Privacy

This OTT Pay Inc. (“OTT”) Privacy Policy is effective as of April 30, 2020. OTT is a corporation established in Canada and is currently offering its services in Canada.

Please read this Privacy Policy carefully before using our services to learn how OTT manages your personal information upon receipt of same from you. By accessing or using any of our services, you acknowledge your consent to the practices described in this Privacy Policy. If you do not agree to be bound by the terms of this Privacy Policy, exit this page and/or the application under consideration without registering for, accessing, or using any of OTT’s services. Your consent may be withdrawn at any time and we will no longer provide the services for which you have registered.

It is OTT’s policy to respect confidentiality and privacy of individuals who open an account or have a business relationship with OTT. Under the applicable law, OTT has an obligation to collect information from its clients and verify their identity to meet regulatory requirements.

Personal information refers to information that can identify an individual, including age, marital status, home address and telephone number, personal email address, employment history, social insurance number, bank account information or credit history. Such information may be provided to us on a signed account application or business contract, or by a phone call, by correspondence in mail or email to us, or by use of our website.

In accordance with current federal and applicable provincial legislation in Canada, including the Personal Information Privacy and Electronic Documents Act (PIPEDA), OTT has adopted privacy practices to protect personal information as part of its overall service commitment to its clients, and makes reasonable efforts to keep personal information secure and confidential. Each employee of OTT is required to handle clients’ personal information properly and to perform all duties in compliance with this Privacy Policy.

 

Principles of PIPEDA

Principle 1 – Accountability

Each employee of an organization is responsible for personal information under his or her control and designated individual(s) shall be accountable for compliance with its Privacy Policy.

Principle 2 – Identifying Purposes

The purposes for which personal information is collected shall be identified before or at the time the information is collected.

Principle 3 – Consent

The prior knowledge and permission of the individual are required for the collection, use or disclosure of personal information, except for legal or security reasons.

Principle 4 – Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified. Personal information shall be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention

Personal information will not be used, disclosed or retained for purposes other than those stated at the time of collection, except with the permission or consent of the individual, or as permitted or required by law.

Principle 6 – Accuracy

Personal information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.

Principle 7 – Safeguarding Information

Personal information will be protected by safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness

The policies and procedures of an organization relating to the management of personal information will be made readily available to its clients and employees for specific information.

Principle 9 – Individual Access

Upon request, an individual will be informed of the existence, use and disclosure of his or her personal information and shall be given access to it. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Handling Client Complaints and Suggestions

Individuals can address any complaint regarding compliance with the above principles to the Privacy Officer of an organization.

Privacy Practices of OTT

OTT recognizes an individual’s right to privacy. OTT adheres to the above ten principles of PIPEDA and only uses personal information for legitimate business purposes. The above privacy regulations pertain to all employees or representatives of OTT. Each employee of OTT is responsible for client personal information under his or her control and designated officers are accountable for compliance with this Policy.

What Personal Information Is Collected

The personal information we may collect from you includes:
* Identifiers – contact information including your first and last name, email address, username, phone number, home address, social insurance number, driver’s licence number, passport number, telephone number, fax number, and/or bank account number(s);
* Commercial information – records of products or services purchased, obtained, considered, sold, or other such records or behaviours;
* Publicly available information about you – for example, web engine search for address verification, or other records about you or your business; and
* Internet or other electronic network activity information – this may include analytical data (e.g. pages and products viewed, emails from us that you open, browser, operating system (“OS”), Internet Protocol (“IP”) address and device information, and any data collected by cookies). When you access our services by or through a mobile device, we may receive or collect and store a unique identification number associated with your device, mobile carrier, device type and manufacturer, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates or similar information regarding the location of your mobile device.

Why Your Personal Information Is Required

OTT is required by law to obtain and collect certain personal information about you as a client in order for us to set up and maintain an account or provide services for you. As stated below, such information will allow OTT to carry out its obligations under law and policies regarding client identification and verification, help establish a relationship with you and provide the best possible service to meet your needs:

* To understand and establish your identity as a client;
* To create a client record or file as required at OTT;
* To understand your needs and assess your eligibility for our services and products;
* To provide you with the services you have agreed to obtain from OTT;
* To send marketing communications or to conduct market research;
* To maintain business relations and protect you and us from error or any fraud; an
* To comply with all applicable law, regulations and compliance requirements.

Obtaining Your Consent

You consent is obtained before or at the time of opening an account or establishing a relationship with OTT. At such times, you will be required to provide certain personal information in order for us to establish the account or provide you services. The information may be collected via an OTT application form or agreement, in which case you will formally indicate your consent for OTT to collect and use your personal information when you sign the application or agreement. You may wish to withdraw your consent; however, without required information, OTT may not be able to maintain your account or provide you with the services requested.

Children

OTT does not collect, process, or use any information relating to an individual under 18 years of age without the prior consent of the child’s parent or legal guardian.

OTT does not intend its app or website for children, and has no intention of collecting personal information from children under 18 years of age. If you discover that your child has provided us with personal information, we ask that you contact us to have this information deleted from our records.

Purposes of Using Your Personal Information

After your personal information is provided to OTT’s employees or representatives, OTT may use it for the following purposes:

* To identify you as a client and create a Client Record or client information file for you;
* To establish and administer your account, and execute your transactions or services requested;
* To maintain, store, record and determine your account, transactions or services related records;
* To ensure our records about you are accurate, and to verify information obtained when necessary;
* To provide you with your account, transactions or services related confirmations or statements, receipts or other information that may be requested or needed to meet your needs;
* To provide you with quality client service and support on your account, transactions or services;
* To maintain our business relationship with you and protect the interests of you and OTT;
* To meet all applicable legal, regulatory and compliance requirements of OTT, such as those under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act; and
* For any other purpose to which you consent or that is permitted by privacy law and/or any other applicable law.

When communicating with you for the purposes above, you consent to receiving your account, transactions or services related communications from us in any form, including mail, email, phone call, or Internet.

How Personal Information Is Collected and Recorded

OTT collects personal information from you as a client in a number of ways as stated below. These ways apply to all methods of collecting personal information including hard copy, electronic and verbal means, and the personal information provided by you will only be used for the purposes indicated in the section above.

* Directly from you, when you provide information and sign OTT’s account application or agreement or transaction documents are completed and submitted to OTT for services or products you requested;
* Your voluntary disclosure of personal information directly to OTT by phone, mail, email, or our website, and such client account or service related information will be recorded and kept properly; and
* By contacting OTT staff or through those you authorized in writing to conduct business on your behalf.

OTT protects your personal information by using appropriate storage, which may be kept in electronic or paper format, and is gathered in a “Client Record”. Depending on the type of business or service required, OTT may need to keep additional information about your account or transactions when identified as a necessity during the business process, or as required by applicable law or compliance requirements.

During the process of providing services to you, OTT employees are required to obtain accurate, complete and current personal information from you, and to keep it updated as is necessary for the identified purposes related to your account, transactions, or services. Such information is required to be provided and updated in a timely manner in order for us to provide you with better service and to meet our regulatory requirements.

Limiting Use, Disclosure and Retention of Personal Information
Any personal information collected from you will only be used for the purposes identified at the time of collecting and will be retained for as long as is necessary to serve your account, provide services, or meet retention requirements under applicable law. If certain information requested is not provided, OTT may not be able to assess your application or needs.

In the course of business activities, all employees of OTT and authorized representatives or service providers are required to protect the confidentiality of personal information for limited use and stated purposes only. Access to your personal information is restricted to those authorized staff and representatives or service providers who need it to do their jobs. Under no circumstances will personal information be given or sold for monetary or other valuable consideration.

OTT may disclose your personal information to a related third party, business partner or government agency. This is done only to meet your service requirements or as may be required by any relevant law or government agencies.

Unless you have opted out, in addition to the above uses and disclosures, we may consult your personal information from time to time in order to determine your suitability for, and occasionally offer you, additional products and services. We may also disclose the above types of information to our affiliates and partners for their use for similar purposes and to send you information about their products or services

Protecting and Safeguarding Your Personal Information
OTT is committed to protecting your personal information in a manner consistent with our privacy practices. In order to ensure client personal information is protected, OTT keeps client information securely in its offices, requires all its employees to adhere to related policies and procedures during daily work when handling personal information, and takes appropriate security measures to safeguard your personal information. The security measures used include the following:

* Physical access security, restricted access to our offices;
* Passwords set up on our systems;
* Limited access to client records for those staff who need to know for their work;
* File encryption put in place to avoid unauthorized access, modification, or use;
* Requiring authorized third-party service providers or business partners to take appropriate measures to secure personal information or remedy to remedy any breach;
* Disposing of or destroying personal information as appropriate to prevent unauthorized access to personal information.

Right to Access Your Personal Information

You have the right to know and ask questions about your personal information after your personal information has been provided to OTT for your account activation. Your rights may include the following:

* Whether we hold any personal information about you;
* How we collect, use or disclose your personal information;
* Whether and how you can see or access that information;
* Accuracy or completeness of your personal information; and
* Other questions or issues you may have about your personal information.

You may contact us by phone, fax, mail or email by using the contact information listed below. When requesting access to your information, full access to your information is normally provided. However, there may be some legal or administrative limitations in certain cases. You may also request specific information about our policies and procedures relating to the management of your personal information by reviewing this Privacy Policy or by contacting us.

Updates to this Privacy Policy

Our Privacy Policy may be updated from time to time to reflect changes in our policies, applicable rules, regulations, or related compliance requirements. It is important for you to review this Privacy Policy by visiting our website regularly, as such changes may be made without prior notice.

Links to Third-Party Websites

Links to third-party websites on our sites or in our applications are for your convenience and ease of access to information. Once you access those links you will leave the OTT website and be re-routed to the third-party website. We do not control third-party sites or their privacy practices, which may differ from our own policies. We make no endorsement, representation or warranty about third-party websites. Any personal information that you choose to provide to third parties is not covered by this Privacy Policy.

You should review the privacy policy of any third-party website before submitting your personal information. Some third-party entities may choose to share your personal information, in which case your personal information will be governed by the privacy practices of the disclosing third-party entity.

Resolving Your Questions and Concerns

OTT employees are required to record and maintain the accuracy of the personal information in your file and to ensure that it is accurate, complete and up-to-date. However, from time to time, an error may occur. If you find any inaccurate information in your account or transactions, or your personal information has changed, please notify us immediately. We will correct or update it in a timely manner. In addition, if you have any questions, concerns or complaints about your personal information or our handling thereof, please contact us directly by using one of the methods below. Upon receipt of your request or complaint, we will contact you as soon as possible and will act diligently to address your concerns and/or resolve any issues appropriately.

Alternate Formats Available Upon Request

If you have difficulty accessing this Privacy Policy because of a disability, please contact us and we will work with you to make the information available in the appropriate format.