People by Wagepoint Privacy Policy

TABLE OF CONTENTS

• Collection and Use of Personal Information
• Sharing of Personal Information
• Information about our Website
• Safeguards and Retention
• Your Choices
• Access to Information
• Updates to the Privacy Policy
• Contact Us
• European Data Subjects

COLLECTION AND USE OF PERSONAL INFORMATION

We provide workplace software to small businesses to enable them to onboard employees, monitor employee time off, manage employee development and performance reviews, organize employee data and store employee files. In the course of providing these services to our customers, we collect and use personal information of our customers’ employees and other representatives (“Customer Information”). In addition, we collect personal information on our own behalf in limited circumstances, such as in connection with visits to our Website, job applications, responding to customer enquiries, and to send marketing communications (“Other Information”).

Information we process on behalf of our customers:

People by Wagepoint Services: In the course of providing the People by Wagepoint services, we collect and use Customer Information which is comprised of personal information that our customers upload or otherwise provide to us through the Website. This information includes, but is not limited to, employee/representative contact information, employee employment information (such as SIN number, benefits information, salary information and emergency contact information), performance reviews, electronic signatures, time off requests and employee onboarding information. Customer Information will be used by us in accordance with a customer’s instructions, including to provide the services, any applicable terms in the Terms of Service and as required by applicable law.

We use Other Information to operate our services, Website and business. More specifically, we process Other Information for the purposes below. We must receive or collect some information to operate, provide, improve, understand, support, and market our services. For example, you must provide an email address to create an account to use our services.

Create an Account: When an employer signs up to use our services, we require certain information to create an account. The information we collect includes name, company email address, company address, company phone number, and billing and payment information. We use this information to create and administer the account.

Use of the Services: We may monitor use of the services by our customers or other authorized users to detect, investigate or prevent any actual or potential violation of our terms and conditions. We may also generate aggregated, non-identifiable data and use such information to monitor the performance, use and stability of the services and to improve the services.

Information we process, collect and use on our own behalf through our Website and other interactions:

We may collect personal information when you:

• Sign up to receive marketing communications
• Apply for a job
• Attend one of our events
• Respond to our surveys
• Enter a contest or participate in a promotion
• Interact with us through our social media channels
• Contact us with a question, comment, or complaint

Marketing Communications: If you sign up to receive email marketing communications, we will collect your email address to send you newsletters and other communications about our products and services. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us.

Careers: In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

Events: If you attend one of our events (or visit a booth at an event), we may collect business contact information such as your first and last name, company name, work email address and phone number. We collect this information so that we can communicate with you about the event and contact you about future events.

Surveys: From time to time, we may offer you the opportunity to participate in one of our surveys. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our users and to enhance our Website.

Social Media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on the Website and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.

Contact Us: When you contact us with a comment, question, or complaint, you may be asked for information that identifies you, such as your name, address, email address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and products. In addition, we may record calls to and from our contact center to ensure accuracy, security, for training purposes and to assist us in responding to your inquiry.

SHARING OF PERSONAL INFORMATION

We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.

Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website, processing payments, call recording, and providing advertising, analytics and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada, or other foreign jurisdictions.

Legal and Compliance: We and our Canadian, U.S. and other foreign service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property. Where a disclosure of our customers’ information is required by applicable law, we notify our customer prior to complying with such requirements (to the extent we are not prohibited from doing so) and co-operate with our customer’s instructions with respect to our response.

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition, or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of People by Wagepoint or as part of a corporate reorganization or other change in corporate control.

INFORMATION ABOUT OUR WEBSITE

Visiting our Website: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.

Cookies: Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features.

Analytics: We may use a third-party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

• https://policies.google.com/technologies/partner-sites
• https://support.google.com/analytics/topic/2919631

Third-Party Links: Our Website may contain links to other websites that People by Wagepoint does not own or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices, and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

INTEREST-BASED ADVERTISING

We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.

Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.

• Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will be less targeted to you and your interests.

  To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

We do not respond to browser-based Do Not Track signals or similar signals.

SAFEGUARDS AND RETENTION

We have implemented reasonable administrative, technical and physical measures in an effort to (i) safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure and (ii) restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes of providing services to our customers or, with respect to the Website or App, for the purposes set out in this privacy policy, or to otherwise meet legal requirements.

YOUR CHOICES

As indicated above, if you have signed-up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below.

ACCESS TO INFORMATION

If we receive a request from an individual to access or update personal information we maintain on behalf of a customer, we will direct that individual to the relevant customer. We will assist our customers wherever possible in responding to individual access requests.

Subject to limited exceptions under applicable law, if you live in Canada or certain other locations outside the United States, you have the right to access, update and correct inaccuracies in your personal information in our custody or control and to withdraw your consent to our collection of your personal information (subject to legal and contractual restrictions). You may request access, updating and corrections of inaccuracies in your personal information in our custody or control, or withdraw your consent, by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

UPDATES TO THE PRIVACY POLICY

We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated. We will notify you if we make material changes to the privacy policy.

EUROPEAN DATA SUBJECTS

This section applies if you reside in the European Economic Area (“EEA”). It contains important information we are required by the General Data Protection Regulation (“GDPR”) to disclose, including (i) the controller(s) of your personal information, (ii) legal bases, (iii) your legal rights, (iv) safeguards we rely on for transferring your personal information outside the EEA, and (v) the contact details of the controller and Privacy Officer.

The controller of your personal information is Wagepoint Holdings Inc.

Legal bases for processing your information

We rely on different legal bases to process your information for the purposes described in this Privacy Policy. We have set our legal bases for processing out in the table below:

Your Rights

You have the following data protection rights:

• a) Right to object (marketing) – You have the right to object to processing for direct marketing purposes at any time.

• b) Right to object (legitimate interest) – Where we process your information based on legitimate interests, you can object to this processing in certain circumstances. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.

• c) Right of access – You can also request a copy of the information we have about you and information explaining how the information is used

• d) Right of rectification – You have the right to request that we rectify inaccurate information about you.

• e) Right of erasure – You have the right, in certain cases, to request that we delete your information, provided there are valid grounds for doing so and subject to applicable law.

• f) Right to restrict processing – You have the right, in certain cases, to temporarily restrict the processing of your information by us, provided there are valid grounds for doing so.

• g) Right to data portability – You may have the right to receive certain of your information in a structured, commonly used and machine-readable format and to transmit such information to another controller.

• h) Right to withdraw consent – Where you have previously provided your consent, such as to send you direct marketing, you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal, we may continue to use your information as permitted or required by law.

These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data.

If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the relevant data protection authority in your jurisdiction.

International Data Transfers

We do not transfer data of data subjects in the European Union outside of the EEA.