Clip Money Inc. (“Clip Money”, “we”, “us” or “our”) services include the Clip mobile app (the “Clip App”) and the related Clip Money cash deposit services (collectively, “Clip”). With Clip, consumers and small businesses can conveniently drop their cash and coin at everyday retail locations, for subsequent deposit to their accounts at banks and other financial institutions. Clip is operated by Clip Money for use by you or the organization you represent (“you” or “your”). At Clip Money we are committed to protecting your privacy and safeguarding your personal information.

The purpose of this privacy statement (“Privacy Statement”) is to inform you about the types of Personal Information (as defined below) Clip Money collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.

Your privacy is one of our priorities. We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in the United States and Canada.

From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.

The following topics will be covered in this Privacy Statement:

1. To which companies does this Privacy Statement apply?
2. What is Personal Information?
3. How do we collect your Personal Information?
4. Where do we store your Personal Information?
5. How do we use your Personal Information?
6. To whom do we provide your Personal Information?
7. When and how do we obtain your consent?
8. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?
9. How long will we utilize, disclose or retain your Personal Information?
10. How can you review your Personal Information that we have collected, utilized or disclosed?
11. How do you know that the Personal Information we have on you is accurate?
12. What if the Personal Information we have on you is inaccurate?
13. What safeguards have we implemented to protect your Personal Information?
14. How do you contact us regarding access to your Personal Information or our privacy practices?

1. To which companies does this Privacy Statement apply?

This Privacy Statement applies to the collection, use and disclosure of Personal Information by Clip Money.

2. What is Personal Information?

“Personal Information” is any information that is identifiable with you, as an individual. Personal Information we may collect includes, but is not limited to:

• your full name, home address, email address, telephone number, mobile phone number and other contact particulars;
• your banking information, including your bank account number, bank balance, transaction history and branch details, and amounts you deposit with us;
• information relating to ongoing interactions with Clip, including deposit history, current and historical deposit amounts or bank balances, inquiries or complaints, and similar information;
• your banking information from other service providers of financial products and services where you have agreed to the sharing of your Personal Information with Clip; and
• other information with your consent or as permitted or required by law.

Personal Information, however, may not include your business title or business address and business telephone number when used or disclosed in your capacity as an employee of an organization.

3. How do we collect your Personal Information?

We will always collect your Personal Information by fair and lawful means (for example, when you register with us or deposit money with us). We may collect Personal Information from you directly and/or from third parties, where we have obtained your consent to do so or as otherwise required or permitted by law.

When you use Clip, you may register a user profile, link your bank account, deposit money, share certain information from Clip, and offer feedback about your experience. Taking such actions may include the provision of Personal Information. We collect such Personal Information so that we can provide Clip, offer improved or personalized features and process your deposits through your bank. In most cases, we retain it so that, for instance, you can return to view information on your Clip account such as the amount available to you and the status of your deposit.

We may collect standard internet log information about how and when you use our Clip or other sites that you share information to. This information may include but, not be limited to, your IP address and location data, weblogs, time, date, browser used, referring web addresses, other communication data, searches conducted, pages visited. We may collect, and we may collect on behalf of our third party providers, basic personal information and feedback from you through the Clip App.

In addition, to ensure that our Clip is optimized for ease of use, we or our service provider(s) may use cookies to collect standard information about your use of Clip and our relates websites, including your language preferences, your browser type and version, and similar information. These cookies are intended to optimize your experience when using our services.

4. Where do we store your Personal Information?

We will keep the Personal Information that we collect at the Clip Money offices or at the offices of our third party service providers, as applicable, including service providers in foreign jurisdictions such as the US, where it will be subject to the legal regimes of those jurisdictions.

5. How do we use your Personal Information?

We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):

• to provide you with requested services, and to register your account on Clip;
• to develop and maintain strong business relationships with customers and potential customers and partners;
• to manage your account with Clip Money;
• to respond to questions, comments or concerns regarding Clip or your deposits on Clip;
• to provide you with information about promotions and other marketing initiatives;
• communicate with you in respect to the product or service we provide,
• to assess your ongoing needs for other suitable products and services;
• to allow for more meaningful and useful sales and marketing initiatives;
• to conduct analytics to better understand our web traffic and marketing effectiveness;
• to collect opinions and comments in regard Clip Money’s operations and products;
• to perform demographic analysis for planning purposes (but only on an aggregate and anonymous basis);
• detect and prevent theft, fraud, or other criminal behaviour, and help;
• protect and safeguard the financial interests of Clip Money and our customers;
• to investigate legal claims;
• such purposes for which Clip Money may obtain consent from time to time;
• such other uses as may be permitted or required by applicable law; and
• to provide organizations that we have relationships with, with necessary data regarding your use of Clip e.g. your bank.

6. To whom do we provide your Personal Information?

Upon request, we will identify to whom, and for what purposes, we disclose your Personal Information at the time we collected such information from you and obtained your consent to such disclosure. We may, at any time, transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes – such as service providers that provide e-mail support, data storage or processing, or hosting. We may share aggregated demographic information with our partners and service providers.

In addition, we may send Personal Information outside of the country for the Purposes, including for processing and storage by service providers in connection with such Purposes. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. For written information about our policies and practices regarding service providers outside of the United States or Canada, contact our Privacy Information Officer in accordance with Section 14 below.

7. When and how do we obtain your consent?

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances.

8. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?

We ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with Personal Information are contractually required to observe the intent of this Privacy Statement and our privacy practices.

9. How long will we utilize, disclose or retain your Personal Information?

We may keep a record of your Personal Information, correspondence or comments, in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.

10. How can you review your Personal Information that we have collected, utilized or disclosed?

If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable.

11. How do you know that the Personal Information we have on you is accurate?

We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We ensure that you have access to and can control certain aspects of your profile on Clip. As such, we expect you, from time to time, to supply us with updates to your Personal Information when it changes.

12. What if the Personal Information we have on you is inaccurate?

You may contact us at any time, to challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information. Any time you make an inquiry about your Personal Information, we may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information.

13. What safeguards have we implemented to protect your Personal Information?

We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The safeguards we implement in each circumstance may depend on the sensitivity of the Personal Information and the reasonable expectations you might have for the protection of such Personal Information. The only employees, who are granted access to your Personal Information, are those with a business ‘need-to-know’ or whose duties reasonably require such information.

14. How do you contact us regarding access to your Personal Information or our privacy practices?

All comments, questions, concerns or complaints regarding your Personal Information or our privacy practices should be forwarded to our Privacy Information Officer as follows:

In writing:

Attn: Privacy Information Officer

Address:

Clip Money Inc.

333 Bay St #2400,

Toronto, ON M5H 2T6

By e-mail: