Privacy - DailyPay Canada

Last updated: August 12, 2024

This is the Privacy Policy (“Privacy Policy“) that governs how we, DailyPay Canada Operations, Inc., our parent company DailyPay, Inc., and our affiliates, including DailyPay, N.I., (collectively “DailyPay”, “we”, “our”, or “us”), use personal information that we collect, receive and store about individuals in connection with the use of our On-Demand Pay (“ODP”) websites located at www.dailypay.ca, mobile apps, and features, programs and partnerships which we offer in connection with the DailyPay ODP platform, and any other offerings for which another privacy policy does not govern (collectively, the “Services”). We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our information practices and the choices you can make about the way your personal information is collected, used, and shared in connection with our Services.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use our Services.

Hi, We’re DailyPay!

1.0. About DailyPay. DailyPay is the leading ﬁntech provider that enables employees to harness the power of their pay and provides innovative ﬁnancial products and solutions to consumers.

Personal Information Collection, Use, Disclosure and Anonymization.

The kinds of personal information that we process, and how we process it, depends on whether we are processing personal information on behalf of companies (i.e., employers) that we have partnered with, or whether we are processing personal information directly at your request when you sign up for the DailyPay platform.

2.0. Information We Process on Behalf of Employers.

2.1. To enable your employer to provide you access to the Services, we may process personal information from or about you on behalf of your employer. The personal information categories may include:

identiﬁers, such as your ﬁrst and last name, email address, phone number, and employee identification number; and
employment or ﬁnancial-related information, such as pay information, general workplace location information, and information relating to the account to which the pay is directed.

We process the above personal information on behalf of your employer, to make the Services available to employees. We rely on employers to comply with applicable privacy laws when collecting, using, or disclosing personal information through the Services. We require employers to ensure that they have obtained all authority to provide personal information to us in accordance with applicable privacy laws. Except as set out herein, we do not collect or use personal information provided by employers for any purpose other than to provide Services.

If you have any questions regarding the personal information we process on behalf of your employer, we encourage you to first contact your employer directly and/or review their applicable privacy policy.

3.0. Information We Process on Our Own Behalf

3.1. In making the Services available to employees, we may process personal information about you on our own behalf.

3.2. In order to utilize our Services, you are required to create an account (“Account”). We may offer different options to create an Account, including:

Online Registration Form: You may choose to complete and submit an online registration form. As part of the registration process, you may be asked to provide us with an email and mailing address, mobile phone number, date of birth, proof of identity documentation, and a password that you will use to access your Account, as well as other information that may be required to open your Account.
Third-Party Accounts: You may choose to create (or supplement) an Account by clicking on a "connect," "sign on," or an equivalent button that we may display on the site for a designated account that you have with a third-party website or service (each a "Third-Party Account"). Doing so will enable you to link your DailyPay Account and your Third-Party Account. If you choose this option, then we will obtain certain information, including personal information, from your Third-Party Account. The information that we obtain from your Third-Party Account is information that you have chosen to make available to us as part of your use of your Third-Party Account, and is typically identiﬁed in the privacy policy of your Third-Party Account provider. You acknowledge the Third-Party Account is governed by the terms of use and privacy policy of that account provider. Please note that to use this option, you will need to have, and may need to be signed-in to, an existing Third-Party Account.

3.3 Regardless of which method you choose to register your Account, we may send an email or text message to your nominated email address, mobile phone number, or to the email address that you have designated in your Third-Party Account to instruct you how to conﬁrm your registration. Once you register your Account, we may process personal information that you or your employer provides to us, including:

identiﬁers, such as your ﬁrst and last name, email address, phone number, and employee identification number;
employment or ﬁnancial-related information, such as pay information, general workplace location information, and information relating to the account to which the pay is directed;
government-issued identiﬁcation cards or the data they reﬂect, such as your driver’s license or state ID card;
communications with DailyPay via chat or phone call, to provide customer service; and
login credentials for your DailyPay account.
We may also include personal information we collect automatically, like when you visit our Website (see Section 6 of this Privacy Policy), including:
geolocation data, internet or network activity, such as general location or IP address for security and data validation purposes; and
user interface information on our site or in our mobile application, such as keystrokes, mouse clicks, page ﬂips, and what you viewed to provide faster and better user support and aid our engineering team in solving bugs and improving user experience.

3.4. When you register an Account to use the platform, we may process personal information for our own purposes, including:

data security and integrity, including fraud or illegal activity prevention and detection;
system maintenance and repair;
non-personalized advertising;
account maintenance or service;
marketing or advertising;
customer service;
processing or fulﬁlling transactions;
verifying customer information;
processing payments;
research and development of new products or improvement of existing products; or
service quality assurance or enhancement.

3.5. We may also use your personal information to provide and improve our Services, to create insights about our users, to contact you in connection with the Services and certain programs, features or offerings that you may have registered for, to advertise our Services, and to identify and authenticate your access to the parts of the Services that you are authorized to access.

3.6. If you send us a "Contact Us" request, such as a question, complaint, or administrative request (for example, to reset your password), whether by calling our customer service number, submitting an online form, emailing a DailyPay email address, text messaging a company number, or interacting with the chat function that we make available on the website, you may be required to provide us with certain information such as your name, phone number, and email address.

3.7. From time to time, we may offer you the opportunity to participate in one of our research projects. The information obtained through our customer research such as gender, age, marital status, ethnicity, etc. is used in an aggregated, non-personally identifiable form to help us understand our customers and to enhance our product and Service offerings, and for purpose of determining the impact of Services on user ﬁnancial wellness.

3.8. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct marketing. We may use your email address or mobile phone number to send you direct marketing communications, such as updates and news regarding the Services, and to market our products and Services to you, as permitted by law, including by email. If you no longer wish to receive these communications, you may opt-out of our marketing communications as described in the Opting Out section below. If you withdraw your consent, we may not be able to provide certain products or services to you.
Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads promoting our and other services across the web. These companies may use cookies and similar technologies to collect information about your interaction (including the data described above) over time across the Internet and use that information to serve online ads that they think will interest our business clients or prospects. You may opt-out of this interest-based advertising as described further in the Opting Out section below, but you may receive less relevant ads instead.

4.0. Use of De-identified Information. We may create de-identified data from personal information by excluding information that makes the data personally identiﬁable, and use that de-identified data for our lawful business purposes, including to provide workforce insights to our employer clients.

5.0. Sharing of Personal Information.

5.1. We do not sell, rent or disclose your personal information to third parties without your consent, except as described below or as required or permitted by applicable law.

5.2. Your Employer. Your personal information may be transferred (or otherwise made available) to your employer for purposes of supporting your experience with our Services, including your consent to wage deductions, and your use of the DailyPay Services (including early wage access taken, and payments made).

5.3. Service Providers. Your personal information may be transferred (or otherwise made available) to third parties who provide services to us or on our behalf. We use third parties to host and manage our website, and other services as required. Our service providers are only given the information they need to perform their designated functions. They are not authorized to use or disclose personal information for their own marketing or other purposes. Your personal information may be maintained and processed by us, our affiliates, potential employers, and other third party service providers in the US or other jurisdictions and outside of the jurisdiction in which you reside (which may include a transfer outside of Quebec for Quebec residents). In the event that personal information is transferred outside of Canada to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.

5.4. Legal and Compliance. We and our Canadian, U.S. and other foreign service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

5.5. Sale of Business. Personal information may be provided to third parties in connection with a merger, acquisition sale (including transfers made as part of insolvency or bankruptcy proceedings), or comparable event involving all or part of DailyPay or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

6.0. Information We Collect Automatically

6.1. Log Files. In general, you can visit our website without telling us who you are or submitting any personal information. However, we may make use of log ﬁles. The information inside the log ﬁles includes internet protocol (IP) addresses of all visitors to our website and other related information such as type of browser, operating system, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, help us understand our website activity, administer our Services, track users’ movement around our Services, gather user categorical data, and to monitor and improve our website.

6.2. Cookies and Other Tracking Technologies. Our website and mobile app may utilize cookies and other tracking technologies in order for us to provide or advertise our Services, and to enable, optimize, and analyze operation of our Services. A cookie is a small text ﬁle that may be used, for example, to collect information about website and Service activity. Certain cookies and other technologies may serve to recall information, such as an IP address, previously indicated by a user.

6.3. Session Replay. In addition to cookies and other tracking, we may also use third-party-provided analytics services (such as session replay services), and other technologies and services to collect information about your interactions with our content and Services. Session replay services consists of an analytics application that allow us to capture and analyze your interaction with our Services to better identify and repair any technical errors and optimize our Services. Such technologies and third-party-provided services may observe or record your activities when using our Services, including movements, scrolling, visit duration, clicks, information typed, and other interactions.

6.4. Browser Control. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin, and conﬁguring them to block third-party cookies/trackers.

6.5. Mobile Device Control. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

6.6. Website Control. You may also set your cookie preferences on our website. If you are not logged in or your IP address is blocked, you may have to re-set your preferences on a subsequent visit when you are logged in or your address is unblocked. You may also have to do so on each device from which you access our Services.

6.7. Do Not Track. Some Internet browsers may be conﬁgured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To ﬁnd out more about “Do Not Track,” please visit www.allaboutdnt.com.

6.8. Analytics Opt-Outs. Our website also uses web analytics services to help us gather and analyze information about how visitors use the website. We use these services to understand your use of the website, and compiling reports on website activity. You can prevent the storage of data relating to your use of the Website and created via the cookie (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links:

6.9. Advertising partner opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:

6.10. Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

Digital Advertising Alliance: http://optout.aboutads.info
Network Advertising Initiative: http://optout.networkadvertising.org

Note that because these opt-out mechanisms are speciﬁc to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

7.0. Links to and Interaction with Third-Party Products or Services. Our Services may enable you to interact with or contain links to your Third-Party Accounts and other third-party websites, mobile software applications and services that are not owned or controlled by us. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. This Privacy Policy does not apply to information collected by the linked websites. They have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we are not responsible or liable for the privacy practices or the content of these Third-Parties. Please be aware that the Third-Parties may collect personal information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third-Party with you choose to engage or interact with.

Your Rights

8.0. Access/Accuracy/Choices. To the extent that you do provide us with personal information, we wish to maintain accurate personal information. You may use the tools that we make available through our Services to remove or modify certain information in your Account. Subject to applicable law, you have the right to access, correct, or withdraw your consent to the use of your personal information. You may request access, correction of, or withdraw consent to the use of your personal information in our custody or control by emailing our Data Protection Officer at privacy@dailypay.com or submitted an online form to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records. Your right to access, correct, and withdraw consent to the use of the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

9.0. Opting In and Opting Out of Promotional Messages. You may choose to receive promotional and advertising messages from us by providing us with your written consent directly or through your employer. You may choose not to receive future promotional or advertising emails or text messages from us by selecting an unsubscribe link at the bottom of such emails, by texting STOP to opt-out of such text messages, or by contacting us at the contact information under the Contact Us section below. You also control your notiﬁcations in your account settings. If you opt-out of receiving the foregoing emails or text messages, we may still send you a response to any Contact Us request as well as administrative emails necessary to facilitate your use of our Services (for example, in connection with a password reset request, an email/text message veriﬁcation, or a payment-related email/text message).

Security and Records

10.0 Security. The security of personal information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security or conﬁdentiality. We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.

11.0. Record Retention/Deletion. We retain personal information no longer than reasonably necessary to achieve the collection and use purposes disclosed in this Policy. The criteria determining retention periods are based on legal obligations and information sensitivity, security, product research and development, technical functionality, and experience improvement considerations. DailyPay may also retain information not formatted for targeted disposal. We may also retain personal information:

to respond to or comply with court orders, subpoenas, or regulator inquiries;
as required by applicable provincial and federal law or regulation; and
in response to or in anticipation of litigation.

Miscellaneous

12.0. Children’s Privacy. Our Services are not structured to attract children under the age of 14 years. Accordingly, we do not intend to collect personal information from anyone we know to be under 14 years. If we learn that we have collected personal information from a child under 14 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us.

13.0. Information About Our Privacy Governance Policies and Practices. We are committed to protecting personal data and have implemented a comprehensive set of policies and practices that govern our treatment of personal data. These policies and procedures include, among other things, the following:

We have implemented policies and procedures to protect personal data in our custody and control from unauthorized access, use or disclosure.
We have implemented processes to respond to data subject requests and complaints in a timely manner.
We have implemented policies and procedures for the defined retention and secure destruction of personal data in compliance with legal obligations.
We have designated a Privacy Officer who is responsible for overseeing DailyPay’s compliance with privacy legislation.
We have implemented a privacy framework that defines the roles and responsibilities for our employees with respect to the treatment of personal data.
We provide our employees with regular privacy training and awareness.

14.0. Changes to this Privacy Policy. We reserve the right, at our discretion, to change this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services. If required by law, we will also provide notiﬁcation of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Services. Any modiﬁcations to this Privacy Policy will be effective upon our posting the modiﬁed version (or as otherwise indicated at the time of posting). We encourage you to periodically review this page to ensure you are familiar with those changes.

15.0. How to Contact Us. If you have any questions or concerns at all about our Privacy Policy or the manner in which we or our service providers (including our service providers outside Canada) handle your personal information, or wish to request access to or correction of your personal information in our records, please contact us at https://www.dailypay.com/legal/privacy-form/ or privacy@dailypay.com.