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Driven's Mobile App Privacy Policy

This Mobile App Privacy Policy applies to personal information that you provide through the mobile app (the “Mobile App”) of Driven Financial Technologies Corporation (“Driven”), and informs you how Driven treats the personal information obtained from you when you use the Mobile App. By submitting your personal information to Driven or our service providers and agents, you agree that Driven may collect, use and disclose such personal information in accordance with this Mobile App Privacy Policy.

INFORMATION WE COLLECT

The following information may be collected from you or your device as you use the mobile app: personal information you input into the app, financial information, transactional data, mobile phone number, mobile country code, contact list (if enabled on your device), IP address, photos and/or camera information, other device-related information such as the make and model of your device, its operating system, mobile device identification number (IMEI), MAC address, non-personal Device Identifier (AAID, IDFA), information about the screen size, and the date and time of your use and information about the features of our application(s) you accessed.

Personal Information” as used herein, means any factual or subjective information in recorded form, that identifies or could be used to identify an individual.

We may also collect data and Personal Information necessary to process your payment, such as your payment instrument number, and the security code associated with your payment instrument     . All payment data is stored by Plaid.com and Flinks.com. You may find their privacy notice link(s) here:

https://plaid.com/overview-privacy/

https://flinks.com/privacy-policy/ 

Please note the ability to collect certain Personal Information is controlled by your device. For example, your device may control the ability to disclose your device's geolocation or provide access to your contacts, photos, and/or camera. Please refer to the documentation for your device regarding how to allow or block the collection of location or certain Personal Information. If you choose not to provide certain Personal Information provided by your device, some services you request may not operate effectively.

A. HOW DRIVEN USES THIS INFORMATION

Driven may use the Personal Information to provide or enhance the app-specific products or services, to facilitate the operation of the app, communicate with you, to help us understand how you use our app, for our internal analytics and reporting, authentication, and security (including fraud prevention), reporting purposes and to improve the functionality of our app. We may also process your Personal Information for other purposes with your consent.

Following are the ways we process your Personal Information depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your Personal Information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate the delivery of services to the user. We may process your Personal Information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your Personal Information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your Personal Information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To request feedback. We may process your Personal Information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the Personal Information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time by contacting our Privacy Officer as per the information set out in Section G.
  • To protect our Services. We may process your Personal Information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To evaluate and improve our Services, products, marketing, and your experience. We may process your Personal Information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and evaluate and improve our Services, products, marketing, and your experience.
  • To identify usage trends. We may process Personal Information about how you use our Services to better understand how they are being used so we can improve them.
  • To comply with our legal obligations. We may process your Personal Information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

We may also use and disclose this Personal Information as described in Driven’s Privacy Policy located on https://www.driven.ca/policies/privacy 

B. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We may process your Personal Information if you have given us specific permission (i.e., express consent) to use your Personal Information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your Personal Information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
  • For investigations and fraud detection and prevention;
  • For business transactions provided certain conditions are met;
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
  • For identifying injured, ill, or deceased persons and communicating with next of kin;
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
  • If the collection is solely for journalistic, artistic, or literary purposes;
  • If the information is publicly available and is specified by the regulations.

We may share Personal Information in specific situations described in this section and/or with the following categories of third parties. 

C. VENDORS, CONSULTANTS, AND OTHER THIRD-PARTY SERVICE PROVIDERS

Driven may share your Personal Information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share Personal Information with include:

  • Data Analytics Services
  • Data Storage Service Providers
  • Finance & Accounting Tools
  • Government Entities
  • Payment Processors
  • Communication & Collaboration Tools
  • Sales & Marketing Tools
  • Testing Tools
  • User Account Registration & Authentication Services
  • Website Hosting Service Providers
  • Product Engineering & Design Tools
  • Performance Monitoring Tools
  • Retargeting Platforms

We may also share your Personal Information in the following situations:

  • Business Transfers. We may share or transfer your Personal Information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Driven & its Affiliates. Sharing your Personal Information among Driven and its affiliate companies allows us to help you achieve your financial goals. It's part of building and maintaining a positive advice-based relationship with you. We may share this Personal Information to better understand your financial needs and to provide products and services we believe may interest you.

We may share your Personal Information with our affiliate companies:

  • for the purpose of preventing or detecting fraud or suppressing financial abuse;
  • for managing risks and operations; or
  • to enable our affiliate companies to meet certain regulatory, legal, financial or other reporting obligations.

Please note the Personal Information that identifies you is only shared with your consent. If you would prefer that we not share your Personal Information with our affiliates or if you do not wish to receive special offers promoting products and services based on such information, kindly let us know by contacting our Privacy Officer as per the information set out in Section G.

If you choose not to consent to our sharing of your Personal Information, you will not be refused credit or other services based on your decision to withhold such consent. We will respect your choice and may advise our affiliates of your preference for the sole purpose of honoring your decision to withhold such consent.

D. HOW LONG DO WE KEEP YOUR INFORMATION?

Driven will retain your Personal Information for as long as needed to fulfill the purposes for which it was collected and used. In some cases, this may be as long as your account is active or as needed to provide you with services. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you have any questions about how long your Personal Information is retained, please contact us pursuant the contact information set out in Section G.

E. HOW DO WE KEEP INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be completely secure, and therefore we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and inappropriately collect, access, steal or modify your Personal Information. Although we make efforts to protect your Personal Information, the transmission of Personal Information to and from our Services is done at your own risk. You should only access the Services within a secure environment.

F. ACCOUNTABILITY AND PRIVACY BY DRIVEN

If you have questions regarding privacy, please contact us via one of the methods set out below.

  • For Access and Correction Requests

Upon request, Driven will provide you with information about whether we hold any of your Personal Information. To request access, update, and/or correction of your Personal Information in our possession, please write to us at privacy@driven.ca. We may need to confirm your identity before fulfilling your request, such as by requesting a copy of a valid driver’s license, birth certificate, or passport. If you are a customer, you can also access and update your Personal Information anytime by logging into your account. We will respond to your request within a reasonable timeframe.

  • For making a complaint/general feedback

If you have problems, or concerns or wish to provide us with your general feedback, you may contact our Privacy Officer:

Office of the Privacy Officer

Marlo Kravetsky

130 Adelaide Street West, Unit 3100
Toronto, ON 

OR at

privacyofficer@driven.ca

G. DO WE MAKE UPDATES TO THIS POLICY?

From time to time, Driven may update the Mobile App Privacy Policy at any time as technology and customers’ interests evolve, and as privacy or other applicable legislation is updated, and when such a change is made we will post a revised version on our website and/or the Mobile App. It is your responsibility to review this Mobile App Privacy Policy from time to time to be aware of any such changes.