Privacy Policy

Privacy Policy – Highlights

CHEQUE SOURCE INC. and its corporate affiliates (“Cheque Source”, “we”, “us”, “our”) understand that your time is valuable. Therefore, we have set out below some important highlights of our Privacy Policy. You can obtain more information about how we collect, use, disclose and protect your member’s / client’s personal information (“Member/Client Information”) by reviewing our full Privacy Policy below.

What Member/Client Information do we collect?

• We may collect Member/Client Information directly from you as the financial institution being a user of our application for cheque printing (the “Sites”).
• By using our Sites, software, or services, you are choosing to provide us with Member/Client Information, and you acknowledge and consent to the processing of the Member/Client Information in Canada.

Why do we collect Member/Client Information and how is it used?

• We collect Member/Client Information to facilitate the use of our Sites, software and services.
• The Member/Client Information that we collect about devices and the use of our Sites is used in an aggregate and de-identified form to evaluate and improve our services.
• We will not use the Member/Client Information for any purpose other than what is explicitly required to perform our services. We do not engage in secondary uses such as marketing, data analytics, or any unrelated services.

Is Member/Client Information shared or disclosed?

• Member/Client Information provided to us is never sold or rented to other organizations.
• We may also disclose or share Member/Client Information for fraud prevention, and other permitted disclosures under applicable law.

How do we protect Member/Client Information?

• We have implemented safeguards to protect Member/Client Information under our control, and regularly review our practices to ensure they align with reasonable practices appropriate to the level of sensitivity of the information, in order to safeguard Member/Client Information against loss or theft, unauthorized access, alteration or disclosure.

What are the risks?

• Although we take steps to safeguard the Member/Client Information under our control, “perfect security” does not exist online or elsewhere. In particular, we cannot guarantee the security of information posted or transmitted using our Sites or via email. It is possible that third parties may unlawfully intercept or access such information.

What are your choices?

• You may request access to and review of the Member/Client Information in our possession, subject to certain limitations.
• You may also request that we change or delete the Member/Client Information in our possession. We will always work hard to comply with such requests, subject to certain limitations.
• You may withdraw your consent to our use of the Member/Client Information at any time provided you also cease using the Sites at the same time.

What else should you know?

• We may amend our Privacy Policy from time-to-time. Although we will try to notify you of major changes by posting updates on our webpage or on the Sites itself, we encourage you to check for updates.
• You can contact us with questions, complaints or to access the Member/Client Information.

Mobile App Privacy Policy

CHEQUE SOURCE INC. and its corporate affiliates (“Cheque Source”, “we”, “us”, “our”) respect and uphold individual rights to privacy and the protection of Member/Client Information while balancing such rights with our need to process the Member/Client Information to manage our business and deliver our services to you. Based on applicable privacy and data protection principles common to Canada and other jurisdictions to which we are subject, we have developed this privacy policy (the “Policy”) to explain our practices for processing the Member/Client Information. This Policy does not apply to our employees’ personal information or any anonymized information.

This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct, update and access the Member/Client Information that you provide as a user of (a) our cheque printing services (the “Sites”), (b) any front-end software we provide you that interacts or interfaces with the Sites (the “Software”), and (c) the services we provide through the Sites and/or the Software (collectively, the “Service”).

Our Sites and Software may contain links to other apps, websites or Internet resources which are provided solely for your convenience and information. When you click on one of those links, you are contacting another Internet resource. We have no responsibility or liability for, or control over, those other Internet resources or their collection, use and disclosure of the Member/Client Information. We encourage you to read the privacy policies of those other Internet resources to learn how they collect and use the Member/Client Information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By using our Sites, Software, or Service, or otherwise by choosing to provide us with the Member/Client Information, you acknowledge and consent to the processing of the Member/Client Information in Canada in accordance with this Policy and as may be further identified when the Member/Client Information is collected.

If you are located or residing outside of Canada, please be aware that our Sites, Software and Service are intended for and directed to users in Canada, and the privacy laws and principles in Canada may differ and not offer the same level of protection as those in your location or residing country/region. Through your continued use of our Sites, Software or Service, you are transferring the Member/Client Information to Canada and you expressly consent to that transfer. We will use this consent as the legal basis for such data transfer, unless otherwise stated in this Policy.

If you do not consent to the processing of the Member/Client Information in accordance with this Policy, please do not access or continue to use any of the Sites, Software or Service or otherwise provide any of the Member/Client Information to us.

1. Member/Client Information

For the purposes of this Policy, “Member/Client Information” means any identifiable information about an individual member/client of yours, including but not limited to an individual’s name, home address, telephone number, email address, and bank account, except any other information otherwise exempted by the applicable laws of Canada and other jurisdictions.

For example, in Canada, the Member/Client Information does not include any business contact information that is processed solely to communicate with that member/client about their employment or profession.

When you use our Sites, Software or Service, we may collect the following Member/Client Information from you:

• Demographic information such as location of residence (city/province/country);
• Contact information such as name, email address, mailing address, and phone number;
• Billing information as appropriate such as credit card number, bank account number and billing address;
• Unique identifiers such as profile photo and/or video, username, account number, and password;
• Technical information such as authentication information, device MAC address information, device and mobile phone IP and IMEI address information, and browser and log information.

The Member/Client Information may be collected when you request cheque printing services from us.

We only collect the Member/Client Information that we need. We encourage you to not provide us with any information about your member/client beyond what is necessary and as requested by us.

Information about Minors

This Site is intended solely for users who are not minors (13 years of age or older). We do not knowingly collect the Member/Client Information about any minor. No such minor, nor any parent or guardian as it relates to such minor, should submit such minor’s information to us through the Sites, Software or otherwise for any reason and under any circumstances.

2. Purpose for Which Member/Client Information is Processed

We may process the Member/Client Information for the following purposes (the “Purposes”):

• Cheque printing and related financial processing services;
• Supporting and enhancing the software’s functionality for the benefit you and your clients;
• To verify and authenticate your member’s/client’s identity;
• To ensure that the Sites, Software or Service is optimized for your use and benefit;
• To operate, maintain and provide to you the Service, features and functionality of the Sites or Software;
• To communicate with your clients regarding reports that include data for billing purposes;
• To carry out our obligations arising from any contracts entered into between you and us;
• To comply with internal policies and procedures and other legal, accounting, or security requirements.

We will only process the Member/Client Information for the Purposes for which we intend to process such information. Otherwise, we will not process the Member/Client Information.

3. Disclosure of The Member/Client Information

We may disclose the Member/Client Information for the Purposes as described in this Policy in the following ways:

• To our employees and contractors;
• To our business partners; and
• To law enforcement, government or regulatory bodies, or other lawful authorities.

4. Legal Basis for Processing The Member/Client Information

Consent

We will process the Member/Client Information only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested.

Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your member’s / client’s address through a form or email seeking information and we use those means to respond to your request.

Taking into account the sensitivity of the Member/Client Information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the Member/Client Information being processed. By using our Sites, Software, or Service, or otherwise by choosing to provide us with the Member/Client Information, you acknowledge and consent to the processing of the Member/Client Information in accordance with this Policy and as may be further identified when the Member/Client Information is collected. When we process the Member/Client Information for a new purpose, we will document that new purpose and ask for your consent again.

If you do not consent to the processing of the Member/Client Information in accordance with this Policy, please do not access or continue to use any of the Sites, Software or Service or otherwise provide any of the Member/Client Information.

You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of the Member/Client Information without penalty, subject to legal or contractual restrictions and reasonable notice by (i) changing your privacy preferences through the Sites or Software, or (ii) deleting your account with the Sites or Software and stopping use of the Sites or Software. However, if you withdraw or change your consent, we may not be able to provide you with the Service through the Sites or Software.

Other Legal Bases

Aside from consent, we may also process the Member/Client Information under other legal bases, as permitted by the applicable laws.

5. Security of Member/Client Information

The security of the Member/Client Information is important to us. We protect the Member/Client Information using physical, technological and organizational safeguards including but not limited to the following:

• Encryption of data in transit;
• Secure access controls to the software; and
• Regular software security updates to address any vulnerabilities.

We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity to safeguard the Member/Client Information against loss or theft, unauthorized access, alteration or disclosure.

However, no method of transmission over the Internet, or method of electronic storage, is completely secure; as such, despite our safeguards and protocols, we cannot fully guarantee the security of the Member/Client Information. You should always exercise caution when disclosing the Member/Client Information over the Internet.

6. Requests for Access to and Correction of Member/Client Information

Applicable privacy laws allow, to varying degrees, individuals the right to access and/or request the correction of errors or omissions in the Member/Client Information that is in our custody or under our control. You may request access to and review of the Member/Client Information in our possession. However, access may be declined where permitted or required by applicable law.

You may request that we change or delete the Member/Client Information in our possession. We reserve the right not to change the Member/Client Information if we do not agree that it is inaccurate or outdated, but will append any alternative text the individual concerned believes appropriate.

If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

7. CASL Policy

We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication we send to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL.

In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.

In addition to adopting and updating this Policy, we undertake various transparency initiatives to ensure we comply with CASL, which include:

• Consent — we do not send you CEMs without your consent. This consent typically must be “express” but in certain circumstances can be “implied” or specifically exempt from consent requirements.
• Content — we adopted processes to ensure that our CEMs identify ourselves as the sender, provide contact information, and include a clear, working unsubscribe mechanism or preference centre.
• Clarity — we ensured that each aspect of a CEM, including its header, content, or any links or URLs, conveys the appropriate information so that you always know what you are clicking on.

If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated in Section 10 below.

8. Retention of Your Member/Client Information

We generally keep the Member/Client Information for only as long as it is needed to accomplish the purposes for which it was collected, or as needed for authorized or legitimate purposes. More specifically, we retain the Member/Client Information as long as necessary for the fulfillment of the identified purposes for its collection or as otherwise necessary to comply with applicable laws or protect our interests.

When the Member/Client Information is no longer necessary or relevant for the identified purposes, or is required to be retained by applicable laws, we will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. We use reasonable industry practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to the Member/Client Information.

9. Updates or Changes to this Policy

This Policy was last updated in 2026. We will occasionally update this Policy and revise the “last updated” date appearing in this paragraph.

If we make any material changes we will either (a) notify you by email, or (b) provide a notice on the Sites or otherwise through the Service before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that this Policy is posted or on the date as specified in the notification. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this Policy.