Privacy Policy

Protecting your privacy is really important to us. QUBER is committed to maintaining the accuracy, security and confidentiality of your personal information in accordance with applicable legislation. With this in mind, we're providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our website located at https://www.qubersavings.com (the “Site”) and our services accessible via our mobile device application (the “App”) (together, the “Services”).

This QUBER Privacy Policy (“Policy”) describes how the QUBER Technology Inc. (“QUBER” or “we”) collects, uses and discloses personal information of our Site visitors and our Service customers (collectively “customers” or individually “you”). By using the Services, you consent to the use of your personal information in accordance with this Policy and our Terms and Conditions. Unless otherwise defined in this Policy, terms used in this Policy have the same meanings as in our Terms and Conditions, accessible from https://www.qubersavings.com/terms.

For a printable version of this Policy, please click here.

“Personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. The types of personal information that QUBER may collect about its customers include (but are not limited to) your contact details and the types of information described below.

Identifiers: QUBER may collect identifiers such as full name, residential address, date of birth, Social Security Number (for US users) or Social Insurance Number (for Canadian users), Internet Protocol address, phone number, driver's license or email address. These are sourced directly from you or indirectly from you (e.g., from observing your actions on the Services or through our business partners). They are used to fulfill or meet the reason you provided the information, to contact you in relation to our Services, to respond to an inquiry, for product and service improvement, to screen for potential risk or fraud, to provide customer service, or marketing. We disclose identifiers for business purposes to third party business partners, banking partners, internet service providers and administrative service providers.

Bank Account Information: When you link a bank account to your QUBER Account, we will collect certain information about your Bank Account, such as your online login credentials for the purpose of providing the Services to you. If you give us access to your Bank Account, you acknowledge and agree that we will have access to your transaction information and your Bank Account balance (“Financial Information”) that we require in order to provide the Services to you. You may link one or several Bank Accounts to your QUBER account. We disclose Bank Account information for business purposes to administrative service providers and the financial institutions.

Commercial information: This may include records of services purchased, obtained, considered, or other purchasing or consuming histories or tendencies. We source this information directly from you. We use this information to fulfill or meet the reason you provided the information, to contact you in relation to our Services, to screen for potential risk or fraud, to respond to inquiries, to provide the products and services that you have ordered or requested, to provide customer service, or marketing. We disclose this information for business purposes to internet service providers, administrative service providers, and payment processors.

Characteristics of protected classifications: QUBER may collect characteristics such as age or gender. We source this information directly from you. We use this information to fulfill or meet the reason you provided the information, marketing, or to provide relevant services. We do not disclose this information to third parties.

Information Sent by Your Mobile Device: We collect certain information that your mobile device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about the use of our Services.

Location Information: When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device's GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

Inferences Drawn from Other Personal Information: QUBER may collect inferences drawn from other personal information, which may include a profile reflecting a person's preferences, interests, and characteristics. We use this information to fulfill or meet the reason you provided the information or for marketing. We do not disclose this information to third parties.

Your Online Activity — How We Use Cookies and Plug-Ins: We may also collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Site. Cookies are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer's hard drive. QUBER may set and access cookies on your computer to track, gather and store preferential information about you. Note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the Services may be impaired for you.

The Services also integrate certain third-party plug-ins (such as a Facebook like button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. These plugins are governed by the privacy policy of the company providing them.

We May Use Third Party Providers to Help Us Improve Our Services: We may also use third party service providers to help us analyze certain online activities. We may permit these service providers to use cookies and other technologies to perform these services for us. We do not share any personal information about our customers with these third-party service providers, and these service providers do not collect such information on our behalf. The Services also enable third-party tracking mechanisms to collect your non-personal information for use in online behavioral advertising.

• Google Analytics: To help facilitate the delivery of relevant content, we use Google Analytics. Google Analytics uses cookies to report on user interactions. We use the data collected for optimizing marketing, refining advertising and/or programming strategies, and generally improving user experience. For more information, please visit: https://policies.google.com/technologies/partner-sites.
• Facebook Analytics: We also use Facebook Analytics to measure your use of our Services. Please note, Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook's Data Policy.

Rewards Information: We may collect information about your purchases when participating in Cashback Rewards and other reward programs, such as purchase amount, purchase date, and status of purchase. This information is used to track and administer your rewards and is not shared with any 3rd parties.

1. What personal information do we collect?

From time to time we may request other personal information to provide you with other benefits of the Services. In all such instances, you will be given the opportunity to provide or to decline to provide that information, and it will be used only for the stated purpose. We may combine the personal information we collect from you with information we collect from other sources, both offline and online. This includes any information you provide to us while using our Services as well as when, where, and how you:

• make payments, purchases and transfers; or
• use our website, mobile application or services; or
• use any other services provided by our partners.

Your decision to provide any personal information is voluntary. However, please note that, if you do not provide certain personal information, we may not be able to accomplish some purposes outlined in this Policy and you may not be able to use or access certain Services.

2. Why do we collect your personal information?

In general, QUBER collects, uses and discloses personal information about you for the purposes of establishing, managing or terminating the customer relationship. More specifically, we collect, use and disclose your personal information for the following purposes:

• to analyze site usage and improve the Services;
• to deliver to you any administrative notices, alerts and communications relevant to your use of the Services;
• to market products and services that we believe may be of interest to you;
• to fulfill your requests for certain products and services;
• for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
• to de-identify your personal information and create aggregated data;
• to enforce our Terms and Conditions;
• to protect the security of the QUBER Services;
• to detect and protect QUBER, its affiliates, and other third parties against error, theft, fraud and other illegal activity;
• to engage in and complete business transactions involving QUBER or its affiliates;
• to operate and administer Cashback Rewards and other rewards features, including tracking eligible purchases, calculating rewards, and crediting any rewards to your account;
• for purposes permitted by and to comply with any legal or regulatory requirements and laws; and
• for such purposes otherwise identified to you from time to time or as you may otherwise consent.

3. To whom do we disclose your personal information?

Our Service Providers: QUBER and its affiliated companies use third-party service providers to help us manage and improve the Services. These service providers may collect and/or use your personal or other information to assist us in achieving the purposes discussed above.

Our Business Partners: We may also transmit your personal information to our banking partners in order to meet legal requirements. We may also share your personal information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Information Shared with our Marketing Partners: We will never share your Financial Information with our marketing partners without your express consent, but we may use your Financial Information to generate offers for financial products and services from our marketing partners that may be of interest to you.

Our Community and the Public: The Services contain comment fields and other features that permit you to share information publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.

Cashback Rewards: We do not share your personal information with Merchant Partners for purposes of Cashback Rewards. Cashback Rewards are tracked and paid through our systems without disclosing your personal identifiers. Merchant Partners may only receive aggregated or anonymized reporting to validate rewards.

Other Disclosures: QUBER reserves the right to share or disclose your personal information when QUBER determines, in its sole discretion, that the disclosure of such information is necessary or appropriate in the following circumstances:

• To comply with applicable law or a court order, subpoena, or other legal process;
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
• To establish, protect, or exercise our legal rights or defend against legal claims; or
• To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Business transactions: Your personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change of control. If transferred in such a case, the purchaser will abide by the terms and conditions of this Policy.

4. How do we protect your personal information?

The security of your personal information is important to us. We utilize physical, technical, and organizational security measures to protect against loss, misuse, and alteration of information under our control. We use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your session on QUBER App and to protect QUBER accounts and systems from unauthorized access.

However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.

You are responsible for keeping your Login ID, Password, Mobile Device, and Email Account confidential. We maintain strict rules to help prevent others from guessing your password. We also recommend that you change your password periodically. If you believe that your credentials have been stolen or been made known to others, you must contact us immediately at support@quber.ca, but in any event you should change your password immediately via the Services.

5. Where is your personal information stored?

Your personal information is stored in secured locations and on servers that are located either at our offices or at the offices of our service providers within Canada or the United States. For access to your personal information, please contact our Privacy Officer via the contact information below.

6. How can you access your personal information and what are your privacy rights?

You may have certain rights regarding your personal information under applicable law:

• Right to Access/Know/Portability: You may have a right to know, access, and receive a portable copy of your personal information. Upon written request, subject to certain exceptions, QUBER will inform you of the existence, use, and disclosure of your personal information and will give you access to that information.
• Right to Correction: You may have the right to ask for your personal information to be corrected or updated. We may ask you to provide documentation to support your request.
• Right to Delete: You may have a right to request that we delete personal information under certain circumstances. You can delete your personal information any time by requesting to have your account deleted. Merely deleting the app from your device does not constitute a request to delete your account.
• Right to Opt Out: Under certain laws, you may have a right to opt-out from certain activities, such as “sales” or “sharing” of personal information, targeted advertising, or profiling. We do not “sell” personal information and we do not knowingly “sell” the personal information of children under 16 years old.
• Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of these rights.

Financial Incentives: We may offer various financial incentives from time to time. The terms of a financial incentive will be provided at the time you sign up. You may withdraw from any financial incentive at any time.

8. International Transfer of Personal Information

If you choose to provide us with personal information, we may transfer that personal information to third parties, in accordance with local law. We may also transfer your personal information across borders, from your country or jurisdiction to other countries or jurisdictions in accordance with legal requirements. By providing personal information, you agree that your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

9. Children

We do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and you are aware that your children have provided us with personal information, please contact us. If we become aware that we have collected personal information from children, we take steps to delete that information.

10. How We Respond to Do Not Track Signals

The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.

11. Record Retention Policy

We will maintain your personal information for our records for as long as necessary to fulfill the purpose for which it is collected and in accordance with legal obligations, our record retention policy, to resolve disputes, and to enforce our agreements.

12. Changes to this Policy

QUBER reserves the right to modify or supplement this Policy at any time. If any changes are made to this Policy, we will notify you by posting a copy of the amended Policy on our website at www.qubersavings.com as soon as practicable following that update. Your continued use of the Services following such notification will be deemed to constitute your consent to such revised terms.

13. Contact Us

QUBER has a Privacy Officer to oversee compliance with this Policy. Should you have questions about this Policy or collection, use and disclosure practices of QUBER, you may contact the Privacy Officer in writing as indicated below:

• Privacy Officer, QUBER Canada
• 232 Botsford Street, Moncton NB, Canada E1C 4X7
• Email: privacyofficer@qubersavings.com

The Privacy Officer will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding QUBER's use of personal information.