Privacy Policy

Willow Privacy Policy

Last Updated: January 11, 2022

Willow RET Holdings Inc. ("Willow") values and respects your privacy. We have prepared this privacy policy to explain the manner in which we collect, use and disclose personal information through our mobile and web application and our website located at www.willow.ca (collectively the "Willow Platform"), and otherwise interact with you.

  1. COLLECTION AND USE OF PERSONAL INFORMATION
    1. Create an Account:
    2. You do not have to register to visit the Willow website. However, if you choose to create an account in order to participate in the Willow Platform we will require certain information.

      • To create and administer your account, we will collect: your first and last name, email address and a password that you create.

      We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.

      • To verify your identify and comply with our regulatory obligations, we will collect: your home address, date of birth, government identification information, and banking information.

      By providing us with such information, you represent that such information is accurate and that you will keep such information current at all times during the term of your account with us. If we believe or suspect that your information is not true, accurate, current or complete, we may deny or terminate your access to the Willow Platform in accordance with our Terms of Service, which are available at www.willow.ca/en/terms-of-service.

    3. Marketing Communications and Advertisements
    4. If you sign-up to receive electronic marketing communications such as newsletters or text messages, we will collect your email address and cell phone number. You can unsubscribe at any time by clicking the "unsubscribe" link included at the bottom of each message. Alternatively, you can opt-out of receiving electronic marketing communications by contacting us at the contact information provided in the "Contact Us" section below. Please note that you may continue to receive transactional or account-related communications from us.

      If you engage with our marketing campaigns on social media websites such as engaging with an influencer's post, we may collect information (e.g. likes, shares, and comments) for the purposes of evaluating the effectiveness of our marketing campaign

    5. Location Information
    6. We may have access to certain information about your location, such as your country or address, when you provide it or via device information (such as an IP address). If you access our sites on your mobile device we may collect information about your device's precise location.

    7. Push Notifications
    8. If you provide your consent to receive push notifications, we may display push notifications on your mobile device such as welcome messages, product features and promotional offers. If you wish to stop receiving push notifications from us, you can turn off push notifications for the mobile application in the settings of your mobile device.

    9. Website purchases
    10. If you are making a purchase on the website, we (or our authorized third-party payment processor) may collect payment information (including billing address, credit card number, expiry data and CVV code) in order to process the transaction. In such event, it is our policy to redirect you to a payment processing portal hosted by a third-party payment processor. Please read the privacy policy on our payment processor's website regarding the use, storage and protection of your credit card information before submitting any payment information.

    11. Careers
    12. If you apply for a job with us, you may provide us with certain personal information about yourself, such as information contained in a resume, cover letter, or similar employment-related materials. We use this information for the purpose of processing and responding to your application for current and future career opportunities.

    13. Referrals
    14. The Willow Platform may permit you to tell others about Willow. This feature requires you to submit your name and email address, as well as the name and email address of the recipient. We do not use the names or email addresses submitted in these circumstances for any other purpose without the consent of you or the email recipient to do so. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship.

    15. Connecting Social Media
    16. You can engage with some of our content and offerings, such as videos, articles, images, games, applications, and other offerings on or through third party communities, forums, and social media sites, services, plug-ins, and applications ("Social Media Sites"). If you connect your social media account, you authorize us to access certain account information (consistent with your social media account privacy settings), including your name and email address as well as any public messages you post. We use such information from the Social Media Site to personalize your experience on the Willow Platform and Social Media Sites, to provide you with products or services you may request, to communicate with you, and otherwise in accordance with this Privacy Policy.

      We do not have access to or collect any information contained in the direct messages of your social media account. You may disconnect your Social Media Site accounts from us at any time in your settings. We do not have control over the manner in which your personal information is treated on these Social Media Sites. Please review the privacy policies that apply to those social media accounts for more information.

    17. Contact Us
    18. When you contact us with a comment, question or complaint through email or telephone, you may be asked for information that identifies you, such as your name, email address and telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings.

    19. Call Recording
    20. We may monitor and record our telephone conversations with you for documentation, training, and quality assurance and documentation purposes. You will be provided with a notice at the beginning of any call that is being recorded. If you do not wish to have your call recorded, please let us know.

    21. Technical and usage information.
    22. We also collect certain technical and usage information when you use the Willow Platform, such as the type of device, browser, and operating system you are using, your Internet service provider or mobile carrier, unique device identifier, IDFA or IDFV, MAC address, IP address, device and browser settings, the webpages and mobile apps you use, advertisements you see and interact with, and certain website usage information. See our Cookies and Other Technical Information section for more information on how we may use these technologies to collect this information.

  2. SHARING OF PERSONAL INFORMATION
    1. Service Providers
    2. Your personal information may be transferred (or otherwise made available) to third parties that provide services on our behalf.

      We use service providers to provide the following types of services:

      • Verification of your identification documents and identity;
      • Fraud, crime, and risk management services, including money laundering and terrorist financing checks, credit risk checks, as well crime and fraud prevention services;
      • Technical and IT services, such as the operation and hosting of the Willow Platform;
      • Advertising and marketing services;
      • Payment processing services; and
      • Accounting, financial, and legal services.

      Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada or other foreign jurisdictions. In the event personal information is transferred 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. Our service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes.

    3. Legal and Compliance
    4. We, our affiliates and our Canadian, U.S. and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, to other organizations in the case of a breach of an agreement or contravention of law or for the purposes of detecting, preventing or suppressing fraud, or as otherwise required or permitted by applicable Canadian, US or other law (which may include lawful access requests by courts, law enforcement and government institutions in such foreign jurisdictions). We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

    5. Sale of Business
    6. We may transfer or disclose any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of the Willow or as part of a corporate reorganization or other change in corporate control.

    7. Business Parties
    8. With your consent, we may provide your personal information to our affiliated companies, co-sponsors or other business partners to use in accordance with their own privacy policies. We may share your personal information so that our business partners, affiliated companies or co-sponsors may provide you with information on the products and services they make available to you through the Willow Platform or that may be of interest to you.

    9. Other Reasons
    10. Where required or permitted by applicable law, we may share your personal information for other reasons.

  3. INTERNATIONAL TRANSFER
  4. We operate internationally, and some of our computer systems are currently based in the United States, this means information we collect will be processed by us or our affiliates or service providers in the U.S. where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union or Canada.

  5. INFORMATION ABOUT THE WILLOW PLATFORM
    1. Visiting our website and the Willow Platform
    2. In general, you can visit our website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to the Willow Platform, including our website and the Willow Platform and other related information such as page requests, browser type, operating system and average time spent on the Willow Platform. We use this information to help us understand your activity and to monitor and improve the Willow Platform.

    3. Cookies, tracer tags, and web beacons
    4. The Willow Platform uses a technology called "cookies". A cookie is a tiny element of data that the Willow Platform sends to a user's browser, which may then be stored on the user's hard drive so that we can recognize the user's computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from us, you may not be able to take advantage of all of the Willow Platform features.

      The Willow Platform may also use a technology called "tracer tags" or "web beacons". This technology allows us to understand which pages you visit on the Willow Platform. These tracer tags are used to help us optimize and tailor the Willow Platform for you and other future visitors to the Willow Platform.

    5. Analytics for the website and the Willow Platform
    6. We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Willow Platform (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Willow Platform. For more information or to opt-out using the Google Analytics opt-out browser add-on, see Google's support at: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631. We do not link the information we store within the analytics software to your account.

    7. Third Party Links.
    8. The Willow Platform may contain links to other websites that we do not own or operate. 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. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

  6. MOBILE APPLICATIONS

    From time to time, we may offer certain mobile apps, including iOS applications ("Apps"), for download. We will use commercially reasonable efforts, given the limitations imposed upon us by third party providers such as Apple Inc. and Google Inc., to clearly disclose what, if any information is collected by the particular App, how it is used, and with whom it is shared. Please note, certain practices are outside of our control, for example, tracking by Google Inc., Apple Inc., or your third party telecommunications carrier. We are not responsible for the actions of such third parties. You should always read and understand the policies of any third party provider, such as Google Inc with respect to Android apps and Apple Inc with respect to IOS apps, and your wireless carrier, before making any purchase or downloading any app.

  7. SAFEGUARDS AND RETENTION

    We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

    We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.

  8. YOUR CHOICES
    1. Unsubscribe
    2. As indicated above, if you have signed-up to receive our email communications, you can unsubscribe any time by clicking the "unsubscribe" link included at the bottom of the email. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under "Contact Us" below.

    3. Managing cookies and other technologies

      Cookies can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). Check your browser settings to learn how to delete cookies.

      You may adjust your browser to reject cookies from us or from any other website. Controlling cookies via browser controls may not limit our use of other technologies. Please consult your browser's settings for more information. However, blocking cookies or similar technology might prevent you from accessing some of our content or services.

      You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. To opt-out of Google Analytics relating to your use of our website, you can download and install the Browser Plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en.

  9. ACCESS TO INFORMATION

    Subject to limited exceptions under applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody and control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying your identity before providing access to their personal information records.

  10. CHILDREN

    While the Willow website is a general audience website, we do not permit anyone under the age of majority to create an account with us to access the Willow Platform. We also do not send email correspondence to anyone who tells us that they are under the age of majority.

    Children should always ask their parents or guardians for permission before providing any contact information to anyone online. We urge parents and guardians to participate in their children's online activities and use parental control or other web filtering technology to supervise children's access to the Internet.

  11. UPDATES TO THE PRIVACY POLICY

    We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated. If we are required by law to obtain your express consent for any changes to the Privacy Policy, then we will make a commercially reasonable attempt to obtain your consent before implementing such revisions.

  12. CONTACT US

    If you have any questions or comments about this privacy policy or the manner in which we or our service providers treat your personal information, or to request access to your personal information in our records, please contact us at support@willow.ca or contact Michael Hibberd, Chief Operating Officer, at mike@willow.ca.