This is the Privacy Policy of Switch Hub Consulting Inc. (trading as “SwitchHub”). We are registered in Canada under Corporation No. 1261181-3. Our registered office is at 105 Consumers Drive, Whitby, Ontario Canada, L1N 1C4. We are regulated by the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) under registration Number M22578161.
At Switch Hub Inc., your privacy is important to us, and so is being transparent about our privacy practices.
This Privacy Policy (“Policy”) describes the information we collect from you and how that information is used and shared by us. It also includes details about the choices we offer you in relation to that information. If you are a customer of Switch Hub Inc., this Policy should be read with “Our Terms and Conditions”.
“Online Channels” means: Websites operated by us (“Websites”);
Software applications made available by us for use on or through computers and mobile devices (“Apps”);
Our social media pages and apps that we control (collectively, our “Social Media Pages”); and
HTML-formatted email messages that we send to you that link to this Policy or other communications with you.
Device notifications and other channels we use that are not Websites, Apps or Social Media Pages.
We may collect some or all of the following information: your name, date of birth, title, gender, mailing address, phone number, email address, nationality, occupation and social identification number or other tax identification number.
To comply with applicable laws and regulations (including anti-money laundering and counter terrorism financing laws (“AML/ CTF Laws”), we may collect identity verification information such as copies of your government-issued identification (including passport, driver’s license, social security card, government health benefits card or national ID card) or other authentication information, all of which may include photographs of you.
We also may provide you with the option of using identification verification technologies that analyse your facial imagery or other biometric information provided.
Financial Information:
In order to comply with AML/ CTF Laws, assess creditworthiness, and process payments and transactions we may collect financial information such as bank account details (account number, routing number), credit or debit card numbers, credit information or reports or tax information, such as withholding allowances and filing status.
To the extent permitted by applicable law, we may obtain, in the course of providing you with the services you request, background check reports from public records of criminal convictions and arrest records. Some jurisdictions require us to obtain your consent. Where you refuse to provide consent, we may be unable to provide services to you.
When you access our Online Channels, we collect server logs, which may include information such as IP address, access times and dates, pages viewed and other system activity, including the third-party site you were using before and after accessing our services.
We may obtain information about the devices you use to access our Online Channels including: the device type, operating systems and versions, the device manufacturer and model, preferred languages, and plugins.
Usage and Preference Information:
We collect information about how you interact with the Online Channels and how you use our Online Channels, including your user preferences and other settings selected by you. In some cases we do this by using cookies and other tracking technologies.
Geolocation Information:
When you use certain features of our Online Channels, we may collect information about your precise or approximate location as determined by data such as your IP address or mobile device GPS. Most mobile devices allow you to control or disable the use of geolocation services for applications by changing preferences on your mobile device.
Aggregated/Anonymised Data:
We may also collect or create aggregated and/or anonymised data about our users with anonymised or deidentified data. This data is used for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
We may collect any other Personal Information you may provide to us when you update your account information, respond to surveys, post to community forums, participate in contests or promotions, or use any other feature of our Online Channels or services.
We collect information about you in a variety of different ways, including the following:
We collect Personal Information and other information from you when you complete an application or form, register for an Switch Hub user account, submit to our verification procedures, apply for additional account features or services, conduct transactions, respond to our emails, messages or surveys, communicate with us including by telephone, email and online, provide feedback, participate in promotions or contests, provide referrals, or upload content. We make and store recordings of our telephone communications with you.
Switch Hub will collect your Personal Information from you unless it is unreasonable or impracticable to do so, or is authorised by applicable laws.
Information from Your Use of services:
When you use our services, we collect Personal Information and other information about you and the devices you use to access the Online Channels. If you connect your social media account to your Switch Hub account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Switch Hub account.
We use Personal Information we collect from or about you (including credit information) for several purposes, including:
You can opt-out of receiving marketing at any time through the unsubscribe function available in each marketing communication we send. Alternatively you can update your preferences by logging in to your SwitchHub account on the Website or contact us at customerservice@SwitchHub.ca or using the “Contact Us” information below.
We will never sell your Personal Information to marketers or other third parties. We may disclose or otherwise provide anonymised/aggregated data to third parties. However, we may share information about you, including Personal Information, with the following third parties if you ask us to, it’s required to provide our services to you, if we have a duty to disclose it or an applicable law allows us to do so for legitimate interests or business reasons:
To facilitate or support us in providing our services to you, we may share your Personal Information with other companies in the Switch Hub group (when applicable).
We engage a variety of service providers to enable us to provide our services to you. For example, service providers may be used to support technology or infrastructure, analytics and insights generation, collect debts, determine who we should market and advertise to, distribute marketing materials, conduct market research, perform audits, provide professional advice or other functions.
We will never sell your Personal Information to marketers or other third parties. We may disclose or otherwise provide anonymised/aggregated data to third parties. However, we may share information about you, including Personal Information, with the following third parties if you ask us to, it’s required to provide our services to you, if we have a duty to disclose it or an applicable law allows us to do so for legitimate interests or business reasons:
To payment processing service providers, intermediary banks and financial institutions to process your transactions.
To any of our partners, business associates, or contractors or your agents that you have authorised to have access to your Switch Hub account or your Personal Information in connection with the provision of our services. A partner’s, business associate’s or contractor’s access to and use of any transactional data provided by Switch Hub will be treated in accordance with that third party’s terms of use.
If you provide your consent, we may share your information including your Personal Information with other authorised third parties. Such disclosure will only be carried out in the manner described to you at the time you agreed to the sharing. Authorising a third-party application or website to access your Switch Hub account or participating in certain promotional activities constitutes such consent to share your information.
If we believe it is necessary or appropriate, we may share your Personal Information with law enforcement officials, government authorities, regulatory bodies or other third parties, including for purposes of: (i) enforcing our Customer Agreement or other applicable agreements or policies; (ii) protecting our rights, property, privacy, or security, or that of others; or (iii) complying with applicable law, legal process, or government orders.
If we are the subject of or are involved in any corporate merger, acquisition, consolidation, reorganisation, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with bankruptcy or similar proceedings), we may disclose or transfer data, including Personal Information, with third parties in connection with such events.
We collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we, our third party service providers or any recipients referred to in section 5. Countries to which we are likely to transfer your information are the Canada, Nigeria, United Kingdom, and United States of America. Whenever we transfer your information, we take steps to protect it.
We need to keep your Personal Information so that we can provide our services to you. Under relevant AML/ CTF Laws we need to keep your Personal Information and information about your transactions for up to 7 years from the end of your relationship with us. We also need to keep it for longer for legitimate business purposes (such as transactional information for our accounting purposes) and for other legal and regulatory reasons. Subject to this, we will destroy, erase, or anonymise your Personal Information when it is no longer needed.
You have choices regarding how to manage your Personal Information and how we use and disclose your Personal Information.
To ensure the information we hold is accurate, you should tell us as soon as possible if any of the information you have provided us has changed. You may request that we correct or update the Personal Information you provided to us at any time by logging into your Switch Hub account or by contacting us using the “Contact Us” information below. If you want to access a copy of the Personal Information we hold about you, you can contact us at privacy@SwitchHub.ca or using the “Contact Us” information below.
We will respond to any such request consistent with applicable law. Prior to changing or correcting your information or providing your information to you, we may be required to verify your identity.
There may be situations where we cannot action your request including where the information may impact the privacy of other individuals, the information is subject to legal privilege, the disclosure could threaten the safety, physical or mental health or life of an individual or Switch Hub is prohibited by applicable law from providing you with access. If this is the case, we will set out in writing to you any reasons for our refusal to provide access to such information.
We will take reasonable steps in the circumstances to ensure that your Personal Information is accurate, complete and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you. We will not routinely update your Personal Information unless such a process is necessary to fulfil the purposes for which the information was collected.
If you are a Californian resident, please refer to the “Additional Information for Californian Residents” section at the end of this Policy for more information about the requests you may make under the California Consumer Privacy Act.
If you are resident in the UK or European Union, please refer to the “Additional Information for UK/EU Residents” section at the end of this Policy for more information about the requests you may make under privacy legislation.
If you are resident in the UK or European Union, you may request further limits on our disclosure of certain of your Personal Information where such information is not required for delivery of our services by contacting us at privacy@SwitchHub.ca or using the “Contact Us” information below.
If you are a U.S. resident using our Services to conduct transactions for personal, family or other household purposes, you may request further limits on our disclosure of certain of your Personal Information to certain affiliated third parties.
Most mobile devices allow you to disable the use of location services, or revoke consent to applications to access your camera and photo library or send you push notifications. Some devices allow you to activate a ‘do not track’ function, reset your device specific advertising identifier. Please refer to your device settings to restrict collection of certain information.
You can opt out of receiving our marketing at any time through the unsubscribe function in each marketing communication or by updating your preferences under the “Your Profile” section or “Profile & Settings – Notifications” section when you log into the Website. Please note that if you opt out of marketing-related emails from us, we will continue to send you non-promotional messages that are required to provide our services, such as transactional receipts and messages about your account or our relationship with you.
We take appropriate technical, physical, and administrative measures designed to safeguard your Personal Information against loss, misuse, or unauthorised access.
The way we do this depends on the sensitivity of the information and the format in which it is contained. Security measures include technological measures such as encryption, physical measures like restricted access to offices and strategic measures such as security clearances and limiting access to a “need-to-know” basis.
Unfortunately, the transmission of information over the Internet or the telephone is never 100% secure and no data storage system can be guaranteed safe. We cannot warrant the security of data transmitted to us and any transmission is at your own risk.
We encourage you to understand the integral role you play in keeping your own Personal Information secure and confidential, always keep your log-in details secure. You should also take care not to give any security credentials we provide you or you choose (such as a password) to someone who is not an Switch Hub representative. We will never ask you for your full security credentials. If you are unsure, please end the session. If you suspect any unauthorised use or access to your account or information, please contact us immediately, using the “Contact Us” information below.
We use cookies and similar tracking technologies to recognise you and to customise your online experience. To learn more about cookies and the other tracking technologies we may utilise, please refer to our Cookie Policy, which includes a comprehensive overview of cookies and provides further details about how we use cookies and how to control our use of cookies. We do not currently respond to browser do-not-track signals.
We may partner with third parties to display and personalise SwitchHub advertisements to you and to track and report on the performance of those advertisements. These third-party partners use cookies and other technologies to gather information about your activities on our Online Channels, as well as information from third parties and your activities on other sites or online services on any of your devices, in order to serve you advertising based upon your online behaviours including browsing history and interests. They also use these technologies, along with information they collect about your online use, to recognise you across the devices you use.
Our Websites may include social media features, such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Website. These features may collect information about you and your online activities and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy statement of the company providing it.
This Policy does not apply to third party websites, applications, products or services, even if they are linked to our services or Online Channels, and we are not responsible for the privacy, information, or other practices of third parties. The inclusion of a link on the Online Channels does not imply endorsement. You should review the privacy policies of any third party websites you visit.
Our services are not intended for or directed at individuals under the age of 18. We do not knowingly collect Personal Information from individuals under the age of 18.
Switch Hub will investigate all complaints. For more information on how we manage complaints see our Terms of Use on complaints procedure or contact us at customerservice@SwitchHub.ca.
We may change this Policy from time to time. If we make any material changes we will notify you by means of a notice on our Websites. Any changes will become effective on the date specified in the revised Policy posted on our Websites.
If you have questions or concerns about this Policy, need it in an alternative format, have a specific request related to your Personal Information or any complaints about our privacy practices, please contact us at privacy@SwitchHub.ca