[This Privacy Policy was last modified on June 15, 2020]
This Privacy Policy governs the manner in which Wagepoint Inc., Wagepoint Holdings USA, Inc., and Wagepoint USA, Inc. (“we” and “us”) collect, use, store and discloses personal information concerning users (individually, a "User" and “you” and collectively, “Users”) of the Wagepoint family of websites, including wagepoint.com, the Wagepoint services and mobile applications such as Track and Luna (individually and collectively, the "Site"). This Privacy Policy applies to the Site and all products and services offered by Wagepoint Inc. via the Site (“Services”).
For the purposes of this Privacy Policy, “personal information” means information about an identifiable individual, as defined under applicable U.S federal and state privacy laws and Canadian provincial privacy legislation, including the Federal Personal Information Protection and Electronic Documents Act (PIPEDA). Where this Privacy Policy states that a list of items is “including”, the lists so described are meant to be examples and not exhaustive or exclusive.
You agree to let us collect and use your personal information as described in this Privacy Policy. Therefore, before you provide us with any personal information, you should read through this Privacy Policy in its entirety and understand its terms. We may update the Policy from time to time, so please check it occasionally. This Privacy Policy is incorporated into, made subject to and is governed by, that certain Terms of Use https://wagepoint.com/terms-of-use.html (“Terms”) by and between us and you (“you”).
At present, our website and mobile applications are directed at users in the Canada and the United States. If you are not a resident of Canada or the United States, please do not use our website or mobile applications.
We may ask Users or representatives of their employers to provide the following personal information as well as other personal information, as appropriate and necessary for payroll processing, for the provision of Services and for other purposes identified herein or otherwise communicated to Users:
We may collect personal information concerning Users in a variety of ways, including, but not limited to: when Users visit our Site, register on the Site, subscribe to our newsletter, respond to a survey, and in connection with other activities, services, features or resources, which we may make available on our Site.
We normally collect your personal information directly from you. However, we may collect your personal information from other persons, including government agencies and benefit providers and your employer and with your consent or as permitted or required by law. Before or at the time of collecting personal information, we identify the purposes for which we are collecting the information. We may not expressly refer to such purposes when personal information is communicated for an obvious purpose. If we wish to use or disclose your personal information for a new purpose, not included in this Privacy Policy, we will notify you and seek your consent.
We also receive and send data from our servers and from your browser when you visit our Site, and use our application, including your IP address, the time and information about the page you requested and the website through which you were linked to our Site, if any, browser name and version, the type of computer, technical information about a your means of connection to our Site (such as the operating system and the Internet service provider utilized), as well as other similar information. We may use tracking technologies in a variety of ways, including the following: keeping count of return visits to our Site; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on Site usage; and determining which features Users like best. We also use software that tracks certain keystrokes and logs keystrokes and mouse clicks for certain data fields for the purpose of customer technical support.
Our Site uses "cookies" to enhance User experience, including cookies from third party service providers. Users' web browser places cookies on their hard drive for record-keeping and analytics purposes. Users may choose to set their web browser to refuse cookies, or to alert them when cookies are being sent. If cookies are disabled, some parts of the Site may not function properly.
We may collect and use Users’ personal information for various purposes, including:
Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose. You should therefore not volunteer information that you do not want us to see, save or share.
You may withdraw consent to the use and disclosure of your personal information at any time, unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain Services if we do not have the necessary personal information.
The purposes for collecting personal information is set out in this Privacy Policy. We ask for your express consent for some purposes and may not be able to provide certain Services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask Users to provide their consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button). We may rely on “opt-out” consent for the collection, use and disclosure of certain types of information.
Personal information collected by Wagepoint Inc., Wagepoint Holdings USA, Inc., and Wagepoint USA, Inc. or on behalf of Wagepoint Inc., Wagepoint Holdings USA, Inc., and Wagepoint USA, Inc. will be stored on servers located in the United States and Canada. Where personal information is stored or processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s governments, courts or law enforcement or regulatory agencies.
We may make your personal information available to public agencies, intermediate payment processors or service providers for fraud prevention, risk management and to fulfill the purposes for which it has been collected or as set forth in this Privacy Policy. We will NOT sell, rent or trade your personal information to any third party. We may share generic, anonymized, aggregated demographic information not linked to any personal information regarding Site visitors and Users with our business partners for the purposes outlined above. Some of our service providers may be located in the United States. As noted above where personal information is processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s governments, courts or law enforcement or regulatory agencies.
We may share your personal information when authorized by law or as follows:
We will retain and use your information for as long as needed to provide you services, to maintain a record of your transaction(s) and/or as necessary to comply with our legal obligations, to resolve disputes and to enforce our agreements. We may also retain your information in an anonymized form for analysis, research, and marketing purposes.
Our website and mobile applications are not directed toward children under 13 years of age nor do we knowingly collect information from children under 13, and we request that they do not submit any Personal Information through our website or mobile applications.
Upon request received by us in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information. Requests to access personal information should be directed to our Privacy Officer:
Requests must be made in writing by mail or by e-mail. Individuals may be required to verify their identity in order to access their personal information. Any such identity documentation provided shall be used for verification purposes only.
We respond to requests for access to personal information within thirty (30) days of receipt of the request, or as may be permitted in accordance with applicable privacy legislation.
A fee for reasonable costs incurred may be charged when responding to more complex requests, if authorized by law. The individual will be informed of the applicable fee.
Requested information will be provided in a form that is generally understandable.
Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and to ensure that documents are not removed, individuals wishing to view an original record will do so at our head office and under the supervision of designated personnel.
We will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation. In the event that we refuse to provide access to information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. We will respond to your requests for access in accordance with applicable privacy legislation.
Personal information shall be kept as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used. To this end, Users should ensure that the personal information, which they have provided us, is as accurate, complete and up-to-date as possible.
Individuals have the right to challenge the accuracy and completeness of their personal information, which is maintained by us, and to have it amended as appropriate.
Individuals seeking a correction or amendment to their personal information should direct their requests in writing to the Privacy Officer:
All formal requests to amend personal information must be accompanied by appropriate supporting documentation. Our Privacy Officer will manage any exceptions. The amended information will be transmitted to third parties, as appropriate.
If the individual is not satisfied with the results of the request, we shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.
We have adopted appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure and destruction of your personal information, username, password, transaction information and other information collected via our Site.
The transmission of information via the Site happens over a SSL-secured communication channel and is encrypted and protected with digital signatures.
Nonetheless, transmission of information on the Internet is not completely secure. Therefore, we cannot guarantee the security of information sent to us electronically via our Site, by email or otherwise. Transmission of such information is therefore entirely at your own risk.
We reserve the right to update this Privacy Policy at any time. When we do, we will revise the date at the top of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect their personal information. By accessing the Site, Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications.
In the event that the modifications materially alter your rights or obligations hereunder we will make commercially reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notifications after such material changes are made. Our amended Privacy Policy will automatically take effect upon the date that an update is published. If you do not agree with any changes to the Privacy Policy, you should cease using our websites and/or services. Your continued use after the revised or updated Privacy Policy has become effective indicates that you have read, understood and agreed to the then-current version of the Privacy Policy.
If you are a California resident, California Civil Code Section 1798.83 permits you to request a notice regarding the disclosure of your personal information by us to any of our partners for the partners’ direct marketing purpose. If you are a California resident and would like a copy of this notice, please contact us at corporate@wagepoint.com. Please allow 30 days for a response.
We do not track our users and visitors over time and across third party websites to provide targeted advertising. Consequently, we do not respond to Do Not Track (DNT) signals. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
Any concern or issue about our personal information handling practices may be made, in writing, to the Privacy Officer. Upon verification of the User's identity, the Privacy Officer will act promptly to investigate the complaint and provide a written report to the User. If the User is dissatisfied with the report provided by the Privacy Officer, or feels that the corrective action taken by Wagepoint Inc. is insufficient, the User may direct a complaint to the provincial Privacy Commissioner in the province where they reside or, if applicable to the Federal Privacy Commissioner, in writing.
If you have any questions about this Privacy Policy, our privacy practices and/or the privacy policies and practices of our service providers, please contact our Privacy Officer at: