This Privacy Code (this “Code”) describes the practices that Caary Capital Ltd. (“we” or “us”) employs in the collection, use and disclosure of personal information in respect of clients and prospective clients, including in connection with the provision of our products and services. In this Code, “personal information” means information about an identifiable individual, “client” means the business in whose name an account is registered, and “you” means an identifiable individual associated with a client or prospective client.
This Code may be revised from time to time, so we encourage you to periodically check the current version available. If we revise this Code in a material way, we will change the “Last Updated” date shown at the bottom of this page.
Personal Information We Collect
The personal information we collect regarding a given individual will depend on the products or services a client uses and the role of the individual, but will typically include:
- personal information to identify and communicate with account administrators, authorized signing officers, owners of clients, and cardholders, such as your name, e-mail, date of birth, address, occupation, telephone numbers, copies of your government issued identification and photos of you
- personal information to verify the identity of account administrators, signing officers and owners of clients, such as credit reports, verification of identifying information you have provided and watchlist status
- personal information associated with your usage of one of our products, such as your card number, card status, spending limits, transaction details, transaction receipts, rewards earned and support requests
- personal information of individuals to whom a client wishes to send funds, such as their name, address, bank and account or card number
- product and marketing options and preferences you select, such as language, alerts and marketing or promotional communications
- technical information associated with you when you use our website or mobile application, such as details of the device you use, its operating system, browser type, IP history, referring websites, browsing history, advertisements by us or our partners that you have viewed or clicked and location information.
We may collect such information directly from you when you apply for a product or offer, or communicate with us, from the associated client, through your use of our products and from our service providers and partners, such as credit agencies and identity verification service providers.
We retain personal information only for so long as such information is required for the purposes for which it was collected.
Our Use of Personal Information
We use personal information to:
- process and evaluate applications for our products
- provide our products and services
- manage our business and credit risk
- safeguard against fraud, error and unauthorized use of our products
- understand the needs of our clients, including for product development
- comply with applicable law and regulation
- market and promote our products or services or those of our partners
We may also use personal information for other purposes to which you have consented.
Our Protection of Personal Information
We maintain appropriate physical, electronic, and administrative safeguards to designed to protect personal information, including through the use of appropriate network architecture and firewalls, password requirements, log settings, file integrity monitoring anti-virus software and data encryption.
Our Disclosure of Personal Information
Some of our products are provided in collaboration with partners, such as financial institutions. Usage of personal information by such partners will be governed by the terms and conditions applicable to such product.
We may also collect information about you from additional online and offline sources, including our affiliates, your mobile service provider, credit reporting agencies and other third-party sources as permitted by law.
We may from time to time use third party service providers to facilitate our provision of products. As a result, your personal information may be accessed, administered or stored by such third parties to the extent reasonably required for them to perform such services. Some service providers may be located in other jurisdictions that do not have privacy legislation similar to that found in Canada, and information in such jurisdictions may be accessed pursuant to the laws of those countries.
We may disclose personal information in connection with actual or prospective corporate transactions, such as financings, securitizations, mergers, amalgamations, an asset or share sales or reorganization. Personal information disclosed for such purposes will be subject to the recipient agreeing to hold such information in confidence.
We may disclose personal information to the extent permitted or required by applicable law or regulation.
You may revoke your consent to receive marketing or promotional communications at any time. Such communications will always include a link to opt-out, or you may contact us to revoke your consent.
Most personal information we collect and use is required to provide our products. Therefore, while you may revoke your consent to such use and collection, subject to legal or contractual restrictions and reasonable notice, we will be unable to continue providing such products to you or the associated client.
Accessing and Updating Your Information
If you wish to access your personal information or correct inaccurate or incomplete personal information, please first contact your account administrator. In most cases, your account administrator will be able to provide or correct such information. If the account administrator is unable to do so, please contact us. We will address your request, subject to any limitations or restrictions on us, such as privilege, obligations of confidentiality, or those imposed by law or regulation. In some situations a fee may apply. We will advise you of such fee in advance.
If you wish to contact us regarding this Code or your personal information, please contact us through our website or mobile application, or by phone at 844-412-2279. If our support team is unable to resolve the matter, you may write to us at:
Caary Capital Ltd.
186 Bartley Drive
Attention: Chief Privacy Officer
Last Updated: 2022-02-23