NORTHONE, INC. PRIVACY AND COOKIE POLICY

LAST UPDATED: JANUARY 2021

Introduction

This privacy and cookie policy (“Policy”) describes how NorthOne, Inc. (“NorthOne,” “we,” and “our”) collects, uses and shares your personal data when you use NorthOne’s applications, including our application known as “NorthOne” (each, a “App” and collectively, the “Apps”) and the services provided in connection therewith (the “Services”). Our Services act as a portal or interface that enables users to access certain financial products and banking services made available by NorthOne’s partnering financial institution (the “Bank”). Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.

Particularly Important Information

Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is NorthOne, Inc. of 18 W 18th St, New York, NY 10011.

BANK INFORMATION: You may contact NorthOne at any time to request information about the Bank by emailing us at support@northone.com.

Must Read Sections: We draw your attention in particular to the sections entitled “International Data Transfer” and “Your Rights.”

Changes to this Policy: We will post any modifications or changes to the Policy on our Apps/Services. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email and/or post a notice on our Apps/Services prior to such changes(s) taking effect.

1.      PURPOSES OF PROCESSING

What is personal data?

We collect information about you in a range of forms, which could include any information which, either alone or in combination with other information we hold about you, identifies you as an individual, for example, your name, date of birth, social security number, postal address, email address and telephone number.

Why do we need your personal data?

We need certain personal data in order to provide you with access to the Apps/Services. We will only process your personal data in accordance with applicable data protection and privacy laws.

2.     COLLECTING YOUR PERSONAL DATA

We collect information about you in the following ways:

Information You Give Us. This includes:

• the personal data you provide when you sign-up for, and/or login to, your account, such biometric data used for facial and/or touch/fingerprint ID recognition purposes, as well as any other information you submit during the registration process, including name, email, and company name;
• the personal data you provide when you access and use the financial and banking products and services made available by the Bank via our Apps/Services;
• the personal data you provide when you report a problem with our Apps/Services or when we provide you with customer support; and
• the personal data you provide when you correspond with us by email or otherwise.

Information We Get from the Bank. We may also get information about you from the Bank, for example, your financial accountant information and transaction history, in order to provide you the Services and information you request from the Bank.

Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Apps/Services. For example, when visiting our Apps/Services, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Apps/Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Apps/Services. We collect this information about you using cookies. Please refer to the sections on cookies.

Automated Decision Making and Profiling.

We may use automated decision making and/or profiling in regard to your personal data for some services and products, for example if you opt-in to see if you pre-qualify for certain financial products of the Bank, we may use the information you provide to automatically determine whether you pre-qualify for such products. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision making and/or profiling by contacting us at: support@northone.com.

3.      COOKIES

What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to help analyze how you use our Apps/Services to improve their design, efficiency and use.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Apps/Services; and (2) third party cookies, which are served by service providers on our Apps/Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies we use

Our Apps/Services use the following types of cookies for the purposes set out below:

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit  www.allaboutcookies.org and  www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our Apps/Services. For example, we may not be able to recognize your device and you may need to answer challenge questions or provide additional information each time you log on.

4.      DO NOT TRACK SIGNALS

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

5.      USING YOUR PERSONAL DATA

We may use your personal data as follows:

• to operate, maintain, and improve our Apps/Services, products, and services;
• to respond to your comments and questions and to provide customer service;
• to recommend, and/or prequalify you for, certain financial and banking products and services to you;
• to send information including technical notices, updates, security alerts, and support and administrative messages;
• with your consent, to send you marketing e-mails and/or text messages about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails and text messages tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
• as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
• as described in the “Sharing of your Personal Data” section below.

6.      SHARING YOUR PERSONAL DATA

We may share your personal data as follows:

• With the Bank. Our Service acts as a portal/interface between you and the Bank. As such, we will share the personal data you provide via the Apps/Services with the Bank so that the Bank may provide you with the products and services you request, and to comply with any audit requests of the Bank. By using our Services, you acknowledge and agree that the Bank’s use of your personal data will be subject to its Privacy Policy. We encourage you to read the Bank’s Privacy Policy in its entirety. Please contact us at  support@northone.com if you need assistance accessing the Bank’s Privacy Policy or other information about the Bank.Permission Based Sharing. We may share read-only (i.e. only permitted to view and not make any changes) access to your personal data with those persons you designate. For example, if you instruct us to provide your accountant with read-only access to your account, we will provide your accountant with such access for the time period(s) you designate. You may revoke any permissions you’ve granted at any time.
• Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
• Third Party Advertisers. We may share personal data with advertisers that require the data to identify new target audiences for our Apps/Services.
• Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
• Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

7.      ANONYMOUS DATA

When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.

We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies.We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyses usage patterns in order to make improvements to our Apps/Services.

8.      USER GENERATED CONTENT

If you provide feedback to us, we may use and disclose such feedback on our Apps/Services, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first name and last initial along with your feedback on our Apps/Services. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.

9.      INTERNATIONAL DATA TRANSFER

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and the Bank outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our App(s)/ Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

10.      SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 15 below.

11.      RETENTION

We will retain your personal data (i) as long as reasonably required for you to use the Apps and/or to provide you with the Services; (ii) in order to improve our services; and/or (iii) as required by applicable law or for regulatory purposes.

12.      SENSITIVE PERSONAL DATA

If you send or disclose any sensitive personal data to us when you log-in to your account, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you will not be able to create or log-in to an account.

13.      YOUR RIGHTS

• Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling (except in the case of automated decision-making for fraud prevention purposes); or (iii) any new processing of your personal data that we may carry out beyond the original purpose. Please note that your use of some of the Apps/Services may be ineffective upon opt-out.
• Amend. You can also contact us to update or correct any inaccuracies in your personal data.
• Move. Your banking transaction data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
• Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us using the details in Section 15 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for regulatory or recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

14.      COMPLAINTS

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at:  support@northone.com. We will reply to your complaint as soon as we can and in any event, within forty-five (45) days.

15.      CONTACT INFORMATION

We welcome your comments or questions about this Policy. You may contact us in writing at  support@northone.com or 559 College Street, Toronto, ON M6G 1A9, Canada.