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Privacy Policy

The NMBR Company, its subsidiaries, and their respective affiliates (collectively, “NMBR”, "we", "us", or "our") have provided this Privacy Policy (the “Policy”) to describe our personal information handling practices, and to assure you of our continuing commitment to take steps to protect all personal information that we collect in the course of commercial activities.

Individuals may access and use this website and our products and services (collectively, the “Services”) in various scenarios, for example: (i) as a website visitor; (ii) as an individual representing an entity that is a customer or client of our Services (“Customer”); (iii) as an individual representing an employer that is a client of a Customer (“Employer-User”); or (iv) as an individual who is an employee of an Employer-User (“Employee-User”) (each, a “User Status”). If you are an Employee-User, NMBR may collect information directly from you or from the Customer or the Employer-User associated with you. Please review your agreement with your Employer-User or respective Customer about how they share your information with NMBR.

"Personal information", as used in this Policy, means information about an identifiable individual. This Policy does not apply to an individual's business contact information where collected, used, or disclosed solely for the purpose of communicating with the individual in relation to their business, employment, or profession.

Please read this Policy carefully to understand our personal information handling practices. You agree to this Policy by using our Services. If you do not agree to this Policy, please do not use the Services.

Methods of Collecting Personal Information

This Policy applies to information we collect:

• on or through our provision of the Services;         
• in email and other electronic messages with us or the Services;         
• through resources you may download from the Services;         
• when you interact with our advertising and Services on third-party applications and services, if those services or advertisements include links to this policy; and        
• reasonably through your interactions with us or the Services.

This Policy does not apply to information collected:

• offline; or         
• by any third party, including through any application, website, product, service, or content (including advertising) that may link to or be accessible from or on the Services.

Personal Information NMBR Collects

We limit the amount and type of personal information collected to that which is necessary for our identified
purposes, and we collect personal information by fair and lawful means.
Personal information that we collect includes, but is not limited to:

 • customer name and contact information, including mailing address, telephone number, and/or
email address;
 •additional information for identity matching purposes, such as occupation, name of employer,
income, Social Insurance Number, date of birth, and/or driver's license number;
• information about the account, such as current and historical information and similar information
and records relating to the handling of any inquiries or complaints;
• payment-related information such as banking information, income and tax amounts; and
• such other information that is necessary for our identified purposes and that is collected with your
consent or as permitted or required by law.

Depending on your User Status, how we collect your personal information will differ. For example, for
Employee-Users, you may directly provide personal information to us, or your Employer-User may provide
your personal information to us in order to set up payroll as part of the Employer-User’s policies. Please
review the applicable agreement(s) to you for information about how your personal information may be
provided to us.

We also automatically collect generic IT information as you use our Services. This may include IP
addresses, web browser preferences, device information, and information collected through cookies and
other tracking technologies. We do not correlate tracking information to individuals in any way.

Purposes For Which NMBR Collects Personal Information

We collect and use personal information for purposes limited to those which are related to our businesses,
which include payroll and related financial services (collectively, the “Services”). We collect personal
information primarily from you, for instance, through your account information and supporting documentation you provide. We may also collect personal information about you through your ongoing interactions with us and, if you are a User, from the Customer with which you are associated and other financial institutions you have identified in your account information.

We may collect and use personal information for purposes such as, but not limited to, the following:

• to develop, provide, and improve the Services;
• to manage and promote the business activities of NMBR and its Customers;
• to verify identity and other information provided by you and to determine eligibility for products and
services;
• to open, administer and service accounts and to provide and administer any requested products or
services;
• to establish relationships, provide quality service to, and communicate with you;
• to protect the business interests of NMBR and its customers, including to verify your identity or to
detect and prevent fraud and other unauthorized or illegal activities;
• to maintain business records for reasonable periods to meet legal and regulatory record retention
requirements; and
• for other purposes identified by NMBR with your consent or as permitted or required by law.

Transfers and Disclosures of Personal Information

NMBR may disclose personal information in a number of circumstances, including:

• to contractors, service providers, and other third parties we use to offer the Services;
• to financial institutions for payment processing purposes;
• for the purposes of detecting and preventing fraud;
• for the purposes of meeting legal, regulatory, industry self-regulatory, risk management and
security requirements; and
• for other purposes identified by NMBR with your consent or as permitted or required by law.

In the course of fulfilling the purposes described above, NMBR may transfer your personal information to service providers, including affiliates or other third-party organizations or individuals retained by NMBR to perform functions on its behalf, such as marketing, data processing, customer service, office, security, collections, insurance, financial, and taxation services. When personal information is transferred to service providers, we use contractual or other means to ensure that a comparable level of protection is provided. Some of our service providers may be located outside Canada and will be subject to applicable legal requirements in that country, including lawful requirements to disclose personal information to government authorities in certain circumstances.

We may share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you. We do not provide any personal information to third parties for their own advertising or marketing purposes.

We may also use and disclose personal information in connection with the proposed or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of our business or assets for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of our business or assets may use and disclose your personal information for similar purposes as those described in this Policy.

Safeguards and Data Retention

NMBR uses reasonable safeguards and other security standards to protect all personal information in its custody and control against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which the information is held. Safeguards will vary depending on the sensitivity, format, location, and storage of the personal information. Only authorized employees, agents, partners, and third parties who require access to the personal information to fulfill their job requirements will have access to the personal information.

We only retain personal information we collect from you in order to fulfill an ongoing legitimate business need. When there is no ongoing legitimate business need to retain your personal information, we will delete or anonymize it.

Access and Accuracy

Individuals have the right to request access to or correction of their personal information that is held by NMBR. Requests must be made in writing, addressed to NMBR’s Privacy Team as per the contact information set out at the end of this Policy. We will respond to written requests within a reasonable time. Copies of records containing personal information may be subject to a fee. If this is the case, NMBR will inform the individual of the amount of the fee in advance. We will use our best efforts to ensure that personal information is as accurate, complete, and up-to-date as necessary for the identified purposes. If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information as required. If we refuse access to personal information or disagree with an assertion that information held by us is incorrect, we will provide a written explanation for such refusal and a description of our complaints procedure should an individual decide   to challenge such written explanation. An individual's right to access or correct personal information is subject to applicable legal restrictions. To prevent fraudulent access to the personal information stored by NMBR, we may take reasonable steps to verify an individual's identity before granting access or making corrections.

NMBR’s Websites and E-Mail Communication

NMBR does not guarantee the confidentiality of any communications made by you via e-mail or otherwise through our websites. If you wish to provide information of a confidential or sensitive nature to us, please contact us directly by emailing us at privacy@nmbr.co to arrange for delivery/transmission of such information by secure means.

We use cookies and other tracking technologies to improve your experience on our website, to facilitate the online application process and for internal research and reporting purposes. A "cookie" is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences, such as your IP address and the pages of the website that you visit. You can set your browser to notify you when you receive a cookie or to refuse cookies altogether. If you refuse cookies, however, you may not be able to use certain features of our website, view ads based on past visits to our website, or report or interact with ad impressions.

Our website may contain links to other websites of interest. These other websites are not governed by thisPolicy, and we are not responsible for any personal information which you provide while visiting other websites. We encourage you to read the privacy policy of every website you visit.

In compliance with Google's advertising policies, we use Google Adwords Search Engine Marketing (PayPer Click) and Display Advertising (Remarketing and Google Display Network). We use Google AdWords Remarketing in compliance with the Google AdWords Interest-Based Advertising Policy, which means that you may see our advertisements on Google and other third party websites on the internet after visiting our website.

We use Google Analytics for Display Advertising, including Remarketing, Google Analytics Demographics and Interest Reporting, Google Display Network Impression Reporting and the DoubleClick CampaignManager integration. You have the option to opt out of Google Analytics for Display Advertising and customize Google Display Network ads. For all the currently available opt-outs, please visit https://tools.google.com/dlpage/gaoptout.

We use the data collected through Google Analytics Demographics and Interest Reporting to better understand our website visitors in terms of demographics and interests, to improve our website content in order to cater to our audience, and to customize advertisements based on our audience's interests and demographics.

Consent

Consent to the collection, use, and disclosure of personal information may be given in various ways. Consent can be express or implied. In some circumstances, where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn consent, you will be considered to have consented for the purposes identified and described to you. By submitting personal information to NMBR or its service providers and agents, you consent to the collection, use, and disclosure of such personal information as described in this Policy or otherwise at the time of collection. If you provide NMBR or our service providers and agents with personal information of another individual, it is your responsibility to obtain consent from such person to enable us to collect, use, and disclose such information for the purposes set forth in this Policy. Subject to legal or contractual requirements and reasonable notice, you may withdraw your consent at any time by contacting NMBR’s Privacy Team at the contact information set out at the end of this Policy. If you withdraw your consent, we may be limited or unable to provide you with certain services or information.

In certain circumstances, as permitted or required by law, we may collect, use, or disclose personal information without the knowledge or consent of the individual. These circumstances include, but are not limited to: personal information that is publicly available as defined by regulation; where collection is clearly in the interests of the individual and consent cannot be obtained in a timely way; or to comply with a subpoena, warrant or court order.

Inquiries or Further Information

NMBR has created a Privacy Team to oversee compliance with this Policy and applicable privacy laws. Any questions related to the Policy or the handling of personal information by NMBR can be addressed directly to the Privacy Team at privacy@nmbr.co or the following address:

40 Temperance Street - Suite 3200
Toronto ON M5H 0B4

If you are not satisfied with our response to a privacy-related matter, you may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or at www.priv.gc.ca, or in Alberta or British Columbia, your provincial privacy regulator, as applicable.

We reserve the right to modify this Policy at any time. If we make a change to this Policy, we will post such changes on our website located at www.nmbr.co.