Now Prepay is committed to keeping customers’ personal information accurate, confidential, secure and private. The Now Prepay Group Privacy Code builds on this commitment.
This Code is based on the Federal Personal Information Protection and Electronic Documents Act (‘PIPEDA’). It describes how Now Prepay subscribes to the principles of PIPEDA Privacy Principles throughout the company.
Now Prepay encompasses all products, services, partners engaged in the following services to the public: purchase of prepaid products or services.
This Code describes the principles Now Prepay will use to protect the privacy of individual customers’ personal information in the carrying out commercial activities throughout the company, no matter how the information is collected, used or disclosed.
This Code applies to Now Prepay as defined within this Code with respect to our operations company wide. Where Now Prepay is subject to laws or industry regulation or self-regulatory requirements which impose greater or additional obligations with respect to the protection of personal information, Now Prepay also complies with those additional obligations.
The Merchant hereby authorizes The Company or its authorized third party to originate a Pre Authorized Debit (“PAD”) to the Merchant’s account, as provided by the Merchant for all obligations of the Merchant under this Agreement. In the event that The Company incurs any charges due to the failure of a PAD debit to properly process or in the event that the Merchant does not have sufficient funds in its account to permit the PAD debit to go through, the Merchant shall immediately, upon demand, reimburse The Company for all such charges and expenses incurred together with a $35.00 administrative fee. Notwithstanding the foregoing, the failure of a PAD debit to properly post to the Merchant’s account shall entitle The Company to immediately suspend service or terminate this Agreement. If there is any discrepancy between the POS terminal transaction reports and the transaction reports generated by the Server, the Server reports shall be considered correct and accurate.
Now Prepay is accountable for all personal information in its possession or custody, including any personal information disclosed to third parties for processing or other administrative functions. Now Prepay has established policies and procedures to comply with this Code, and has designated one or more persons to be accountable for compliance.
Now Prepay also oversees compliance with these policies and procedures through normal risk-based review, and through ongoing compliance policies and procedures reviews.
Now Prepay will identify the purposes for which it collects the personal information, before or when the information is collected.
When a customer applies for a product or service provided by or through Now Prepay, Now Prepay will make sure the customer is made aware of:
In some cases Now Prepay may not explain or obtain customer consent for the other
purposes for which the information has been collected.
Now Prepay will collect and use personal information for the following purposes:
Now Prepay will identify the purposes for which it intends to use the personal information, in writing, orally in person or over the telephone, electronically or by any other alternative format or means it uses to communicate with its customers. Now Prepay will use words that customers can easily understand when identifying these purposes.
Now Prepay will distinguish the purposes from other information so that customers will be
made aware of them. For instance, on an online application form, Now Prepay may identify the purposes using bolder type or a box, or a confirmation box. Over the telephone,
Now Prepay will identify the purposes as a distinct part of the conversation with respect to the personal information that is required as well as the purpose for gathering the information.
Now Prepay staff, its affiliates, partners and other related parties who collect personal information will be able to explain the purposes to customers. Customers will also be able to ask for information about the purposes when they email, phone or write to Now Prepay with respect to the use and collection of their personal information.
Now Prepay will explain all the purposes for which personal information is collected including any purposes which may not appear to be as obvious as others. The purposes for collecting a name or address are obvious and do not need to be explained. For the purposes of collecting other information that may not be obvious Now Prepay will inform the customers that:
Now Prepay will make all reasonable effort to make sure customers understand how their personal information will be used by Now Prepay. Now Prepay will obtain consent from its customers before, when it collects, or uses the personal information. Now Prepay will not attempt to deceive a customer into giving consent.
A customer’s consent can be express, implied, or given through an authorized representative at Now Prepay, its affiliates, or partners.
A customer can withdraw consent at any time, with certain exceptions.
Now Prepay, however, may collect, use or disclose personal information without the customer’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.
Generally, Now Prepay will seek consent to use and disclose personal information at the same time it is collected. Sometimes, however, Now Prepay may identify a new purpose and it will seek consent to use and disclose personal information for that purpose after the information has been collected.
Now Prepay will not obtain consent through deceptive practices. It will explain to customers how personal information will be used before they give their consent, except where applicable laws do not require consent.
Customers can give consent orally, in writing or electronically. They can imply consent through action or inaction. They can also give consent through an authorized representative. Express consent is the preferred form at Now Prepay.
Customers can grant consent:
Customers can grant implied consent by:
Customers can also give consent through an authorized representative, such as a legal guardian or a person with a power of attorney. This is necessary, for example, if Now Prepay cannot obtain express consent from a customer who is a minor, seriously ill, or mentally incapacitated.
Before deciding what form of consent is appropriate, Now Prepay will consider the type of personal information it needs, the reason for its use, and the type of customer contact that is involved.
Customers always have the option to withdraw consent to the use of personal information for marketing purposes.
Now Prepay can collect or use personal information without the knowledge and consent of the customer in exceptional circumstances where such collection or use is permitted or as required by law.
For example, Now Prepay will not ask for consent when personal information is collected used, or disclosed:
Now Prepay can disclose personal information without the knowledge and consent of the customer in exceptional circumstances where such disclosure is permitted or required by law. For example Now Prepay will not ask for consent when personal information is:
Subject to legal and contractual restrictions, customers can refuse or withdraw consent at any time as long as:
Now Prepay limits the amount and type of personal information it collects. Now Prepay will collect personal information for the purposes it identifies to the customer at time of collection. Now Prepay will inform the customer if the information collected will be used for new purposes.
Now Prepay collects personal information using policies and procedures which are fair and lawful.
Although Now Prepay will collect personal information primarily from customers, it may
also collect personal information from external sources such as third party service providers, credit bureaus, government records, and partners as required by law or confirmation that the personal information collected is correct.
Now Prepay will use or disclose personal information only for the reasons it was collected, unless consent is obtained from the customer to use or disclose the personal information for another reason, or is permitted/required by law.
Under certain exceptional circumstances, Now Prepay has a legal duty or right to disclose personal information without customer knowledge or consent, including to protect Now Prepay’s or the public interest.
Now Prepay will keep personal information only as long as necessary for the identified purposes for which it was collected.
Now Prepay may disclose personal information without consent where permitted/required by law. For example:
In these circumstances, Now Prepay will protect the interests of its customers by making reasonable efforts to ensure that:
Now Prepay may notify customers that an order has been received, if permitted by law.
Now Prepay may notify customers of such orders to the last know telephone, electronic mail, or letter.
Now Prepay may want to use personal information to market products and services to its customers, either directly or through Now Prepay or its affiliates. Now Prepay will obtain the consent of the customer before using personal information for such purposes.
When a customer uses a Now Prepay product or service and provides personal information, Now Prepay will:
The first time a new type of Now Prepay affiliate provides promotional information about its product or service, the Now Prepay affiliate will:
Now Prepay specifies in its policies and procedures the periods of time it will keep personal information. Some of these time periods are determined by legislation. If personal information has been used to make a decision about a customer, Now Prepay will keep the personal information long enough for the customer to have access to it after the decision has been made, subject to any regulated record retention period.
Now Prepay will destroy or erase any personal information no longer needed for its identified purposes or for legal requirements.
Now Prepay’s policies and procedures explain how Now Prepay will destroy personal information so that unauthorized persons or organizations do not gain access to it.
Now Prepay will keep personal information as accurate, complete and current as necessary for the identified purposes for which it was collected.
Customers may, in writing, challenge the accuracy and completeness of their personal information and request that it be amended as appropriate.
Now Prepay will make reasonable efforts to minimize the possibility of using inaccurate, incomplete, or outdated personal information to make a decision about the customer.
Now Prepay will update personal information only if it is necessary for the purposes for which it was collected.
Now Prepay will make reasonable efforts to keep customers’ personal information accurate and current if the information is used on an ongoing basis. This includes personal information disclosed to third parties for processing.
Now Prepay will also rely on customers to keep certain personal information (such as customer addresses) accurate, complete, and current. If a customer shows that personal information is inaccurate, incomplete, out of date, or irrelevant, Now Prepay will revise its records. If necessary, Now Prepay will disclose the revised personal information to third parties which were provided with the information to revise their records as well.
If Now Prepay does not agree to revise personal information as requested by the customer, the customer may challenge Now Prepay’s decision. Now Prepay will make a record of this challenge, and if necessary, disclose the challenge to the third parties who also possess the personal information, and advise the customer of the relevant complaint procedures.
Now Prepay protects personal information with safeguards appropriate to the sensitivity of the information. These safeguards include protecting personal information from loss or theft, from unauthorized access, disclosure, duplication, use, or modification.
Now Prepay’s safeguards vary depending on the sensitivity, amount, distribution, format, and storage of the personal information. Now Prepay gives the highest level of protection to the most sensitive personal information.
Now Prepay safeguards personal information through security measures. For example:
Now Prepay informs its staff regularly about Now Prepay’s policies and procedures for
protecting customers’ personal information, and emphasizes the importance of complying with them. As a condition of employment, employees are required to conform to Now Prepay’s policies and procedures.
Now Prepay may disclose personal information to third parties for fraud screening, credit worthiness, data processing services or administrative services, collection of debts, or for other goods and services. Now Prepay requires these third parties to safeguard all personal information in a way that is consistent with Now Prepay’s measures, or as regulated by law.
Now Prepay may, with the customer’s consent, disclose personal information to businesses such as, credit bureaus, and third party payment providers, its partners and issuers of prepaid products or accounts, advisory organizations, and regulatory organizations. Now Prepay uses procedures and/or contracts to protect the privacy of that personal information.
As referred to in Principle 5, Now Prepay uses care when disposing of or destroying personal information, to prevent unauthorized access to the information.
Now Prepay is open about the policies and procedures it uses to manage personal information. Customers have access to information about these policies and procedures. The information will be made available in a manner that is generally easy to understand.
Now Prepay makes available to customers information about the policies and procedures it uses to manage personal information. Copies of this Code are available in printed format upon request.
Information about Now Prepay’s policies and procedures has been written so that it is generally easy to understand and it is readily available to customers. Through printed format or other related documents, customers will be able to find out:
Now Prepay makes information about its policies and procedures available in a variety of ways, depending on the nature of the service customers are using and the sensitivity of the personal information. For example, Now Prepay may make printed format or other information available upon request, mail information to its customers, establish a toll-free telephone service, use electronic mail, or provide online access.
If you have a question about Now Prepay’s privacy policies, please contact us toll free at 1-844-241-2991.
Alternatively, you may write to us at:
Now Prepay Inc.
c/o Chief Privacy Officer
365 Evans Avenue
Suite 301 Toronto
ON M8Z 1K2
When customers make a request in writing, Now Prepay will, within a reasonable time, inform them of what personal information Now Prepay has, what it is being used for, and/or to whom it has been disclosed, depending on what details the customers have requested and that is not restricted by law, and/or from a contractual perspective.
When customers request it in writing, Now Prepay will give them access to their personal information. Now Prepay will respond to the written customer request within 30 days. In certain situations, however, Now Prepay may not be able to give customers access to all their personal information. Now Prepay will explain the reasons for this limitation on access and any recourse the customer may have, except where prohibited by law, and/or from a contractual perspective.
A customer has the right to know, by written request, what personal information is held by Now Prepay. Customers have a right, upon written request, to access personal information, and to know to which third parties the information has been disclosed, except where prohibited by law, and/or from a contractual perspective.
Now Prepay has policies and procedures for responding to customers’ requests for access to personal information. When customers ask, Now Prepay will make these policies and procedures known to the customers. To respond to a customer’s request certain information may be required, for example, customers have to be specific about the type of personal information that may be held by Now Prepay.
Now Prepay will attempt to be as specific as possible about the persons from whom it collected the personal information, to whom it has disclosed the personal information, and how and when the information was disclosed. Now Prepay will take this information from its records, and will provide it to the customer in a form that is generally easy to understand, providing explanations for abbreviations and codes. Now Prepay will provide the information to the customer within 30 days following a written request, and for a cost commensurate with the effort to retrieve the information, or at no cost.
Now Prepay will not charge the customer without first informing the customer of the cost of providing the requested information and giving the customer the option to withdraw the request.
Now Prepay will, on request, give a customer who has a sensory disability, access to personal information to which the customer is entitled, in an alternative format if a version of the information already exists in the alternative format, or if conversion into that format is reasonable and necessary in order for the customer to access the personal information.
Now Prepay will not provide the personal information that is in its control if:
Now Prepay will not record in customers’ individual files when personal information was disclosed to third parties for routine purposes. For example:
If Now Prepay denies the customer’s request for access to personal information, Now Prepay will explain the decision to the customer, except where prohibited by law. The customer may then challenge Now Prepay’s decision (See Principle 10).
A customer may challenge the reasonableness of the cost of providing personal information.
Customers may challenge Now Prepay’s compliance with this Privacy Policy. Now Prepay has policies and procedures to receive, investigate, and respond to customers’ complaints and questions.
Now Prepay will inform customers of these policies and procedures, which are generally easy to understand and use. The complaint resolution process and the appropriate contact person are part of these policies and procedures.
Now Prepay will investigate all complaints received in writing and if it finds a complaint justified, Now Prepay will try to resolve it. If necessary, Now Prepay will take appropriate measures, including changing its policies or procedures, to ensure that other customers will not experience the same problem.
If a customer is not satisfied that Now Prepay is operating in compliance with the requirements of this Privacy Policy, the customers may file a complaint with the privacy regulator or data protection agency of their respective jurisdiction within Canada. Various privacy regulators or data protection agencies have different methods for filing customer complaints. Customers may also file a written complaint to the Office of the Privacy Commissioner of Canada.
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
Fax: (819) 994-5424
Internet: www.priv.gc.ca
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