1. General

This Privacy Policy (the “Policy”) describes the type of information that Pennygem, Inc. (the “Company”) gathers from users (the “Users”) of the Pennygem website (the “Site”) and the Pennygem application for a mobile phone or any other device (the “App”), why the Company gathers such information, and how the Company uses that information. 

This privacy policy seeks to address any concerns with how your 'Personally Identifiable Information' (PII) may be used online. Under PIPEDA, personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your Personally Identifiable Information in accordance with our website. If you have any questions about your personal information or our privacy policy, please email us at info@pennygemapp.com.

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2. Reading, Agreeing, and Keeping a Copy

By requesting, accessing, or otherwise using our services, products, features, functions, technologies, or content offered on the Website, the App, and all related sites and applications, regardless of how accessed, including by computer, mobile phone, or any other device (collectively “Services” or “Pennygem Services”), you accept this Privacy Policy and agree to the collection and use of your Personal Information and the Personal Information of your dependents, if applicable, in accordance with this Privacy Policy.

There might be changes to the Privacy Policy from time to time; in case of the changes, the Site will be updated with the new information immediately. Further, you will be notified of any major changes to our Terms via email, text message, or in-app notification. 

Please see the definitions section below for any other capitalized words not otherwise defined.

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IF YOU DO NOT AGREE TO THIS POLICY, YOU OR ANY CHILD UNDER YOUR PARENTAL RESPONSIBILITY MAY NOT ACCESS OR USE THE SERVICES.

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3. Notice to guardians and other Primary Account holders 

As a parent or guardian (or other Primary Account holder) who has signed-up with a dependent(s) to use the Pennygem service, you are giving us explicit prior verifiable consent to collect, use and share their data in the ways specified in this Policy. By providing a set of verified contact details for their dependent(s), guardians are explicitly giving their permission for their dependents to be contacted. We are reliant on you providing accurate information in order to implement our Privacy Policy and cannot be held responsible if you circumvent age restrictions by providing the incorrect date of birth information. We encourage guardians to explain to their dependents how their information will be used, as set out in this policy.

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4. Definitions

In this Privacy Policy, the following terms will be understood as follows:

“Policy” means this Privacy Policy (as may be amended from time to time);

“Site” means the Pennygem website;

“App” means the Pennygem application for a mobile phone or any other device;

“Services”, or “Pennygem Services” means the applications, websites, content, products, and services made available by Pennygem;

"Company", “Pennygem”, “we”, “our”, “us” means Pennygem, Inc.;

“You”, “your” means any individual using the Services;

"Primary Account" means the service account with Pennygem established by the parent or guardian;

“Primary Account Holder” means the parent or guardian who establishes the service account with Pennygem;

“Sub-Account” means the linked account established by the Primary Account Holder for their dependent;

“Sub-Account Holder” means the holder of the Sub-Account;

“Pennygem Account” means the service account at Pennygem, established by the Primary Accountholder, through which the Pennygem Services are provided with regard to the Primary Account and Sub-Account(s) (dependent accounts);

“Account”, or "Membership Account" means the Primary Account or Sub-Account;

“Account Holder” means the Primary Account Holder and Sub-Account Holder;

“Users” means those using the Services collectively;

“Intellectual Property Rights” means all intellectual property rights wherever in the world arising, whether registered or unregistered (and including any application), including (without limitation) copyright, confidential information, patents, patentable rights, rights in know-how, database rights, trademarks, service marks, logos, URLs, domain names and design rights;

“Personal Data” means any personal information provided by you via the Services including (without limitation) the personal information described in Pennygem’s Privacy Policy;

"Anonymous Information" means information that does not enable identification of an individual User, such as aggregated information about the use of the Site, the App, or the Services.

“Submission” means any material from time to time submitted by you via the Services including (without limitation) any postings, messages, emails, or other communications, and any other text, information, data, photograph, image, audio, or visual material in whatever medium or form;

"E-Communications" means any electronic communication including but not limited to newsletter email, disclosure, notice, agreement, statement, schedule of fees, explanation of services, inquiry response, or any other communication regarding any account, product, or service provided to you, including Promotional Programs, directly or indirectly, by Pennygem.

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5. Information About Us

5.1 The Services are owned and operated by and on behalf of Pennygem, Inc.

5.2 Pennygem, Inc. is a corporation registered in Canada under the corporation number 1101412-9 and with the registered office at 25 Town Centre Court, Unit 3503, Toronto, Ontario Canada M1P 0B4.

5.3 PLEASE NOTE THAT PENNYGEM OPERATES THE SERVICES AND MEMBERSHIP ACCOUNTS TO HELP FAMILIES MANAGE POCKET MONEY. IT IS NOT A BANK OR A FINANCIAL INSTITUTION AND DOES NOT UNDERTAKE ANY ACTIVITIES WHICH ARE FINANCIALLY REGULATED IN CANADA OR ANY OTHER COUNTRY BY THE FINANCIAL SERVICES AUTHORITY. PENNYGEM DOES NOT HOLD ANY MONETARY DEPOSITS OR OPERATE OR MANAGE ANY FORM OF SAVINGS ACCOUNTS.

If you have any inquiries about these Conditions, please email us at info@pennygemapp.com.

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6. What Information Does the Company Collect?
The Company occasionally collects Personal Information from Users. "Personal Information" means information that can be used to identify an individual.

6.1 Consent and Modification

6.1.1 By using the Pennygem Services, you consent to the terms of the Policy and to our processing of Personal Information in the manner and for the purposes set forth in the Policy. If you do not agree with the Policy, please do not use the Pennygem Services.
6.1.2 The Company reserves the right, at its sole discretion, to change the Policy at any time, which change will be effective 10 days following posting of the revision to the Policy on the Site. Your continued use of the Site 10 days following such posting means you accept those changes.
6.1.3 If the Company makes any change in how we use your Personal Information, the Company will notify you by email (at the e-mail address specified in your account), or by means of a notice on the Site prior to the change becoming effective.

6.2 Information We Collect

6.2.1 The Company collects information in the following ways:

(i) Information Users Provide Directly. The Company collects information directly provided by Users as part of using the Pennygem Service ("User Content"), such as information provided when you subscribe to email updates on our website or sign up for the App. 

(ii) Cookies. The Company may use cookies and similar technologies, such as web beacons, pixels, and clear gifs, and third-party analytics services, such as Google Analytics, to collect and analyze information about Users. This may include information about Users' search preferences, interaction with the website, and location.

(iii) Log Files. The Site and the App may record certain log file information, such as IP address, location, mobile carrier, device, and interaction with links in the Site.

(iv) Device Identifiers. The Site and the App may access, collect, monitor, store on your device, and/or remotely store one or more device identifiers, which are small data files that uniquely identify it.

(v) Metadata. Metadata is technical information associated with Personal Information, such as how or when Personal Information was collected. The Site collects metadata on User Content.

6.2.2 The PII we collect depends on the context of your interactions with our Services, and the choices you make and may include the following:

(i) Contact information such as your and your dependant’s email address.

(ii) Demographic information such as your child’s age.

(iii) Security information such as usernames, passwords, password hints, security questions and answers, and other similar security information. 

(iv) Device and technical information such as IP address, unique device identifiers (such as the IMEI number for phones, the MAC address of the device’s wireless network interface), device functionality (browser type and version, operating system and platform, the hardware used, browser plug-in types and versions) and other similar device and technical information.

(v) Usage information such as the full uniform resource locators (URLs), information about page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), error reports, and performance data (i.e., details of the software or hardware related to an error, the content of files you were using when an error occurred), troubleshooting and help data plus other similar usage information.

(vi) Data resulting from the usage of the App and the Pennygem Services including but not limited to the virtual account balances and transactional data,  information as it relates to the Users creating jobs for their dependants within the App, online store purchase information, reviews for the items in the online store, and any other information as it relates to the usage of the App and the Pennygem Services.

(vii) Location information such as your device location which may include a street name and city, or GPS location, ISP or your mobile carrier, the URL of both the site you came from and the one you go to next and other similar locational information. We use GPS technology and Your IP address to determine your location - this may be used when the application is running in the foreground and the background of your device. Please also know that most devices allow you to prevent location information from being sent to us.

(viii) Any other information you directly provide to us when filling out forms, corresponding with us (i.e., email, conversations with Member Services by phone or chat sessions), filling out surveys, providing us with feedback and product reviews, and other similar information.

You have choices about the PII we collect. So, when you are asked to provide us with your PII, you always have the right not to do so. Please note however that if you choose not to provide us with your PII when prompted, you may not be able to use our Services.

6.3 Use of Information

6.3.1 The Company may use information from Users to operate and improve the Site and the App and its Services, and to deliver the Site and the App. These uses may include providing you with more effective customer service; performing research and analysis aimed at improving the Site and the App; automatically updating the Site and the App; diagnosing or fixing problems with the Site or the App, and displaying content customized to your interests and preferences. The Company might also use the information to display anonymized aggregated statistics to the Users of the App and in the Company’s external communications, reports, and blogs.
6.3.2 The Company also uses information from Users to communicate with Users. The Company may send certain mandatory service communications, such as welcome letters, information on technical service issues, security announcements and policy updates, and emails to notify of the Primary Account and Sub-Account activity. Moreover, if Users leave their email information through the signup form on the Site or the App, the Company will send updates about its blog and offers and updates as it relates to the App.
6.3.3 The Company does not use Users' personal information for building user profiles for commercial purposes not related to the provision of the Services. The Company may use Anonymous Information as described in this Policy.
6.3.4 Personal Information collected by the Site and the App may be stored and processed in Canada or any other country in which the Company or its affiliates, subsidiaries, or agents maintain facilities. By using the Services, you consent to any such transfer of information outside of your country. The Company may transfer your Personal Information to third-party companies for the purpose of storing or processing such information on its behalf. Such information may be transferred to other countries. The Company requires that these parties agree to process such information in compliance with the Policy. In particular, if you provide Personal Information, it may be transferred to and processed on computers in the U.S. and other countries.
6.3.5 The Company may disclose your Personal Information or any information submitted via the Site or the App if the Company has a good faith belief that disclosure of such information is helpful or reasonably necessary to (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, our Users, yourself or the public. The Company may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

6.4 Sharing of Information

6.4.1 The Company will not share your Personal Information except as provided for by this Policy. The Company will not sell Personal Information. The Company may share other information as provided by this Policy.

(i) Affiliates. The Company may share information collected by the Site, the App and through its Services with businesses that are legally part of the same group as the Company, or that become part of that group ("Affiliates").

(ii) Third-Party Service Providers. The Company may use contractors to collect, use, analyze, and otherwise process the information on its behalf. The Company requires such suppliers to handle information in a manner consistent with the Policy. The Company may occasionally hire other companies to provide limited services on its behalf, such as providing customer support, hosting websites, processing transactions, or performing statistical analysis of its services. Those companies will be permitted to obtain only the Personal Information they need to deliver the service. They will be required to maintain the confidentiality of the information and will be prohibited from using it for any other purpose.

(iii) Anonymous Information. The Company may use Anonymous Information or disclose it to third-party service providers, to provide and improve the Site, the App, and the Services. The Company may also disclose Anonymous Information to third parties for a fee.

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7. Retention

7.1 If you choose to close your account, your personal information will stop being visible on our Services within 24 hours. We retain your personal information after you have closed your account for the purposes for which it was originally collected, or for which it was further processed. If you want us to delete your personal information completely, please contact us at info@pennygemapp.com.

 

8. Other Information

8.1 Business Transitions

8.1.1 If the Company is acquired by or merged with a third-party entity, or if it is subject to a bankruptcy or any comparable event, the Company reserves the right to transfer or assign Personal Information in connection therewith.

8.2 Security, Confidentiality, and Integrity of Personal Information

8.2.1 The security of your Personal Information is important to us. The Company follows generally accepted industry standards, including the use of appropriate administrative, physical, and technical safeguards, to protect Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while the Company strives to use commercially reasonable means to protect Personal Information, the Company cannot guarantee its absolute security or confidentiality. If you have any questions about security, you can contact the Company at info@pennygemapp.com.
8.2.2 Please be aware that certain Personal Information and other information provided by you in connection with your use of the Site may be stored on your device (even if that information is not collected by the Company). You are solely responsible for maintaining the security of your device from unauthorized access.

8.3 International Users

8.3.1 The Company is located in Canada with most of its servers located in the United States and are subject to the applicable local and national laws. The Company operates in Canada and the United States.

8.3.2 Those who choose to access the Site, the App, or the Services do so on their own initiative and at their own risk and are responsible for complying with all local laws, rules, and regulations.

8.3.3 Users who choose to access or use the Site, the App, or the Services consent to the use and disclosure of information in accordance with this Policy and subject to such laws.

8.3.4 The Company may limit the Service availability, in whole or in part, to any person, geographic area, or jurisdiction we choose, at any time and in our sole discretion.

8.3.5 The Company does not represent or warrant that the Site, the App, or the Services or any part thereof, is appropriate or available for use in any other jurisdiction.

8.4 Children's Privacy

8.4.1 The Site is directed to and structured to attract Users over age 18. If you are under age 18, you are not permitted to use the Site.

8.4.2 The Company does not knowingly collect Personal Information from Users under age 18. If you are a parent with concerns about children's privacy issues in conjunction with the use of the Site, please contact the Company at info@pennygemapp.com.

8.4.3 We follow the guidelines and rules laid out by COPPA (the Children's Online Privacy Protection Act) and have adopted these policies to keep your children safe. Please note that there are a few exceptions to these policies as noted below in "Exceptions to Verifiable Guardian Consent and Information Collected from Children".

8.4.4 We will not knowingly collect, use, or distribute personal information from children under the age of 13 without prior verifiable consent from the guardian (Primary Account Holder). Personal information we collect from children under the age of 13 will be used solely by Pennygem for internal purposes only and will not be sold or otherwise distributed to third parties other than as laid out in this Privacy Policy.

8.4.5 If the guardian (Primary Account Holder) provides us with their dependant’s (Sub-Account Holder’s) email address, we might send the following communications to the Sub-Account Holder: 

(i) Essential service communications;

(ii) Push notifications and usage alerts e.g. allowance notifications, available balance information, transaction details, etc.;

(iii) The App updates.

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9. Exceptions to Verifiable Parental Consent and Information Collected from Children

9.1 We will not obtain verifiable guardian consent for the collection of a Sub-Account Holder’s personal information to use persistent identifiers on our Site or the App in order to support the internal operations of our Site or the App which include, among others: maintaining and analyzing the functioning of the Site or the App; performing network communications; authenticating users; personalizing content on the Site or the App; serving contextual advertising or capping the frequency of advertising; protecting the security or integrity of the User, the Site, the App, or the Service; and to ensure legal and regulatory compliance. A "persistent identifier" is a series of symbols that we assign to a User.

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