A. Collection and Use of Personal Information
The term “personal information” means information about an identifiable individual, and includes your name, address, postal code, mobile number, email address, date of birth, employment status, industry, occupation and other information.
We may collect personal information when you interact with UGO, including when you:
- Download and launch the UGO Wallet app;
- Register to use UGO Wallet;
- Use the following UGO Wallet functionalities:
- Storing and using gift, loyalty, membership and other cards;
- Storing and organizing your paper or electronic receipts;
- Using a UGO personalized email address “@ugowallet.ca” to send or forward receipts from merchants; or
- Using card suggestion capability to obtain quick access to cards based on usage and/or geo-location;
- Purchasing or gifting an electronic gift card (“e-Gift Card”)
- Consent to receive information and offers from UGO; or
- Contact us with a comment, question or complaint.
Information collected by UGO may be used to confirm your identity, protect from fraud and error, to comply with legal and regulatory requirements, for analytics and reporting, to generate offers and to otherwise provide and enhance the UGO services. In addition, UGO collects and uses personal information as follows:
i. Downloading the UGO Wallet app: When you download the UGO Wallet app to your mobile device, we may collect device-related technical information (as outlined in more detail below) for the purposes of determining whether your device is compatible with, and eligible to use, the UGO Wallet app.
ii. Registering to use UGO Wallet: When you use UGO Wallet for the first time, you will be asked to register and provide us with your information, including contact information.
iii. Adding and using a loyalty, gift, membership or other card in your UGO Wallet: When you add a loyalty, gift, membership or other card (“Card”) to your UGO Wallet, we will collect information necessary to facilitate your use of the Card through the UGO Wallet. When you use a Card that you have added to your UGO Wallet, UGO and the merchant will use information about the Card in order to facilitate and complete the transaction. UGO may receive confirmation that the transaction was successful, and in some cases, may also receive the number of loyalty program points you have earned in connection with the transaction for the purposes of notifying you that the points have been deposited to your loyalty program account. If you have geo-location enabled and choose to use the card suggestion capability, the approximate physical location of your device may be used to customize the display of Cards in your UGO Wallet. If you do not enable geo-location and still choose to use the card suggestion capability, information about your usage of Cards may be used to customize the display of Cards in your UGO Wallet.
iv. Using the receipts feature: When you (a) upload digital representations of your receipts or (b) forward or otherwise have sent electronic receipts or any other emails to your UGO personalized email address “@ugowallet.ca”, UGO will collect the information contained on these receipts and emails. The information contained in the digital representation of your receipt may include your name, address, a portion of your card account numbers, description of the goods and services, and the location of the merchant.
v. Purchasing or gifting e-Gift Cards in your UGO Wallet: When you make purchases of e-Gift Cards in your UGO Wallet, UGO will collect information on the e-Gift Card merchant, purchase amount, the date and time of the purchase, the sender and recipient’s first and last name and email address if completing a gifting transaction and other necessary information to facilitate the transaction and will share this information with third party service providers for the purpose of facilitating and fulfilling the transaction, maintaining a record of transactional activities, and to enhance the services associated with this feature. When completing a gifting transaction, your permission may be requested to access the contact list on your device. Only the contacts you select will be shared with UGO. You agree that the individual whose contact information you provide has consented to the purpose for which the information is being collected, used and disclosed.
vi. Offers and other communication: When you register with UGO or use your UGO Wallet, we may contact you by e-mail, phone, mail, text message, push notification or other similar methods with offers, surveys or information that we believe may be of interest to you. We may also display tailored in-app offers, surveys or ads through third party websites about products, services and promotions relating to UGO, its partners and other third parties that may be of interest to you. You can choose to not have us contact you with marketing offers by contacting us as outlined below.
vii. Relationship-based Ads on Third Party Websites: Depending on your marketing preferences, we may use your contact information for the purposes of enabling the delivery of tailored UGO ads on third-party websites such as social media or webmail sites with which you have a relationship. To opt-out of receiving such relationship-based ads, update your settings on your social media or webmail sites.
viii. Customer Service: When you contact us with a question, comment or complaint, register for updates through our website, enter one of our contests, sign-up for one of our promotions, answer one of our surveys, or leave a comment on our website or social media sites, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service, product and service offerings, and promotions.
B. Collection and Use of Technical Information:
When you use UGO Wallet, we collect the Internet Protocol (IP) address and other device-related information such as the make and model of your device, its operating system, mobile device identification number (IMEI), Media Access Control (MAC) address, geo-location (if enabled on your device), Integrated Circuit Card Identifier (ICCID), which identifies your SIM card, information about its screen size, and the date and time of your use. We use this information to facilitate the operation of UGO Wallet, to help us understand how our users’ use the UGO Wallet app, for our internal analytics and reporting, and to monitor and improve UGO Wallet. Such device-related information may be used as a mobile marketing identifier to offer UGO content and advertisements to you in third party mobile applications. To disable this feature, refer to the advertising settings on your device.
Please note that the ability to collect certain personal information is controlled by your device. Please refer to the documentation for your device regarding how to allow or block the collection of location or device information. If you choose not to provide location or certain device information, some services you request may not operate optimally.
C. Disclosure of Personal Information
i. Transactions: When you use UGO Wallet to complete a transaction by way of a Card, we facilitate the disclosure of information related to your device and such Card, to the merchant or their payment processor in order to process the transaction.
ii. Sale of Business: We may transfer any information we have about you in connection with a merger or sale involving all or part of UGO or as part of a corporate reorganization or stock sale or other change in corporate control.
iii. Service Provider Arrangements: We may transfer (or otherwise make available) your personal information to our affiliates, partners and other third parties who provide services on our behalf. For example, we may use service providers to host UGO Wallet-related services, facilitate transactions, or send offers or other communications on our behalf. Your personal information may be maintained and processed by our affiliates and other third party service providers in the US or other jurisdictions. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own purposes.
iv. Legal: UGO, our affiliates and our Canadian, US and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, to meet requests for information from regulators or to satisfy legal and regulatory requirements applicable to us, or as otherwise required by applicable Canadian, US or other law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims, protecting our rights or property, or as otherwise permitted by law.
v. The Toronto-Dominion Bank and its affiliates ("Bank Group"): We may share information about you with the Bank Group world-wide subsidiaries and affiliates for the following purposes:
- To manage your total relationship within the Bank Group, including servicing your Accounts and maintaining up-to-date information about you; and
- To comply with legal and regulatory requirements.
We have implemented administrative, technical and physical safeguards designed to protect personal information in our custody and control against unauthorized access, use, modification and disclosure, including appropriate measures to protect the safety of Card information. For more information about this feature, please refer to the FAQ.
E. Access to your Personal Information
You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. To request access, updating or correction of inaccuracies in your personal information that we have in our custody or control, email or write to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
How to Contact UGO
Mail: UGO Mobile Solutions, 33 Bloor Street East, Suite 700,
Toronto, Ontario, M4W 3H1