NED PRIVACY POLICY

UPDATED AS OF APRIL 16 2018.

Your relationship with needextradata (ned), your use of our website (the “website”), and your participation in the Data Incentive Program (the “Data Incentive Program”) (collectively, the “Services”) is governed, in part, by this Privacy Policy. This Privacy Policy tells you how ned collects, uses, discloses and retains Personal Information, including information collected by us through our website and telephone calls, and when providing you the Services.

1. Definition of Personal Information

“Personal Information” means information about you, such as your name, email address, phone number, date of birth, social insurance number, as well as financial information such as your monthly income and expenses, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables you to be contacted at your place of business.

2. Providing Your Consent

By using the Services and providing us with your Personal Information, you consent to the collection, use, disclosure and retention of your disclosed Personal Information, by us, in accordance with this Privacy Policy and as otherwise permitted by applicable law.

3. Withdrawing Your Consent

You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to ned. However, we may not be able to proceed with providing the Services offered to you, and we would not be able to proceed with offering further Services to you, and you would not receive the full benefit of ned’s Services.

4. Information That We Collect

(a) Information that You Provide

You will be asked to voluntarily give your Personal Information to ned when you interact, orally, in writing or by electronic transmission, with ned. In those circumstances, you can choose not to provide certain requested Personal Information, but then we may not be able to proceed with providing the Services offered to you, and we would not be able to proceed with offering further Services to you, and you would not receive the full benefit of ned’s Services.

(b) Electronic Collection (Automated)

ned may automatically collect certain information regarding your use of the ned Services, such as the dates and times that you access the website, and/or Data Incentive Program, the browsers, operating systems, software and devices that you use to access the website or online service and details of your use of the website or online service.

The ned Services may use

1. Technologies (e.g. cookies, web beacons, tokens, pixels or tags) to collect information that assists us to improve our products, services, customer communications and advertising and to prevent fraud; and

2. Information that we collect through technological means to recognize you as a user of the Services, to facilitate and improve your use of the Services, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements.

You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of the Services. Much of the information that is automatically collected by technological means is non-Personal Information and does not personally identify you, and such information is used as further explained in this Privacy Policy unless applicable law requires otherwise.

Personal Information That We Use

(a) General

We use your Personal Information collected for providing the Services and completing the Related Transactions and as otherwise set out in this Privacy Policy or permitted by applicable law, including:

  • to provide, complete, and administer the Services and the Related Transactions and to manage your participation in the Services and the Related Transactions; to market, manage, and process the Services and the Related Transactions;
  • to facilitate your interactions and transactions with us, authorizations for the Services, and to process and respond to your inquiries, requests and other communications;
  • to provide you with information (including by email and other electronic messages) regarding ned and its products and services and related products and services offered by other businesses, including principals, affiliates, partners and provider companies, to the extent permitted by applicable law;
  • to communicate information and offers to our principals, affiliates, partners and provider companies;
  • to understand and analyze our user’s responses, needs and preferences, and to develop new products and services to meet those needs and preferences;
  • to maintain, protect and improve the Services and Related Transactions, and to protect and enforce our legal rights, interests and remedies and to protect the business, operations and customers of ned and other persons; and
  • to assist our principals, affiliates, partners and provider companies to collect, use, disclose and retain your Personal Information in accordance with this Privacy Policy.

(b) Sharing Information

ned may share your Personal Information with our principals, affiliates, partners and provider companies who assist to

1. administer and deliver the Services and the Related Transactions;

2. provide information, products and services to you;v

3. facilitate your dealings with ned and as otherwise set out in this Privacy Policy.

(c) Interest-Based Advertising

ned may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by third party vendors (such as Google and Facebook) to display advertisements on third party websites and social media sites visited by users of the ned website. Advertising vendors (such as Google and Facebook) use cookies, pixels or tokens, which are unique identifiers of a web browser on a specific computer, that are installed on the computer when it accesses ned’s website, to display ads based on the computer’s past access to ned’s website. You can opt-out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page.

6. Personal Information that We Disclose

(a) General

We disclose your Personal Information for purposes relating to or arising from the provision of the Services and completion of the Related Transactions and as otherwise set out in this Privacy Policy or permitted by applicable law.

(b) Specific Consents

We may disclose your Personal Information in accordance with express or implied consents that you give during your interactions and transactions with the Services and Related Transactions.

(c) Principals, Affiliates, Partners and Provider Companies

ned may disclose your Personal Information to its principals, affiliates, partners and provider companies (including fraud prevention services and payment processors) to assist ned in the provision of Personal Information, products and services to you, to provide services to ned, to assist ned to use your Personal Information as set out in this Privacy Policy and as otherwise permitted by applicable law.

(d) Disclosure Required by Law

ned may disclose your Personal Information as required or authorized by law, including to law enforcement agencies, other independent organizations, and to third parties

1. to comply with a disclosure obligation pursuant to a legal process;

2. where ned reasonably believes the disclosure is necessary or appropriate in connection with security, law enforcement or other issues of public importance; and

3. where ned reasonably believes the disclosure is necessary or appropriate to protect and enforce ned’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of ned or other persons (including to detect and prevent fraud and other illegal activities, enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of the ned’s products or services).

ned has no control over, or responsibility or liability for, the use, disclosure or retention of your Personal Information by the agencies, independent organizations or other persons to whom ned discloses the Personal Information in the foregoing circumstances, and the use, disclosure and retention of the disclosed Personal Information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.

(f) Business Transactions

ned may disclose your Personal Information in connection with a proposed or actual business transaction in which ned is involved (such as a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of ned’s business or assets), but ned will require the information recipient to agree to protect the privacy of your Personal Information in a manner that is consistent with this Privacy Policy and applicable law.

7. Location of Your Personal Information

ned and its principals, affiliates, partners and provider companies may process, store and use your Personal Information at facilities in Canada and/or in other countries such as the United States of America. The Personal Information protection laws of any other countries might be different from the laws of and within Canada, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your Personal Information without notice. By providing your Personal Information to the ned, you consent to the transfer of the Personal Information to facilities located in other countries and the processing and storage of the Personal Information at those facilities.

8. How We Retain Your Personal Information

ned retains your Personal Information for a period of time reasonably necessary or a longer period required or permitted by applicable law

1. for the purposes set out or referenced in this Privacy Policy;

2. to comply with ned’s legal reporting obligations; and

3. to enforce or protect ned’s legal rights.

ned will delete or dispose of your Personal Information when ned is no longer reasonably required to retain your Personal Information for the purposes set out or referenced in this Privacy Policy.

9. How We Protect Your Personal Information

ned uses reasonable safeguards, including administrative, physical and technical security and safeguarding measures, appropriate to the sensitivity of the Personal Information in ned’s possession or under ned’s control to help protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. Nevertheless, security risks cannot be eliminated and ned cannot guarantee that your Personal Information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy.

10. Accuracy of Your Personal Information

ned will rely on you to ensure that your Personal Information provided is as accurate, complete and up to date as necessary for the purposes for which ned uses the Personal Information as described in this Privacy Policy.

11. Access to Your Personal Information

You may reasonably request access to your Personal Information collected and retained by ned and information about ned’s use, disclosure and retention of your Personal Information by submitting a written request to ned’s Chief Privacy Officer using the contact information listed on our website and/or listed below in this Privacy Policy. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your Personal Information and you will be entitled to verify the accuracy and completeness of your Personal Information and to have your Personal Information revised as appropriate. You may be required to pay a reasonable fee for access to your Personal Information. ned may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.

12. Collection, Retention and Use of Non-Personal Information

ned collects non-personal information (information that is not about an identifiable individual), including Personal Information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. ned may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with your Personal Information, then ned will treat the combined non-personal information as Personal Information for the purposes of this Privacy Policy for as long as the non-personal information is combined.

13. Other Websites and Businesses

ned’s website and correspondence (including emails and messages) may include advertisements for products and services (e.g. car sales, personal loans and credit cards) offered by independent businesses (that may have a financial relationship with ned) or links to websites operated by independent entities. ned has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your Personal Information. This Privacy Policy does not apply to the collection, use, disclosure and retention of your Personal Information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain Personal Information, please contact the owner or operator of the website, service or business.

14. Other Matters

(a) Disclaimers, Liability Exclusions/Limitations and Disputes:

The agreements (for example, ned’s Terms and Conditions, the Data Incentive Program rules, and this Privacy Policy) that you accept when you apply for or use the Services or Related Transactions contain important provisions, including provisions disclaiming, limiting or excluding the liability of ned and other persons (including principals, affiliates, partners and provider companies) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or ned’s collection, use, disclosure and retention of your Personal Information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

(b) Changes to this Policy:

ned may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on the ned website. ned’s collection, use, disclosure and retention of your Personal Information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with ned after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your Personal Information as set out in the changed Privacy Policy. Accordingly, you should check the “updated as of” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.

(c) Contacting ned’s Privacy Officer:

If you have any comments or questions about this Privacy Policy or how ned deals with your Personal Information, please contact ned’s Privacy Officer by mail or emailĀ privacy@needextradata.com

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