Wipstream - Privacy Policy

WIPSTREAM is provided to you by NeedExtraData Systems Ltd.

During your relationship with NeedExtraData Systems Ltd., including use of our WIPSTREAM website and other WIPSTREAM products and services, protecting the privacy and confidentiality of your Personal Information (as defined below) is important to us.

This Privacy Policy tells you how NeedExtraData collects, uses, discloses and retains personal information, including information collected by us through our website, telephone calls, emails, and when providing you our WIPSTREAM products and services.

This Privacy Policy applies to users of the WIPSTREAM website in addition to the WIPSTREAM Website Terms and Conditions, and to WIPSTREAM subscribers in addition to your subscription order and the Subscription Terms and Conditions.

For the purpose of this Policy:

“NeedExtraData” means NeedExtraData System Ltd.

“us”, “we”, and “our” means NeedExtraData and its directors, officers, principals, agents, employees, and affiliates.

“NED Parties” means NeedExtraData’s partner businesses and partner service providers,

“NED Products” means the website, WIPSTREAM, and any other product or service provided by NeedExtraData.

“website” means the WIPSTREAM website.

“WIPSTREAM” means our WIPSTREAM-branded products and services.

“Personal Information” is defined in Section 3 of this Privacy Policy, below.

“Related Transaction” is defined in Section 4(c) of this Privacy Policy, below.

Our Privacy Policy may be updated from time to time. The effective date of this policy is listed above, so please review our published policy and its effective date periodically.

1. Providing Your Consent

By using our NED Products, and providing us with your Personal Information, you consent to the collection, use, disclosure and retention of your disclosed Personal Information by us in accordance with this Privacy Policy and as otherwise permitted by applicable law.

2. Withdrawing Your Consent

You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to us. However, some Personal Information is essential and necessary in order for us to provide NED Products to you, so we may not be able to proceed or continue with providing NED

Products to you, or offering further products and services to you, and you would not receive the full benefit of NED Products.

3. Definition of Personal Information

“Personal Information” is defined as information about you that is not publicly available information, such as date of birth, social insurance number, other government-issued identification, as well as financial information, bank and credit card information, device information, IP address, user ID and password information, location information, and information on your product and service subscriptions and usage.

Personal Information does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables you to be contacted at your place of business, such as name, address, telephone number.

We collect and use such other information that is also publicly available, but it is not considered “Personal Information”.

4. Information That We Collect

(a) Information that You Provide

You will be asked to voluntarily give us information, including Personal Information, when you interact with us orally, in writing, or by electronic transmission.

In those circumstances, you can choose not to provide certain requested Personal Information, but as mentioned above, then we may not be able to proceed or continue with providing NED Products to you.

(b) Electronic Collection (Automated)

We may automatically collect certain information regarding your use of NED Products such as the dates and times that you access NED Products, your location, the browsers, operating systems, software and devices that you use to access the website or online service and details of your use of the website or online service.

NeedExtraData may use

(i) Technologies (e.g. cookies, web beacons, tokens, pixels or tags) to collect information that assists us to improve our products, services, customer communications and advertising and to prevent fraud; and

(ii) Information that we collect through technological means to recognize you as a user of NED Products, to facilitate and improve your use of NED Products, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements.

You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of NED Products.

Much of the information that is automatically collected by technological means is non-personal information and does not personally identify you, and such information is used as further explained in this Privacy Policy unless applicable law requires otherwise.

A “Related Transaction” means a transaction that is related to your use of the NED Products, but which includes other Ned Parties or independent businesses in addition to NeedExtraData.

For example, a Related Transaction could include obtaining financing for NED Products through an independent financing business.

If you complete an application to finance any of the NED Products, we may obtain your credit score and related information from a credit reporting agency. This may assist us to process or fulfill a Related Transaction to your use of NED Products.

Upon your request we will inform you if we have ordered such a report, and will give you the name and address of the credit reporting agency that furnished the report.

You acknowledge and agree that any of the NED Parties, or independent businesses, to which we have disclosed your Personal Information may request a credit report for any legitimate purpose associated with your application, for example, for credit, extending credit, modifying the terms of your credit agreement, or collection on your account.

(d) Personal Information When Referred for a Related Transaction

For some products and services, we may refer you to an independent business for a Related Transaction. For example, in the event that you apply for financing, we may refer to an independent financer.

When we refer you to an independent business, we may also collect information from that independent business regarding the Related Transaction to update your NeedExtraData user profile.

(e) Disclosure From Third Parties

We may also collect information about you from third parties where such third parties have the right to disclose such information.

Prior to collecting this information, we would first get your consent excepting only where it is impractical or inappropriate to do so.

5. Personal Information That We Use

(a) General

We use your Personal Information collected primarily for providing NED Products and completing the Related Transactions.

We also use your Personal Information as otherwise set out in this Privacy Policy or permitted by applicable law.

Use of Personal Information includes:

(i) to provide, complete, and administer NED Products and the Related Transactions;

(ii) to manage your participation in NED Products and the Related Transactions;

(iii) to market, manage, and process NED Products and the Related Transactions;

(iv) to facilitate your interactions and transactions with us, including to process your finance applications and Related Transactions, and to process and respond to your inquiries, requests and other communications;

(v) to provide you with information (including by email and other electronic messages) regarding NeedExtraData and NED Products;

(vi) to provide you with information (including by email and other electronic messages) related products and services offered by other NED Parties or independent businesses, to the extent mentioned in this Privacy Policy or as otherwise permitted by applicable law;

(vii) to communicate information and offers to the NED Parties;

(viii) to understand and analyze our user’s responses, needs and preferences, and to develop new products and services to meet those needs and preferences;

(ix) to maintain, protect and improve NED Products and Related Transactions;

(x) to protect and enforce our legal rights, interests and remedies and to protect the business, operations and customers of NeedExtraData and other persons;

(xi) to assist the NED Parties to collect, use, disclose and retain your Personal Information in accordance with this Privacy Policy; and

(xii) to comply with all legal and regulatory requirements.

(b) Sharing Information

NeedExtraData may share your Personal Information with our NED Parties and with independent businesses

(i) who assist to administer and deliver NED Products and the Related Transactions;

(ii) who assist to provide related information, products, and services to you;

(iii) who assist to facilitate your dealings with NeedExtraData; and

(iv) as otherwise set out in this Privacy Policy or permitted by law.

NeedExtraData may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by independent vendors (such as Google, Facebook, Instagram) to display advertisements on independent websites and social media sites visited by users of NED Products.

Advertising vendors use cookies, pixels or tokens, which are unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses NeedExtraData’s website, to display ads based on the computer’s past access to NeedExtraData’s website.

You can configurate your web browser to vary or opt-out of the use of cookies, however, the functionality of our website and other websites may be reduced and some features may not work properly.

6. Personal Information that We Disclose

(a) General

We disclose your personal information for purposes relating to or arising from the provision of NED Products and completion of the Related Transactions, and as otherwise set out in this Privacy Policy or permitted by applicable law.

(b) Specific Consents

We may disclose your Personal Information in accordance with express or implied consents that you give during your interactions and transactions with us, including Related Transactions.

If we refer you to an independent business for a Related Transaction, then we may disclose your Personal Information (including your credit score and related financial information) to the independent business to facilitate the Related Transaction.

NeedExtraData has no control over, or responsibility or liability for, the use, disclosure or retention of your Personal Information by an independent business, and the use, disclosure and retention of the disclosed Personal Information by an independent business is not subject to this Privacy Policy.

However, when possible, we may require such independent businesses to oblige by our Privacy Policy terms in dealing with any Personal Information that they may obtain from us.

(d) NED Parties

We may disclose your Personal Information to our NED Parties (including fraud prevention services and payment processors) to assist us in the provision of products and services to you, to obtain services that are necessary or advantageous to us in providing NED Products, to use your Personal Information as set out in this Privacy Policy, and as otherwise permitted by applicable law.

(e) Disclosure Required by Law

We may disclose your Personal Information as required or authorized by law, including to law enforcement agencies, other independent organizations, and to third parties

(i) to comply with a disclosure obligation pursuant to a legal process;

(ii) where NeeedExtraData reasonably believes the disclosure is necessary or appropriate in connection with security, law enforcement or other issues of public importance; and

(iii) where NeedExtraData reasonably believes the disclosure is necessary or appropriate to protect and enforce NeedExtraData’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of NeedExtraData or other persons (including to detect and prevent fraud and other illegal activities, enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of the NeedExtraData’s products or services).

NeedExtraData has no control over, or responsibility or liability for, the use, disclosure or retention of your Personal Information by the agencies, independent organizations or other persons to whom NeedExtraData discloses the Personal Information in the foregoing circumstances. The use, disclosure and retention of the disclosed Personal Information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.

(f) Business Transactions

We may disclose your Personal Information in connection with a proposed or actual business transaction in which NeedExtraData is involved (such as a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of NeedExtraData’s business or assets), but NeedExtraData will require the information recipient to agree to protect the privacy of your Personal Information in a manner that is consistent with this Privacy Policy and applicable law.

7. Location of Your Personal Information

NeedExtraData, the Ned Parties, and any applicable independent businesses may process, store and use your Personal Information at facilities in Canada and/or in other countries such as the United States of America.

The personal information protection laws of any other countries might be different from the laws of and within Canada, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your Personal Information without notice.

By providing your Personal Information to us, you consent to the transfer of the Personal Information to facilities located in other countries for the processing and storage of the Personal Information at those facilities.

8. How We Retain Your Personal Information

We retain your Personal Information for a period of time reasonably necessary or a longer period required or permitted by applicable law

(i) for the purposes set out or referenced in this Privacy Policy;

(ii) to comply with NeedExtraData’s legal reporting obligations; and

(iii) to enforce or protect NeedExtraData’s legal rights.

We will delete or dispose of your Personal Information when NeedExtraData is no longer reasonably required to retain your Personal Information for the purposes set out or referenced in this Privacy Policy.

9. How We Protect Your Personal Information

We use reasonable safeguards, including administrative, physical and technical security and safeguarding measures, appropriate to the sensitivity of the Personal Information in our possession or under our control to help protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks.

Nevertheless, security risks cannot be eliminated and we cannot guarantee that your Personal Information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy.

10. Accuracy of Your Personal Information

We will rely on you to ensure that your Personal Information provided is as accurate, complete and up to date as necessary for the purposes for which NeedExtraData uses the Personal Information as described in this Privacy Policy.

11. Access to Your Personal Information

You may reasonably request access to your Personal Information collected and retained by NeedExtraData and information about NeedExtraData’s use, disclosure and retention of your Personal Information by submitting a written request to NeedExtraData’s Chief Privacy Officer using the contact information listed on our website and/or listed below in this Privacy Policy.

Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your Personal Information and you will be entitled to verify the accuracy and

completeness of your Personal Information and to have your Personal Information revised as appropriate.

You may be required to pay a reasonable fee for access to your Personal Information. NeedExtraData may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.

12. Collection, Retention and Use of Non-Personal Information

We collect non-Personal Information, including additional information that is not about an identifiable individual, for example, Personal Information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual.

We may use, disclose, transfer and retain non-Personal Information for any purpose and in any manner, including where not set forth in this Privacy Policy.

If non-Personal Information is combined with your Personal Information, then we will treat the combined non-Personal Information as Personal Information for the purposes of this Privacy Policy for as long as the non-Personal Information is combined.

13. Other Websites and Businesses

Our website and correspondence (including emails and messages) may include advertisements for products and services offered by independent businesses (that may have a financial relationship with NeedExtraData) or links to websites operated by independent businesses (for example, related product or service providers, lenders and credit providers).

Please be aware that NeedExtraData has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your Personal Information.

This Privacy Policy does not apply to the collection, use, disclosure and retention of your Personal Information by those websites, online services and independent businesses.

If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service or business.

14. Other Matters

(a) Disclaimers, Liability Exclusions/Limitations and Disputes:

The agreements that you accept when you apply for or use NED Products or Related Transactions, for example, the WIPSTREAM Website Terms and Conditions, Subscription Terms and Conditions, and this Privacy Policy, contain important provisions, including provisions disclaiming, limiting or excluding the liability of NeedExtraData and other persons (including principals, affiliates, partner businesses and providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes.

To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or our collection, use, disclosure and retention of your Personal Information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

(b) Changes to this Policy:

As mentioned above, we may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on website.

Our collection, use, disclosure and retention of your Personal Information will be governed by the version of this Privacy Policy in effect at that time.

Your continued dealings with us and/or use of NED Products after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your Personal Information as set out in the changed Privacy Policy.

Accordingly, you should check the “updated as of” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.

If you have any comments or questions about this Privacy Policy or how NeedExtraData deals with your personal information, please contact:

NeedExtraData’s Privacy Officer

by email at:

privacy@wipstream.io.

by mail at:

3315 Wells Ave

Saskatoon, SK

S7K 8B7

If this doesn't resolve your concern to your satisfaction, you may contact the Saskatchewan Information and Privacy Commissioner by writing to:

Saskatchewan Information and Privacy Commissioner

503 – 1801 Hamilton Street

Regina SK S4P 4B4

Telephone: 306-787-8350

Toll Free Telephone (within Saskatchewan): 1-877-748-2298

Fax: 306-798-1603

Email: webmaster@oipc.sk.ca

Twitter: @SaskIPC

Last Modified: July 1, 2021

WIPSTREAM - Privacy Policy – Updated as of July 1, 2021.

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