new purpose.

Updating or withdrawing consent: Subject to legal and contractual restrictions, you can, with reasonable notice to us, withdraw your consent for use and disclosure of your personal information, other than that which is required for us to maintain your account and to provide services for which you were approved. Please contact our customer service at 1-800-251-3129 for further information on how we can assist you in updating or withdrawing your consent.

Opt out of mail, email, and phone marketing: You can request that we don’t contact you for advertising, marketing, promotions, rewards programs, research or contests, by updating your privacy preferences. You should know that withdrawing your consent in these instances may result in you missing out on offers specific to your account, including increases to your credit limit. Contact by our third-party program merchants and co-brand card partners for advertising, marketing, promotions, rewards programs, research or contests is governed by the privacy policy of the applicable third-party program merchant or co-brand card partner.

You must opt out of the use of cookies separately on the website or the app.

What rights do you have?

You may have certain rights under Data Protection Laws including:

The right to access – You have the right to access your personal data and information about how we process your personal data.

The right to rectification – You have the right to request that we correct any personal data you believe is inaccurate. You also have the right to request we complete personal data you believe is incomplete.

The right to erasure – You may have the right to request that we erase your personal data, under certain conditions. If you enforce this right at the same time as you object to the processing, we will have to maintain basic identification data to ensure we do not contact you again.

The right to restrict processing and withdrawal consent – You have the right to request that we restrict the processing of your personal data, and to withdraw your consent to our processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, this means if you do not want to be contacted for the purposes set out in this notice then we will stop processing your data.

The right to data portability – You may have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you.

Governing Law and Jurisdiction

Hutsy is domiciled and provides its services in the Province of Ontario. Consumers from countries and jurisdictions outside of Canada are advised that this Policy, and the collection, retention, and use of your Information, shall be construed in accordance with and governed by the laws of the Province of Ontario and the federal laws of Canada as applicable.

You are also advised that personal information and non-personal information is retained in cloud-based servers which may be located in Canada, the US and other jurisdictions. You acknowledge and agree that: (i) by providing personal information to Hutsy, you consent that such Information be transferred through and to the third party services providers selected by Hutsy at its absolute discretion, and shall be treated in accordance with the laws of Canada 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 Hutsy and will not be disclosed to you.

Contact Hutsy

If you have any questions, concerns or complaints about our privacy policy or are unhappy with any information or requests you receive from Hutsy via phone, email, or post, we encourage you to contact us immediately at 1-800-251-3129.  In most cases, any questions or concerns that you have can be resolved by discussing them with us or our Privacy Officer.
You may also contact our Data Privacy Officer directly at [email protected] or by mail at:

ATTN: Data Privacy Officer
Hutsy Financial Corp.
2500 – 88 Queens Quay W,
Toronto, Ontario
M5J 0B8

If you have a concern that is not able to be resolved by our Privacy Office you may consider contacting the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada
1-800-282-1376
priv.gc.ca
30 Victoria Street
Gatineau, QC, K1A 1H3