Privacy Policies

INTRODUCTION

Glow Financial Services Canada Corp, or its subsidiary, as the case may be ("Glow," "Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal information in accordance with this privacy policy and applicable Canadian privacy laws, including Canada's Personal Information Protection and Electronic Documents Act. If you are a resident of Quebec, the Act respecting the protection of personal information in the private sector (CQLR c. P-39.1) (the "Quebec Privacy Act") also applies to how we handle your personal information, and we comply with both that Act and the federal legislation named above.
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This privacy policy explains how we collect, use, disclose, retain, transfer, protect, and otherwise process personal information when individuals use a computer, electronic device and/or the Glow mobile application (collectively, the "App") to apply for financing to purchase a new mobile device from a telecom carrier.
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In this policy, "personal information" means information about an identifiable individual, including information that, alone or together with other information, can identify an individual.
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In this policy, information is "anonymized" only where it irreversibly no longer allows you to be identified, directly or indirectly, in accordance with generally accepted best practices and the criteria and terms determined by regulation under the Quebec Privacy Act. Anonymized information is not personal information and is not subject to this policy. Information is "de-identified" where it no longer allows you to be directly identified but where re-identification remains reasonably possible. If you are a resident of Quebec, de-identified information remains personal information, and we continue to treat it as such under this policy and the Quebec Privacy Act.
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We collect, use, and disclose personal information only for the purposes described in this policy, and with your consent or as otherwise permitted or required by law.
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Please read this policy carefully. By downloading, accessing, registering with, or using the App, or by submitting personal information, including through the App, you acknowledge that you understand this policy and consent to the collection, use, and disclosure of your personal information as described in this policy. If you are a resident of Quebec, we do not rely on this acknowledgement alone as your consent; instead, we obtain your consent for the specific purposes described in this policy, in clear and simple language, and we obtain your express consent where the law requires it.
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If you do not agree with this policy, do not use the App or submit personal information through the App. Some personal information is required to process a financing application, verify identity, prevent fraud, arrange device purchase and wireless activation, and administer financing; if you do not provide required information, we may not be able to provide those services.
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This policy applies only to personal information that Glow collects through or in connection with the App. It does not apply to the privacy practices of any telecom carrier, IDVerse, credit bureaus, payment processors, your device manufacturer, your mobile service provider, or any other third party that may have its own privacy policy.

We encourage you to read the privacy policies of the applicable telecom carrier, IDVerse, credit bureaus, payment processors, and other third parties before providing information to them or authorizing us to share information with them.

INFORMATION WE COLLECT ABOUT YOU

• We collect the following categories of personal information, depending on how you use the App and the information needed to process your financing application:
• Contact and identifying information, including your first name, middle name, last name, home address, email address, mobile number, and date of birth.
• Government-issued identification information, including driver's license number, driver's license expiry date, the province or territory that issued the driver's license, an image of the driver's license, passport or other government-issued identification number and expiry date where applicable, and an image of the passport or other government-issued identification where applicable.
• Identity verification images and biometric-related information, including an image of yourself taken with your smartphone or tablet (a "selfie") and information derived from your selfie and identification document images for identity verification and fraud prevention. If you are a resident of Quebec, we do not collect a selfie or biometric-related information from you, and we verify your identity using your government-issued identification only. Where this policy refers to a selfie or to biometric information, those references do not apply to residents of Quebec.
• Social insurance number, if you choose to provide it, including in connection with a driver's license-based application, or if you do not have a driver's license and elect to provide your social insurance number to complete identity and credit verification.
• Employment and income information, including your employment status, income frequency, and total income before taxes.
• Debit card information, including Visa Debit or Mastercard Debit card number, expiration date, security code, and associated country.
• Financing application, approval, and loan information, including your application details, financial approval status, funding status, financing account information, repayment information, and payment status, including late payments.
• Credit information, including information we obtain from credit bureaus, such as credit reports, credit scores, credit history, and information used to assess creditworthiness and administer financing.
• App, device, and usage information, such as device type, operating system, IP address, mobile network information, App interactions, logs, and other technical information collected through the App. This may also include location information, cookies and similar tracking technologies, mobile SDK data, analytics data, crash logs, and other device or usage information collected through third-party service providers that support the operation, performance, analytics, or functionality of the App.
• Communications and support information, including records and copies of correspondence, email addresses, phone numbers, and other information you provide when you contact us for support or ask questions about the App or financing.
• Some information we collect, including government identification, social insurance number, selfie, biometric-related information, credit information, income information, and debit card information, may be sensitive. We use enhanced care for sensitive information and limit our collection, use, and disclosure to the purposes described in this policy and other purposes permitted or required by law. If you are a resident of Quebec, we obtain your express consent to the collection, use, and communication of sensitive personal information, meaning personal information that, because of its nature (as applicable, including its medical, biometric, or otherwise intimate nature) or the context in which it is used or communicated, entails a high level of reasonable expectation of privacy. As applicable, this includes your government-issued identification, social insurance number, selfie and biometric-related information, credit information, and income information.

AUTOMATIC INFORMATION COLLECTION AND TRACKING TECHNOLOGIES

When you download, access, or use the App, Glow and its service providers may automatically collect technical and usage information for to operate, secure, maintain, troubleshoot, and improve the App; prevent fraud; and support your financing application; and, in certain cases for marketing purposes.
 

• Usage details. We may collect details about your access to and use of the App, including logs, interaction data, error reports, timestamps, and resources accessed through the App.
• Device information. We may collect information about your mobile device and internet connection, including device type, operating system, browser type, IP address, mobile network information, and device identifiers.
• Camera, image, and file access. The App may request access to your device camera, photo library, or files so that you can capture or upload your identification document and selfie. We use that access only for the purpose disclosed when permission is requested, unless we ask for and obtain additional consent.

Location information.

The technologies we use for automatic collection may include:

• Cookies, mobile cookies, and similar technologies. We may use cookies, mobile cookies, local storage, software development kits, or similar technologies to operate and secure the App, remember preferences, and support analytics and App performance.
• Analytics and diagnostics. We may use analytics and diagnostic tools to understand how the App is used, identify errors, maintain security, and improve performance.

Cookies are used for performance tracking. SDKs are used to enable communication between the embedded application and the surrounding webpage, including to support handover eCREDIT, IDENTITY VERIFICATION, AND FRAUD PREVENTIONxchange. We may use pixels, and similar technologies, including through advertising partners, to track your activity across our Site, our App, and unrelated third-party sites and apps, and to build a profile of your interests for targeted or interest-based advertising ("behavioural advertising"). We may share device and advertising identifiers, hashed contact information, and interaction data with advertising partners for this purpose, and they may combine it with information they collect elsewhere. You can opt out of this tracking and profiling through your browser or device settings, an in-app ad-preference control, or industry opt-out tools. If you are a resident of Quebec, this technology allows you to be identified, located, or profiled within the meaning of the Act respecting the protection of personal information in the private sector, and we will inform you of that use and the means available to activate or deactivate it at or before the time of collection.

If you are a resident of Quebec and we use technology that includes functions allowing you to be identified, located, or profiled (for example, to assess your economic situation for credit purposes, or to track how you interact with the App for analytics or advertising), we will inform you of the use of that technology at or before the time of collection, together with the means available to you to activate or deactivate those functions.
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If you are a resident of Quebec and the App offers you privacy settings, those settings are configured by default to provide the highest level of confidentiality, without any action required on your part. This does not apply to privacy settings for browser cookies.

HOW WE USE YOUR INFORMATION

We use personal information that we collect or receive, including for the following purposes:

• To provide, operate, maintain, troubleshoot, secure, and improve the App and related services.
• To create, receive, assess, process, approve, decline, and administer your financing application and any resulting financing account.
• To verify your identity, confirm the authenticity and validity of identification documents, match your selfie to your identification document, and prevent, detect, investigate, and address fraud or unauthorized activity.
• To obtain credit reports, credit scores, and related credit information from credit bureaus and to assess creditworthiness, credit risk, and financing eligibility.
• To complete your device purchase from a telecom carrier, support activation of wireless service, administer financing for your device, and coordinate customer service or account administration relating to those activities.
• To process, manage, and verify payments or repayment methods, including through debit card information you provide.
• To communicate with you about your application, financing, payments, App use, customer support requests, policy updates, and other service-related matters.
• To report loan, repayment, account status, and late payment information to credit bureaus, where permitted by law and applicable credit reporting rules.
• To comply with legal, regulatory, accounting, audit, security, and risk management obligations, and to enforce our rights and agreements.
• To generate aggregated, de-identified, or anonymized information for analytics, reporting, App improvement, risk management, and other lawful business purposes. If you are a resident of Quebec, de-identified information remains personal information and continues to be governed by this policy.
• For any other purpose disclosed to you at or before the time of collection, or for any other purpose with your consent or as otherwise permitted or required by law.
• If you are a resident of Quebec, we rely on your consent to collect, use, and disclose your personal information, except where the law permits or requires us to do so without your consent. Your consent must be clear, free, and informed, and is requested for specific purposes. We ask for your consent for each such purpose in clear and simple language and, where we request it in writing, separately from any other information we provide to you. We do not rely on implied consent for residents of Quebec, and your consent is valid only for as long as it is needed to achieve the purposes for which it was requested. Where we collect or use sensitive personal information about you, such as your social insurance number or credit and income information, we obtain your express consent for that purpose.

CREDIT, IDENTITY VERIFICATION, AND FRAUD PREVENTION

Glow uses identity verification, fraud prevention, and credit assessment processes to determine whether we can offer financing and to protect you, Glow, telecom carriers, credit bureaus, and other parties from fraud, identity theft, credit risk, and unauthorized activity.

• We share personal information with IDVerse so IDVerse can verify your identity, authenticate identification documents, compare your selfie with your identification document, and help prevent fraud. In certain cases, including for fraud prevention, we may also share relevant information with your telecom carrier.
• IDVerse temporarily processes biometric data, including to perform the facial comparison. We do not receive or retain such biometric data. IDVerse deletes the biometric data within seven days.
• Where applicable, IDVerse keeps a copy of your identification document and selfie in its secure systems. We also keep copies of the same in our own secure systems.
• We share personal information with credit bureaus and obtain information from credit bureaus, including credit score information, for identity verification, fraud prevention, credit assessment, account administration, and credit risk management.
• If you are a resident of Quebec and we consult a credit report or recommendation about you from a credit bureau in connection with your financing application, we will inform you of your rights of access to, and rectification of, the personal information held about you by that credit bureau, and of the manner in which and the place where you may exercise those rights. On request, we will disclose to you the content of any credit report or recommendation we consulted to make a decision about you, and, if we decline your application or offer you less advantageous terms based on that consultation, we will inform you of that fact.
• If you receive financing, we may report information about your loan to credit bureaus, including account status, repayment history, and late or missed payments.
• Late or missed payments, defaults, or other negative account information may negatively affect your credit score and credit history.
• Where we ask for your social insurance number, we use it only for identity verification, credit assessment, fraud prevention, and other purposes disclosed at the time of collection or permitted by law. Your social insurance number and government identification information may be shared with your telecom carrier for administrative purposes, including to establish and manage your billing account.
• We may share driver's license information with the provincial or territorial authority that issued the driver's license to verify the driver's license and confirm the identity information associated with it.
• We may use automated or manual review processes to assist with application review, identity verification, fraud prevention, and credit risk assessment.
• If you are a resident of Quebec and we make a decision about your financing application, such as an approval or a decline, based exclusively on the automated processing of your personal information, we will inform you of that fact no later than at the time we notify you of the decision. On request, we will inform you of the personal information used to make the decision, the reasons and the principal factors and parameters that led to it, and your right to have that personal information corrected. You may also submit observations to a member of our personnel who has the authority to review the decision.

DISCLOSURE OF YOUR INFORMATION

In certain circumstances, we may disclose personal information to your telecom carrier, including but not limited to:

• Application and financing status. We may share information about your device financing application and, if approved, the ongoing status of your financing, such as whether it is active, up to date, in arrears, settled, or closed.
• Declined applications. If your application is not approved, we may tell your telecom carrier that it was declined and provide a general reason, such as an identity verification failure, failure to meet our eligibility or affordability criteria, or a fraud-related concern.
• Billing account setup. We may share your social insurance number and driver’s licence number where required to establish or administer your telecom billing account.
• Credit assessment and reconciliation. We may share selctive information relating to our credit assessment, including your applicable credit band or tier, where required to reconcile payments between us and your telecom carrier.
• Other information. We may also share other personal information with your telecom carrier where reasonably necessary in connection with your telecom relationship, our financing services, or the administration and servicing of accounts between us and your telecom carrier.

We may disclose aggregated or anonymized information that no longer constitutes personal information, where permitted by law. If you are a resident of Quebec, de-identified information remains personal information under the Quebec Privacy Act, and we disclose it only as permitted or required by that Act.

We may disclose personal information that we collect or receive as described in this policy, including to the following recipients and for the following purposes:

• IDVerse. We disclose personal information to IDVerse, including for identity verification, document authentication, selfie comparison, liveness or fraud checks, and fraud prevention.
• Credit bureaus. We disclose personal information to credit bureaus and obtain information from credit bureaus, including to verify identity, assess creditworthiness, evaluate and administer financing, report loan status, and report late or missed payments.
• Telecom Carriers. We disclose personal information to the relevant telecom carriers, including financial approval status, funding status, identity document information, social insurance number where applicable, identity verification status, and other information needed to complete your device purchase, activate wireless service, administer your financing, and provide related customer or account support.
• Provincial or territorial issuing authorities. We may disclose driver's license information to the provincial or territorial authority that issued the driver's license for verification purposes.
• Payment processors, card networks, banks, and financing administration providers. We may disclose debit card and payment-related information, including to process payments, manage repayment methods, administer financing, prevent fraud, and comply with payment-network requirements.
• Service providers. We may disclose personal information to contractors, service providers, and other third parties that support the App, including hosting, cloud storage, customer support, communications, analytics, security, fraud prevention, compliance, payment processing, and business operations.
• Affiliates and business transaction parties. We may disclose personal information to our affiliates and to a buyer or other successor, including in connection with a merger, acquisition, financing, reorganization, restructuring, sale of assets, bankruptcy, or similar transaction involving Glow, where permitted by law.
• Legal, regulatory, and safety recipients. We may disclose personal information to comply with a court order, law, legal process, government or regulatory request, credit reporting rules, audit or accounting obligations, or to protect the rights, property, security, or safety of Glow, users, telecom carriers, credit bureaus, service providers, or others.
• Other recipients with consent. We may disclose personal information for any other purpose we disclose when you provide the information, with your consent, or as otherwise permitted or required by law.

TRANSFERRING YOUR PERSONAL INFORMATION

We may process, store, transfer, or access personal information outside the province or territory in which it was collected, including in the United States and other jurisdictions where Glow, our affiliates, or our service providers operate.
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Personal information processed or stored outside your province, territory, or Canada may be subject to the laws of those jurisdictions and may be accessible to courts, law enforcement, national security authorities, or regulators in those jurisdictions. Those jurisdictions may have privacy laws that may or may not be as comprehensive as Canadian law. When we engage service providers, we seek to arrange appropriate privacy, security, and data protection requirements, taking into account the nature of the services and the provider’s role. In some cases, including where a third party determines its own purposes and means of processing, that party may be subject to its own privacy obligations and terms rather than ours.
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If you are a resident of Quebec, before we communicate your personal information outside Quebec, we conduct a privacy impact assessment that takes into account the sensitivity of the information, the purposes for which it is to be used, the protection measures (including contractual measures) that would apply to it, and the legal framework applicable in the jurisdiction in which the information would be communicated. We communicate the information outside Quebec only where the assessment establishes that it would receive adequate protection, and each such communication is governed by a written agreement that reflects the results of the assessment and, where applicable, the measures agreed to in order to mitigate the risks identified.
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When we use service providers to process personal information, we use contractual and other measures designed to protect personal information and require service providers to use personal information only for the purposes for which we disclose it to them or as otherwise permitted by law.
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You may contact us using the contact information below to obtain information about our policies and practices regarding service providers outside Canada.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to give you meaningful information about our privacy practices so you can make informed choices about whether to provide personal information and how we use and disclose it.
 

• Optional social insurance number. If you have a driver's license and we ask you to provide a social insurance number on an optional basis, you may choose not to provide it, and we will use other information to process your application where available.
• Required information. Some information is required to verify your identity, assess eligibility, prevent fraud, complete the device purchase, activate wireless service, process payments, and administer financing. If you do not provide required information, we may be unable to process your application or provide the App's services.
• Device permissions. You may use your device settings to manage camera, photo, file, notification, and other App permissions. If you disable permissions needed for identity verification or App functionality, some features may not be available.
• Marketing communications. We may use your contact and relationship information to send you marketing about our or your telecom carrier’s products, services, offers, and promotions, including joint marketing. Where required by law, we will obtain consent, and you may unsubscribe at any time without affecting service or account communications.
• Tracking, analytics, and advertising. See the Cookie Policy for more information.
• Credit reporting. You may have rights under applicable credit reporting laws to request access to or correction of information in your credit file by contacting TransUnion, or the relevant credit bureau.

DATA SECURITY

We use physical, organizational, contractual, and technological safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, modification, and disposal.
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You are responsible for maintaining the security of your device, login credentials, and any information you submit through the App. Please do not share credentials or leave your device unsecured.
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No method of transmission over the Internet or mobile networks, or method of electronic storage, is completely secure. Although we use safeguards designed to protect personal information, we cannot guarantee absolute security.

CONFIDENTIALITY INCIDENTS

If we have reason to believe that a confidentiality incident involving your personal information has occurred, meaning access to, or the use or communication of, personal information that is not authorized by law, or the loss of personal information or any other breach in its protection, we will take reasonable measures to reduce the risk of injury and to prevent new incidents of the same nature from occurring.
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Where a breach of personal information creates a real risk of significant harm, we will notify affected individuals and applicable privacy regulators as required by law, taking into account the sensitivity of the information and the likelihood and potential consequences of misuse. If you are a resident of Quebec, that regulator is the Commission d'accès à l'information du Québec (the "CAI"), and we maintain a register of confidentiality incidents that we will provide to the CAI on request.

DATA RETENTION

Except as otherwise permitted or required by applicable law, we retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including identity verification, fraud prevention, financing application review, loan administration, payment processing, customer service, dispute resolution, legal, accounting, audit, regulatory, and reporting requirements. IDVerse deletes biometric data used for identity matching within seven days and retains other identity verification information for up to 12 months, while we separately retain relevant records in our own secure systems in accordance with our applicable retention requirements.
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If you are a resident of Quebec, we maintain governance policies and practices for the protection of personal information that are proportionate to the nature and scope of our activities. These policies and practices govern the retention and destruction of personal information, describe the roles and responsibilities of our personnel throughout the life cycle of that information, and establish a process for dealing with complaints about our handling of personal information. They are approved by our person in charge of the protection of personal information (identified in the Contact Information section below), and detailed information about them is available on our website and within the App.

AGE ELIGIBILITY

The App is intended only for individuals who are legally eligible to apply for financing and enter into related agreements in their province or territory of residence and who are at least 19 years of age if resident in British Columbia, New Brunswick, Newfoundland and Labrador, Nova Scotia, the Northwest Territories, Nunavut, or Yukon, and at least 18 years of age if resident elsewhere in Canada. We do not knowingly collect personal information from individuals who are not eligible to use the App, including persons who are under the age of 19 in British Columbia, New Brunswick, Newfoundland and Labrador, Nova Scotia, the Northwest Territories, Nunavut, or Yukon, or under the age of 18 elsewhere in Canada.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate, complete, and current. Please keep us informed if your information changes. You can view your personal information in the Customer Hub.

Subject to applicable law, you may request access to the personal information we hold about you and request correction of inaccurate or incomplete personal information.

You may make an access or correction request by contacting heretohelp@ca.glowcustomerhub.com, with copy to:
ca-compliance@glowgfs.com. This inbox reaches our Privacy Officer, the person in charge of the protection of personal information.
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We may ask you for information to verify your identity before responding to an access or correction request. We will respond within 30 days of receiving your request and will explain if we cannot provide access to or correct certain information, subject to legal or regulatory restrictions.
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If you believe information in your credit file is inaccurate, you may also need to contact TransUnion, or the relevant credit bureau directly.
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If you are a resident of Quebec, we provide access to your personal information free of charge. Where applicable law permits, we may charge a reasonable fee for transcribing, reproducing, or transmitting the information, in which case we will inform you of the approximate amount of the fee before proceeding. If we refuse an access or correction request, in whole or in part, we will give you written reasons for the refusal, indicate the provision of law on which it is based, and inform you of the recourses available to you and the time limit for exercising them.
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If you are a resident of Quebec, you may also ask us to provide the computerized personal information you have provided to us, other than information we have created or inferred about you, in a structured, commonly used technological format. On request, and unless doing so raises serious practical difficulties, we will provide that information to you or communicate it to any person or body authorized by law to collect it.

WITHDRAWING YOUR CONSENT

Where we rely on consent to collect, use, or disclose personal information, you may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw consent, contact our compliance officer at heretohelp@ca.glowcustomerhub.com. If you withdraw consent, we may not be able to process your application, provide financing, administer your financing, report to credit bureaus, process payments, or provide some or all App services; we will explain the consequences of withdrawal when you contact us.

CHANGES TO OUR PRIVACY POLICY

We may update this privacy policy from time to time. If we make material changes to how we collect, use, disclose, retain, or transfer personal information, we will provide notice as required by applicable law and, where required, seek your consent before using or disclosing personal information for a new purpose.

The date this privacy policy was last revised appears at the top of the policy. You are responsible for ensuring that we have an up-to-date, active, and deliverable email address and mobile number for you, and for reviewing this policy periodically.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome questions, comments, requests, and complaints regarding this privacy policy, our privacy practices, and our compliance with applicable privacy laws. You may contact us at:
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Attention: Privacy Officer, Glow Financial Services Canada Corp
Mailing address: 600-1741 Lower Water Street, Halifax, Nova Scotia B3J 0J2
Email: ca-compliance@glowgfs.com; with copy to dataprotection@glowgfs.com
Telephone: 514-400-6253
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If you are a resident of Quebec, the individual identified above as our compliance officer is the person in charge of the protection of personal information for the purposes of the Quebec Privacy Act, and that person's title and contact information are published on our website.

If you are a resident of Quebec, in accordance with the Charter of the French Language, you are entitled to receive this privacy policy in French; you may agree to receive it in another language only after we have made the French version available to you.
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We have procedures to receive and respond to complaints and inquiries about our handling of personal information. If you are not satisfied with our response, you may have the right to contact the Office of the Privacy Commissioner of Canada or another applicable privacy regulator. If you are a resident of Quebec, you may also file a complaint with the CAI.