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</ul>OnGuard<sup>®</sup> and ID Assist<sup>®</sup> - Privacy Policy<p>This Privacy Policy is effective February 2022.</p>
<p>We understand that protecting your identity and personal information is critically important to you.
This Privacy Policy applies to the OnGuard and ID Assist monitoring services, including financial identity monitoring, digital identity monitoring, lost wallet protection, credit bureau monitoring, emergency travel services, and identity restoration (the "Services") provided to you through Sigma Loyalty Group ("Sigma").
In this Privacy Policy, Sigma may be referred to as "we", "us", and "our".
This Privacy Policy serves to inform you about how your information is used and protected by Sigma in providing the services.
Please read this Privacy Policy carefully.
If you do not agree to the terms and conditions of this Privacy Policy, please do not use the Services.</p>
<p>Your use of the Services is also subject to our Terms of Use.</p>
Collection and Use of Information
<p>We collect personal information when you use the Services.
"Personal information" is any information relating to an identified or identifiable natural person.
We collect the following information from you in the following ways and for the following purposes:</p>
<ol>
<li>
<strong>Your Credit Report Information</strong>
<p>As part of the Services you have requested, we may, based on the authorization you have provided, retrieve or access your credit report information from credit reporting agencies on your behalf, and provide that information to you.</p>
<p>Except for the purposes of customer service support, we do not disclose that credit report information to anyone except you.</p>
</li>
<li>
<strong>Other Personal Information Collected to Provide the Services</strong>
<p>We collect information such as your name, mailing address, email address, phone number, date of birth, or other information that may be needed to verify your identity.
Credit card or other payment information may also be collected.</p>
<p>Your personal information collected by Sigma may be obtained from your financial institution, or directly from you, for the purposes of enrolling you to receive this service.</p>
<p>Your personal information is used for the purposes of delivering you the Services, which includes obtaining your credit information, hosting and maintaining the website, providing internet surveillance, and providing you with ongoing credit bureau monitoring.</p>
<p>We collect this personal information in order to:</p>
<ul>
<li>Process your application for the Services.</li>
<li>Verify your identity and retrieve your credit report information.</li>
<li>Provide other services to you, including payment processing, customer service, lost card reporting, and restoration services.</li>
</ul>
</li>
<li>
<strong>Information by Telephone</strong>
<p>If you contact us by telephone, we may monitor and/or record your discussions with our customer service representatives for our mutual protection to confirm our discussions with you.
We may also use your call for coaching and training purposes.</p>
</li>
<li>
<strong>Information by Email</strong>
<p>If you contact us by email, we will use your email address to acknowledge your comments and/or reply to your questions.
Your email and our response may be stored by us as confirmation of our communication.</p>
</li>
<li>
<strong>Cookie Information</strong>
<p>We use "cookies" to:</p>
<ul>
<li>Help personalize our website</li>
<li>Ensure a secure connection when delivering services involving sensitive personal information</li>
<li>Analyze and optimize the use of the Services</li>
</ul>
<p>Cookies are small bits of computer code that your browser creates to store data locally on your computer or smartphone.
Most Web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely.</p>
<p>If you decide not to accept cookies from our website, you might not be able to take advantage of all of its features.</p>
<p>We may also use cookies from a third-party service provider to gather and analyze information about the areas that have been visited on the website, to help us evaluate and improve the convenience of the website, and to help us evaluate some of the specific information related to your website visits.</p>
</li>
<li>
<strong>Surveys and Customer Research</strong>
<p>From time to time, we may offer you the opportunity to participate in one of our surveys or other customer research.
We use this information to help us understand our customers and to enhance the product and service offerings.</p>
</li>
</ol>
Sharing and Disclosure of Information
<p>We may share your personal information to the following entities in the following circumstances:</p>
<ol>
<li>
<strong>Service Providers</strong>
<p>We may transfer or disclose personal information to service providers who assist in the fulfillment of our services to you.</p>
<p>Our service providers are given only the information they need to perform their designated functions, and they are not authorized by us to use or disclose your personal information for any other purposes.</p>
<p>We require our service providers to protect personal information which has been provided to them in a manner that is consistent with our privacy and security practices.</p>
</li>
<li>
<strong>Legal Compliance</strong>
<p>Sigma, our affiliates, and other service providers may be required to provide your personal information in response to:</p>
<ul>
<li>A search warrant or other legally valid inquiry or order,</li>
<li>An investigative body permitted by applicable Canadian law in the case of a breach or contravention of a law.</li>
</ul>
<p>We may also disclose personal information where necessary to:</p>
<ul>
<li>Establish, exercise or defend a legal claim,</li>
<li>Investigate or prevent actual or suspected loss or harm to persons or property.</li>
</ul>
<p>In the event we are required by law to disclose personal information, we will take reasonable steps to verify the lawful authority for the collection, and disclose only the information that is legally required.</p>
</li>
<li>
<strong>Business Transactions</strong>
<p>We may disclose personal information in connection with a proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets.
This confidential disclosure would be for the purpose of evaluating and/or performing the proposed transaction.</p>
<p>If required, our assignees or successors may use and disclose your personal information for similar purposes as those described in this Privacy Policy in order to continue providing you with our services.</p>
</li>
</ol>
Restricted Access
<p>To access your personal information on the website, you are required to select a user name and password.
It is your responsibility to restrict access to your user name and password so that only you may gain entry to your personal information online.</p>
<p>If you have concerns that your user name or password may have been compromised, contact Customer Service immediately at 1-866-327-3078.</p>
Security
<p>We recognize the importance of having advanced security on our systems to safeguard your information.
However, while we may implement reasonable security measures, please understand that no data transmissions over the Internet can be guaranteed to be 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.
It is important that you protect and maintain the security of your account credentials and you should immediately notify us of any unauthorized access to or use of your account.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps.
By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services.
We may post a notice via the Services if a security breach occurs.
We may also send an email to you at the email address you have provided to us in these circumstances.
Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
We review our security procedures regularly to ensure that they are properly administered and remain effective and appropriate.</p>
Children’s Privacy
<p>You must be above the age of majority to be eligible for our Services.
We do not knowingly solicit or retain information from children.
In the event we learn we have collected information from children, we will immediately delete such information.</p>
Changes to Our Privacy Policy
<p>From time to time, we may update our Privacy Policy to provide greater clarity about our information handling practices.</p>
<p>If however, we should make a substantive change to our Privacy Policy that significantly impacts how we collect, use, or disclose personal information, we will post a prominent notification on our website in advance of the implementation.
We encourage you to periodically review this Privacy Policy to keep up to date on how we are handling your personal information.</p>
Access to Your Information
<p>Correction of any information contained within the credit report must be done by you through the credit reporting agency.</p>
<p>With the exception of your credit report information as outlined above, you have the right to access, update and correct inaccuracies in your personal information in our custody or control.
To access your personal information, a request must be submitted in writing to us at:</p>
<p>Sigma Loyalty Group
<br>P.O.
Box 3020 STN D
<br>Toronto, Ontario M9C 4V5</p>
<p>We will take reasonable steps to verify your identity before granting access or making corrections.</p>
<p>We will respond to your request for access, update, and/or correction within a reasonable time.
Certain changes to your personal information may be subject to legal restrictions and, if applicable, these will be communicated to you.</p>
Opt-Out
<p>From time to time, we may contact you about additional offers relating to our services and those of our partners.
You may opt-out of being contacted about such services by contacting Customer Service at 1-866-327-3078.</p>
Retention of Personal Information
<p>We will retain your personal information as long as you are enrolled in the service provided by us, and to satisfy any legal compliance.</p>
Contact Us
<p>We take our commitment to privacy seriously.
We will investigate and respond in a reasonable time to your questions or concerns about the privacy of your personal information and our privacy procedures.</p>
<p>You may contact us by:</p>
<ul>
<li>Calling our Customer Service Contact Centre at 1-866-327-3078</li>
<li>Email to privacy.canada@sigmaloyaltygroup.com</li>
<li>Mail to the Privacy Officer at Sigma Loyalty Group, P.O.
Box 3020 STN D, Toronto, Ontario M9C 4V5</li>
</ul>
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