Privacy Policy

This policy is instituted by WeSpare Finance Inc., a company registered at 440 Stalwart Crescent, Ottawa, K1T 0H2, Canada (“we,” “us,” “our”).

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We are committed to safeguarding the privacy of our service users by clearly outlining our role as the data controller for their personal data. As a data controller, we determine the purposes and methods for processing personal data. “Personal Data” refers to any information that can be directly linked to a living, identifiable individual. This includes various pieces of information that, when combined, could identify a specific person.

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WeSpare Finance Inc. is the data controller for personal data it processes in connection with the Services. When you use payment or financial services provided by Züm Rails through our Services, Züm Rails (and, as applicable, its vendors, processors, payment networks, and financial institutions) may act as an independent data controller (or equivalent role under applicable law) for the personal data it processes in its systems. Züm Rails’s processing is governed by its own privacy policy and applicable customer agreement(s). Please review Züm Rails’s current privacy documentation and any Züm Rails customer agreement(s) presented to you for details about its data practices.

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We use cookies on our website. Non-essential cookies require your consent. While we take steps to protect your data, we cannot guarantee complete security during transmission. Data transmission is at your own risk.

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How We Will Process and Collect Your Data

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Legal Obligations. We may process any of your personal data identified in this policy where necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or those of another natural person. Please do not supply any other person’s personal data to us unless we prompt you to do so within our platform. Specifically:

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Account Data. We may process your account data (“Account Data”). This includes your name, email address, phone number, date of birth, and residential address. The source of the account data is you or your authorized representative. We process this data to operate our website, provide our services, ensure security, maintain backups, and communicate with you.

Legal Basis. Consent or our legitimate interests, namely the proper administration of our website and business, or the performance of a contract between you and us.

Profile Data. We may process information included in your personal profile on our website (“Profile Data”). This may include your occupation details, employment information, and any preferences you provide. We process this data to enable and monitor your use of our website and services.

Service Data. We may process personal data provided in the course of using our services (“Service Data”). This includes financial information, transaction history, Circle participation details, and any other data necessary to provide our services. The source of the service data is you, other Circle members (as applicable), or your financial institution and payment providers (as applicable). We process this data to operate our services, ensure security, maintain backups, and communicate with you.

Inquiry Data. We may process information contained in any inquiry you submit to us regarding services (“Inquiry Data”). We process this data to offer, market, and sell relevant services to you.

Correspondence Data. We may process information contained in or relating to any communication you send to us (“Correspondence Data”). This includes communication content and metadata associated with the communication. Our website generates metadata associated with communications made using website contact forms.

Transaction Data. We may process information relating to transactions, including purchases of goods and services that you enter into with us and through our website (“Transaction Data”). This may include your contact details, payment instrument details (in tokenized or masked form where feasible), transaction details, and related records. We process this data to supply the purchased services, facilitate contributions and payouts, manage returns and disputes, and keep proper transaction records.

Usage Data. We may process data about your use of our website and services (“Usage Data”). This includes your IP address, geographical location, browser type, referral source, length of visit, and page views. We process this data to analyze the use of our website and services.

Financial Data. As a financial technology platform offering savings circles, we may process additional personal data, including financial account details, payment information, transaction history, and related verification information (“Financial Data”). We process this data to provide and maintain our services, verify your identity (as applicable), prevent fraud, comply with regulatory obligations, and communicate with you about your account.

Züm Rails Services Data. We utilize Züm Rails to deliver payment processing and associated services, which may encompass credit and debit card processing, EFT/ACH processing, Interac E-Transfer, online payments, invoicing and bill presentment, transaction processing, handling of returns and chargebacks, as well as related customer support and risk monitoring. To facilitate these services, we share personal data with Züm Rails, which, along with its vendors, may collect personal data directly from you and your devices. The categories of data may include identification and onboarding information, such as legal name, date of birth, address, business information where applicable, and information necessary for verification and underwriting; contact information; device and network information; bank account and payment instrument details; transaction and funding history; chargeback and return history; risk and fraud indicators; and compliance-related information.

Purposes and Legal Bases. processing is necessary for (a) performance of a contract to provide you payment functionality and related services; (b) compliance with legal obligations and payment-system and network rules (including applicable Payments Canada rules and applicable card network rules); and (c) our and Züm Rails’s legitimate interests in securing the platform and preventing fraud and abuse. For personal data processed by Züm Rails in connection with its services, Züm Rails may be an independent controller and processes data in accordance with its own privacy policy and applicable customer agreement(s).

Fraud and Risk Data. We and Züm Rails (and its vendors and networks, as applicable) may process data related to fraud and risk, including risk scoring, identity and device signals, transaction monitoring, velocity checks, suspicious activity indicators, and return/chargeback events to prevent, detect, investigate, and remediate fraud, abuse, prohibited transactions, and violations of law, policy, or network rules. Processing is based on our legitimate interests and compliance obligations.

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Data Use by WeSpare Finance Inc.

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We use the personal information collected by us in the following ways:

Service Provision. To provide our services to you, ensure security, maintain backups, and communicate with you.

Payment and Financial Functionality. To offer and maintain our savings circles services in conjunction with the terms of our payments partner, Züm Rails; facilitate contributions and payouts; support customer service; and comply with applicable legal, regulatory, and network obligations.

Improvement. To conduct research and further develop our services for a better, more intuitive, and personalized experience.

Administration. To monitor the use of our website for technical administration.

Analytics. To use cookies to understand how you interact with our website, monitor aggregate usage, and improve our services.

Fraud Prevention and Compliance. To verify identities (as applicable), detect and prevent fraud and abuse, manage transaction risk (including returns and chargebacks), and comply with applicable laws and payment-system/network rules, including through our service provider Züm Rails.

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User Rights

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Under data protection law, you have the following rights:

Right to Access. You can request copies of your personal data.

Right to Rectification. You can request correction of inaccurate or incomplete data.

Right to Erasure. You can request deletion of your personal data under certain circumstances.

Right to Restrict Processing. You can request a restriction of processing your personal data under certain circumstances.

Right to Object to Processing. You can object to processing your personal data under certain circumstances.

Right to Data Portability. You can request the transfer of your personal data to another organization or to you.

Right to Complain. You can complain to a supervisory authority if you believe your rights have been violated.

Right to Withdraw Consent. You can withdraw your consent at any time.

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Exercising Your Rights. To exercise any of these rights, please contact us using the details provided in the “Contact Us” section. We will respond to your request within the applicable legal timeframe.

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Requests Involving Züm Rails. For personal data that Züm Rails controls and processes in connection with its payment services, you should submit your access, correction, deletion, restriction, objection, portability, or other privacy requests directly to Züm Rails using the contact methods described in Züm Rails’s privacy policy and/or the applicable Züm Rails customer agreement(s). If you send such a request to us, we will forward it to Züm Rails where appropriate and cooperate to facilitate your request, to the extent required by law.

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Location and Jurisdiction of Data Storage

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Data Storage and Transfer. Personal data collected by WeSpare Finance Inc. is predominantly stored and processed within Canada. We may also store and process data in other jurisdictions (including the United States) if necessary for service delivery, operational support, fraud prevention, dispute handling, or compliance purposes with our service providers like Züm Rails. By using our services and submitting your personal information, you consent to such transfer, storage, and processing within Canada and, where applicable, other jurisdictions.

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International Transfers. For users accessing our services outside Canada, please note that your information may be transferred to, stored, and processed in Canada or other jurisdictions where our servers and central database are located. Data protection laws in these countries may not be as comprehensive as those in your country. By using our services, you consent to your information being transferred to our facilities in these jurisdictions.

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Transfers to Züm Rails and Other Partners. Personal data shared with Züm Rails may be transferred to, stored, and processed in Canada, the United States, and other jurisdictions where Züm Rails, its vendors, processors, payment networks, or subprocessors operate. Such processing is subject to Züm Rails’s safeguards, agreements, and policies. By using our Services and payment functionality, you acknowledge these partner-enabled cross-border transfers.

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Disclosure of Personal Information. We do not disclose your personal data to third parties except as described in this policy.

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Disclosure

We may disclose personal data to our service providers, contractors, and affiliated organizations that need to know the information to process it on our behalf or provide services available on our website.

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This includes:

Service Provider Disclosure. Personal data may be shared with Züm Rails for payment processing and related services (including onboarding/underwriting support, transaction processing, returns and chargebacks handling, risk monitoring, customer support, and compliance).

Independent Controller Disclosure (Züm Rails). Where Züm Rails provides payment services, Züm Rails may act as an independent data controller for the personal data it processes and may use such data in accordance with its own privacy policy and applicable customer agreement(s). We share personal data with Züm Rails for payments, onboarding/underwriting, fraud prevention, dispute handling, and compliance with applicable rules.

Payment Processing Disclosure. We engage third-party payment processors and technical service providers to process financial transactions securely, necessitating the sharing of relevant personal data.

Payment Networks and Financial Institutions. We may disclose personal data to banks, card networks, payment networks, and similar financial infrastructure providers as necessary to process transactions, manage returns and chargebacks, support dispute resolution, and comply with network rules and legal requirements.

Underwriting, Onboarding, and Monitoring. We may disclose personal data (including business details where applicable), underwriting and onboarding documentation, and transaction details to Züm Rails to support onboarding, underwriting, approval, ongoing monitoring, risk management, and compliance activities. You acknowledge that such sharing is necessary to enable payment functionality.

Credit Agency Disclosure. Personal data may be shared with credit agencies to verify creditworthiness, prevent fraud, and report delinquent payments, where permitted and applicable.

Legal and Compliance Disclosure. We may share personal data as necessary to comply with legal obligations, respond to legal requests, and protect our rights, including responding to requests from public authorities.

Service Provider Obligations. Our contractual agreements with service providers require that they implement appropriate safeguards for personal data and utilize such data solely for purposes specified by our organization, except where a provider acts as an independent controller.

Legal Obligation Disclosure. Personal data may be disclosed when necessary to comply with a legal obligation, protect vital interests of the data subject, or protect the vital interests of another natural person.

Corporate Transaction Disclosure. Your personal data may be transferred as part of any merger, acquisition, reorganization, or sale of assets involving our organization.

Consent-Based Disclosure. We may disclose your personal data in circumstances where you have provided explicit consent for such disclosure.

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Data Retention

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Retention and Use of Personal Data. We retain your personal data only as long as necessary for the purposes set out in this policy. The retention period depends on the type of information and the purposes for which we use it. We take reasonable steps to delete or permanently de-identify personal data that is no longer needed. We may retain your personal data where necessary to comply with legal obligations, comply with payment-system and network rules, resolve disputes, enforce agreements, or protect your vital interests or those of another natural person.

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Partner Retention. Our service providers, including Züm Rails (and its vendors), maintain their own retention schedules and legal obligations. Personal data processed by Züm Rails is retained by Züm Rails in accordance with its policies, contractual obligations, payment-network requirements, and regulatory requirements, which may differ from WeSpare’s retention periods.

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Amendments to this Policy. We may update this policy from time to time by publishing a new version on our website. Each version will apply to information collected while it was in place. We encourage you to review this page periodically to stay informed about any changes.

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Cookies

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What Are Cookies? A web server sends a cookie (an identifier) to a web browser, which stores it. Each page request includes this identifier. Cookies can be “persistent” (stored until expiry) or “session” (expiring when the browser closes). While cookies typically don’t contain personal details, they can link to user-specific information.

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Cookie Types. We use cookies for the following purposes:

Authentication. To identify you when you visit our website and as you navigate our website.

Status. To help us determine if you are logged into our website.

Personalization. To store information about your preferences and personalize our website for you.

Security. As an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials.

Analysis. To help us analyze the use and performance of our website and services.

Cookie Consent. To store your preferences in relation to the use of cookies.

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Cookies Used by Our Service Providers. Our service providers use cookies, and those cookies may be stored on your computer when you visit our website.

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Google Analytics. We use Google Analytics to analyze the use of our website. Google Analytics gathers information using cookies. The information gathered is used to create reports about website use. Google’s privacy policy is available at:

https://www.google.com/policies/privacy

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Managing Cookies. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods vary from browser to browser and version to version. You can obtain up-to-date information about blocking and deleting cookies via these links:

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Browser

Google Chrome

Link

https://support.google.com/chrome/answer/95647

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Mozilla Firefox

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

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Opera Browser

https://help.opera.com/en/latest/web-preferences/#cookies

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Apple Safari and WebKit

https://support.apple.com/en-ca/guide/safari/sfri11471/mac

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Gnome Epiphany

https://help.gnome.org/users/epiphany/stable/pref-cookies.html.en

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Samsung Browser

https://www.samsung.com/uk/support/mobile-devices/what-are-cookies-and-how-do-i-enable-or-disable-them-on-my-samsung-galaxy-device/

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Blocking all cookies may have a negative impact on the usability of many websites.

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If you block cookies, you may not be able to use all the features on our website.

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Cookie Preferences. You can manage your preferences relating to the use of cookies on our website by visiting: legal@wespare.com.

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Other Clauses

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Third-Party Services. Our website may include links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

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Züm Rails Services. We use Züm Rails to provide payment processing and related services. Personal data necessary to deliver those services is shared with Züm Rails and may also be collected directly by Züm Rails (and its vendors) as part of onboarding, underwriting, transaction processing, dispute handling, and compliance. Züm Rails may act as an independent data controller for its processing and uses personal data in accordance with its own privacy policy and applicable customer agreement(s). By using payment functionality, you consent to Züm Rails’s collection and use of your personal data as described in its privacy documentation and any applicable Züm Rails customer agreement(s).

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Canadian Users. With regard to any content sent, received, or stored in Canada via the services provided to a customer location, WeSpare Finance Inc. shall use and disclose any “personal information” as defined by the Personal Information Protection and Electronic Documents Act (2000, c. 5) (“Canada Personal Information”) solely for fulfilling its obligations or exercising its rights under this policy, as approved in advance in writing by the customer, in accordance with the customer’s instructions, or to comply with laws or regulations, including responding to legal processes or court or administrative orders. Any Canada Personal Information submitted to WeSpare Finance Inc. shall be used and disclosed solely as set forth in this Privacy Policy.

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Corporate Details. This website is owned and operated by WeSpare Finance Inc. We are a Canadian Federal Corporation with business number 790943757RC0001 and Corporation Number 1534069-1. Our registered address and principal place of business is located at:

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WeSpare Finance Inc.
440 Stalwart Crescent
Ottawa, Ontario K1T 0H2
Canada

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Contact Us. You can contact us in the following ways:

Website Contact Form. Fill out our website contact form and submit it to us. We will respond as soon as possible.

Email. Send us an email at help@wespare.com. We will respond as soon as possible.

Partner Privacy Requests. For privacy requests concerning Züm Rails’s processing as an independent controller, please contact Züm Rails using the instructions provided in Züm Rails’s privacy policy and/or applicable customer agreement(s). If you contact WeSpare about Züm Rails-controlled data, we will forward your request to Züm Rails where appropriate.

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Data Protection Officer. Our data protection officer’s contact details are:

Alexander Jonathan Hardy Steffen
Barrister and Solicitor
410 Adelaide St West
Suite 200
Toronto, ON M5V 1S8
Canada

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Privacy Policy

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