Privacy Policy

Revised March 23, 2023‍‍

Introduction

Keep Technologies Corp. ("Keep" or "We") respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

How we collect, use, disclose, and protect the personal information of our customers and website users ("you").
Describes the types of information we may collect from you or that you may provide when you visit the website trykeep.com (our "Website").
Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:

On this Website.
In email, text, and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
When your business applies for or uses our products or services.
When you sign up as an Authorized User under an existing Keep Account.
When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

The Website may include links to third-party websites, plug-ins, services, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

Information we collect about you

We collect and use several types of information from and about you, including:

Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, date of birth, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, income, occupation, credit limits and credit scores, social insurance number, transaction information from your bank account (i.e. transaction amount, merchant, location, and category), your historical and current bank account balance, and your bank account number, institution number, and branch number, and any other identifier we may use to contact you ("personal information").
Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

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How we collect information about you

We use different methods to collect your information, including through:

Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
Third parties, for example credit reporting agencies and credit bureaus. We may also collect cardholder personal information from third party service providers who process cardholder transactions when a Keep payment product is used in store or online. We also use Plaid Inc. (Plaid) and Flinks Technology Inc (Flinks) to collect your personal information from the financial institutions that you use. When you connect Keep to your account with a financial institution using Plaid or Flinks by entering your account credentials, you (a) acknowledge and agree that Plaid’s or Flink’s collection, use, and disclosure of your personal information is subject to Plaid or Flinks’ privacy policy, as applicable; and (b) grant Keep and Plaid or Flinks, as applicable, the right, power, and authority to use your account credentials to continuously access your account and to transmit to one another the personal information accessed from your account as is reasonably required until you close your Keep account. Keep does not control how Plaid or Flinks use your personal information, and if you do not agree to the collection, use, or disclosure of your personal information described in Plaid’s End User Privacy Policy or Flinks’ Privacy Statement, as applicable, you may not open a Keep account.

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Information you provide to us

The information we collect directly from you (or your business) on or through our Website, may include:

Information that you provide by filling in forms or applying for a product on our Website. This includes when your business applies for a Keep product, such as a credit card, or wants to add you as a cardholder on its account. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions carried out by cardholders when using our payment products in store and online.

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Information we collect through cookies and other automatic data collection technologies

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Keep, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third party use of cookies and other tracking technologies

Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How we use your information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
To process cardholder purchases, refunds and other transactions using your Keep payment products.
To create, administer, and maintain accounts which may include processing your business’ application for a payment product and other products and services that we offer our customers.
To verify your identity to determine your business’ eligibility for a payment product, service, or program, or your eligibility to be a cardholder.
To manage, detect, prevent fraud.
To manage credit risk in evaluating your business’ credit application, and assessing and updating creditworthiness on an ongoing basis (for example, to adjust credit limits).
To carry out our obligations and enforce our rights arising from any contracts with you, including for collections or to comply with legal requirements.
To underwrite the spend limit on your Keep account and adjust the spend limit over time.
To authenticate a financial services account for EFT payment
To notify you about changes to our Website or any products or services we offer or provide through it.
To improve our Website, products or services, marketing, or customer relationships and experiences.
To meet regulatory obligations, such as “know your client” and anti-money laundering requirements (which require that we collect certain information about individuals associated with business accounts).
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Subject to obtaining your consent, we may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you, as permitted by law. If you no longer want us to use your information in this way, please use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at privacy@trykeep.com.

Disclosure of your information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Keep 's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Keep about our customers and users is among the assets transferred.
To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
To contractors, service providers, and other third parties, including other financial institutions, we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
To third party organizations in order to confirm eligibility for a payment product or to process a transaction. For example, when your business applies for a payment product, Keep shares your personal information with credit bureau agencies in order to allow us to evaluate the application. We may also share your personal information on an ongoing basis to evaluate your business’ ability to continue with a specific product or feature associated with one of your products and to maintain the integrity of the credit reporting system.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
To enforce or apply our terms of use https://trykeep.com/terms-of-service and other agreements, including for collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Keep, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Transferring your personal information

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to the following foreign countries: United States, which have 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 those countries may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

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Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.
Promotional Offers from Keep. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by Keep to promote our own or third parties' products or services, you can opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to support@trykeep.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by sending us an email stating your request to privacy@trykeep.com.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Data security

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Children under the age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information about yourself to us. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact our Privacy Officer using the contact information provided below.

Accessing and correcting your personal information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Website and visiting your business’ account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may contact our Privacy Officer using the contact information provided below to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Withdrawing your consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact our Privacy Officer using the contact information provided below. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

Changes to our privacy policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your business’ account or through a notice on the Website home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact information and challenging compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Privacy Officer

privacy@trykeep.com

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We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

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