Privacy Policy

Latest Update: June 26, 2024

We are Trampoline Technology Inc. (“Trampoline”, “we”, or “us”)!

It’s important for us that you trust how we handle your personal information when you use our Services (as defined hereinafter). This is why this Privacy Policy (the “Policy”) provides you with the information that you need to understand how we collect, use and disclose your personal information when you use the Services.

Please review carefully this Policy. By using our Services (as defined hereinafter), you consent to the collection, use and disclosure of your personal information, as precisely set out in this Policy, and as revised from time to time.

Our mission is to simplify your finances and we want to make sure that you fully trust us in offering you the best experience to do so. We use industry-leading practices to protect your privacy, which is extremely important to us.

Privacy Program

In order to protect your personal information, we have put in place policies, practices and procedures relating to the management of the personal information we hold.

These internal policies and procedures govern the collection, use, disclosure, retention and destruction of personal information, as well as complaint handling, information security and data governance at Trampoline. They also provide the framework for the implementation of Privacy Impact Assessments, where required, as well as the prevention of and response to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer.
The collection of your personal information through our Services complies with the requirements of this program.

Privacy Officer

Our senior executives have delegated the management of the privacy program to the Privacy Officer. His duties consist of managing and monitoring Trampoline's internal privacy program.

It is the Privacy Officer who approves and implements privacy policies and procedures, ensures their proper functioning and reports to Trampoline senior management on the effectiveness of the program.
It is also the responsibility of the Privacy Officer to provide you with the necessary support in the event of a question, complaint or request relating to the protection of personal information:

Trampoline - Attention: Privacy Officer
403-1085 rue Saint-Alexandre
Montreal (Québec) H2Z 1P4
Canada
legal@trampoline.cx

We are committed to responding promptly to your requests.

Upon receipt of a complaint, the Privacy Officer will conduct an investigation. If the complaint is justified, the situation will be corrected. Regardless of our conclusion, we will keep you informed.

When does this Privacy Policy apply and what does it cover?

This Policy contains information about how we collect, use and disclose your personal information when you are:

Navigating our public websites such as www.trampoline.cx and www.bounce.cx (the “Websites”);
Using our web application named Bounce made available to you at app.bounce.cx, and the associated services (the “WebApp”)
Using our mobile application named Bounce (together with the WebApp, the “App”); and
Exchanging with us by e-mails, social media or otherwise.

In this Policy, we use the term “Services” to refer to all of the above, and where there is no distinction to make between the different aspects of the Services.

The term “App User” refers to someone who uses our App.

By comparison, the term “Website User” refers to someone who is navigating our Websites, or is interacting with us by e-mails, social media or otherwise. The term “User” or “you” refers indistinctively to an App User or a Website User. A User can be both an App User and a Website User.

This Policy also covers our use of tracking technologies such as cookies (as defined hereinafter). For more information about what we mean by “cookies” and what we do with it, please click here.

In addition, this Policy covers the use of your personal information for interest-based advertising. For more information about this topic, please .We do not conduct interest-based advertising within our Websites or as part of our Services. We only conduct interest-based advertising through our App and social media.

As a participant of the Digital Advertising Alliance (“DAA”), we adhere to DAA’s interest-based advertising principles by providing you with an enhanced notice, transparency and control of our digital marketing practices as stated at http://www.aboutads.info/principles. This Policy does not apply to third-party content accessible through the Services, or to the use of a third party for the purpose of connecting to the Service, as applicable. The App also allows connection to third-party services through application program interfaces. These third-party services are integration partners. You must have your own subscription with them, and they are not our service providers. These third parties collect, use and disclose personal information in accordance with their respective privacy policies. We invite you to consult these policies carefully.

1. What do we mean by “personal information”?

Personal information is information that relates to a natural person or allows for the identification of a natural person. Some information may not be personal on its own, but may become personal information if associated with personal information or if the sum of the information allows us to identify you. For the purpose of this Policy, we consider that cookies are personal information, regardless of applicable laws.

The definition of what constitutes personal information is subject to the laws applicable in your jurisdiction, and this Policy shall be interpreted in accordance with applicable laws.

For the purposes of this Policy, personal information means any information about an identifiable individual, including any information that directly or indirectly identifies such individual.

2. Basis for processing personal information

Trampoline needs to collect and process some of your personal information in order for you to use our Services.

When we collect your personal information, we ensure that we collect only the information necessary to fulfill one of our purposes, which has been previously disclosed to you, for example, in this Policy. We use personal information in accordance with the privacy laws applicable to our business.

The following is a description of the basis on which Trampoline collects and processes your personal information:

Your consent

As required by applicable privacy legislation, Trampoline collects the majority of your personal information on the basis of your voluntary consent, favouring collection directly from you.

Other permissible legal basis, such as the performance of our contracts

As permitted by applicable privacy laws, Trampoline may collect personal information without your express consent, for example, to comply with obligations under applicable laws or to fulfill our contracts.

3. What types of personal information do we collect, and why

We collect personal information to provide you with our Services, for the purpose of obtaining analytics on your use of our Services, or in connection with our marketing activities.

Services

Electronic Data

IP address, mobile identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and language.
This information is collected automatically by our Services to function effectively, to fix bugs, or to improve the security of our Services. We also use this information for analytics purposes to help know more about your use of our Services. These may be collected as part of cookies.

Usage Data

Time spent on the Services, pages visited, links clicked, language preferences, pages that led or referred you to the Website.
We collect this information for analytics purposes.

Communication Data

Email addresses, identification data, publicly available information, emails content.
If you communicate with us by email, on social media, by subscribing to our services-related news communications on our Websites, or by any other means, we collect the personal information that you share with us, such as your email address and the content of your communication. If you communicate with us using social media, we will have access to your publicly available information.

App

Registration Data

First name, last name, e-mail address, personal identification number, username and password.
We collect this information to create App Users’ account on our App.

All financial account integrations are done through our trusted service provider, Plaid (Visa). This means that our servers can never see, nor store, any of your banking credentials and identifiers. Click here to have more information about our third-party service providers.

We also use your email address to communicate with you about the App, such as for updates or maintenance.

User Data

Personal notes on your transactions.
We collect this information to :

(a) provide App Users with the functionalities of the App, such as performing research through transactions, based on personal notes attached to it ;
(b) to allow App Users to use aggregated data, reports and past data about their financial information.

Location Data

Geolocation based on IP addresses.
Geolocation is collected as part of IP addresses. This allows us to know on a high-level where in the world you are located so that we can tune up our Services accordingly. It does not allow us to track you, to follow you or to know where you live, for instance.

Financial Information (provided by third parties)

Financial information.
When you connect your banking or financial accounts through our trusted third-party service providers, we receive from them some of your financial information, such as your account balance, expenses and daily transactions, in order to provide the Services to you. Click here to have more details about our third-party service providers and what information they provide us with.

Support Data

Email addresses, email content, account information, electronic data.
As part of the App, we offer support to App Users. To provide you with support, we collect the personal information included in your inquiries, as well as the personal information required to identify you and help you resolve the issue.

Website and Marketing Activities

Email, Consent to receive emails.
If you consent to receive our communications, we will send you emails about updates and specific app information. You can unsubscribe at any time directly in the emails or by contacting us.

Social Media

Publicly available information.
If you follow us or interact with us on social media, we may process your personal information for marketing or advertising purposes, subject to applicable laws, including those on consent.

Events and academic seminars

Business contact information, registration information.
If we interact with you as part of events or tradeshows, we may collect your contact information. If you register for our academic seminars or any other training sessions, we will collect personal information to register you.

4. What cookies do you use and why?

Cookies are messages that web services pass to your web browser when you navigate the Internet. Your browser stores each of these messages in a small file. Our definition of cookies also includes similar technologies, like pixel and web beacons that are installed on your devices. Cookies can track you across different websites, and serve different purposes. There are various types of cookies: (1) essential; (2) functional; (3) marketing and (4) analytics.

We use cookies for our Services to function as intended, to conduct marketing, to provide functionalities on our App, to analyze our performance and to improve our Services’ security. Cookies are also useful to identify bugs and errors. We use both first-party and third-party cookies installed by partners on our Website.

There are different types of cookies. We use both first party and third party cookies:

First party

First party cookies are those that are issued by us, and they can only be set or retrieved by us. They are used for purposes specific to us, such as to personalize the website.

Third party

Third party cookies are placed on our Websites or Apps by other entities, such as to create new functionalities or conduct advertising.
Cookies can also be categorized based on their roles. We collect cookies that classify in each of these categories:

Essential

Essential cookies are necessary to operate the core functions of our Services. These include login cookies, session ID cookies, language cookies as well as security cookies.

Functional

Functional cookies are used to provide you with some functionalities and to remember preferences, consents and configurations.

Analytics

Analytics cookies are used to generate aggregated statistical data about the traffic and behaviour of Users when using our Services. For instance, we can determine how much time Users spend on a page, and how successful our advertisings are.

Marketing

Marketing cookies are used to deliver relevant advertisings which requires tracking and analyzing users’ behaviour across websites. Cookies help us to do so through our partners, as Facebook and LinkedIn.

5. Do you use Google Analytics?

Yes. We use Google Analytics as part of Analytics cookies on our Websites. Google Analytics is Google’s analytical tool that helps us to understand how Users engage with our Websites. The information we collect through Google Analytics is page views, time spent through the Services, number of visitors, the source where they come from, the pages they have visited, session and Websites usage, the whole in an anonymous form. It uses a set of cookies to collect such information and report site usage statistics without allowing us to identify individual visitors.

6. Do you conduct interest-based advertising (IBA)?

Yes. We use targeting cookies as part of our marketing strategy. This is called interest-based advertising, which is also referred to as targeted advertising or behavioural advertising. Re-targeting means that the ads that you are being served are personalized based on your behaviour when browsing online. This is enabled through cookies and requires the processing of electronic data that is considered personal information under certain laws.[A1] (#_msocom_1)

We do not conduct interest-based advertising within our Website or as part of our Services or using Users’ data when they are within the Website or using the Services. We only conduct interest-based advertising through our App and social media.

We collect your Mobile Advertising ID (also called Identifier for Advertisers in iOS operating systems and Android Advertising ID in Android operating systems). A Mobile Advertising ID is a user-resettable ID assigned to a specific device that enables us to associate activity on a device to that specific device and to track usage of applications. The tool lets us convert your email address to a unique number that advertisers use to match to unique numbers it generates from email addresses of its users as part of real-time bidding.

If you are not comfortable with this, you can opt-out of interest-based advertising by managing your cookies and other tracking technologies. Click here to jump to the section of the Policy that explains to you how to do this. You can also use WebChoices which is a browser-based tool for opting out of interest-based advertising. Mobile users can also download the DAA Choice App in the Apple App Store, Google PlayStore or Amazon Store. AdChoices provides additional solutions and explanations to control block and control cookies, as well as plug-ins to retain opt-out cookie preferences, even if you delete your cookies.

7. To whom do you disclose my personal information to?

We do not sell your personal information to third parties. However, we do share your personal information with certain types of third parties to provide you with the Services, conduct marketing and as required by the law. We can also share your personal information in the context of a merger and acquisition, as part of bankruptcy procedures or for other corporate requirements.

Service Providers

Service providers are used to providing you with some functionalities that are outsourced to third parties. For instance, we use Elastic Cloud to offer App Users a search tool within the App, and others to provide support to App Users and to send you emails (click here to jump to its privacy statement).

We also use service providers to (1) log you into your banking and financial accounts to connect such accounts, and then (2) receive and synchronize your banking and financial information contained therein, the whole in order to provide our Services to you. These service providers include Plaid (click here to jump to its privacy statement).

IT Service Providers

We use IT Service Providers to offer you the Services, such as AWS to host the Services and your personal information (click here to jump to their privacy policy). For instance, we also use Sentry for crash reporting (click here to jump to their privacy policy) and Sardine for risk analysis and fraud prevention (click here to jump to their privacy policy).

Marketing Partners

We use marketing partners to (1) serve you relevant ads; (2) analyze our advertising campaigns performance; (3) manage our leads and (4) provide you with marketing content. All of these activities require the processing of your personal information, including through cookies. For instance, we use Mixpanel, which is based on generative artificial intelligence, to provide you with personalized marketing content (click here to jump to their privacy policy).

Integration Partners

If you decide to integrate our App with third-party applications, this may require the sharing of personal information with these third parties. Integration partners are not suppliers of us. You are required to enter into distinct agreements with them and review their privacy policy.

Law enforcement and other authorities

We may receive requests by authorities to access your personal information. We will validate that the request is licit before responding. When possible, we will advise you. We will only share what is strictly required to:

Comply with the law;
Comply with the order of a competent judicial authority in any jurisdiction;
Comply with legal proceedings;
Protect and defend the rights or property of Trampoline;
Enforce or verify your compliance with any part of your contracts with us, if applicable;
Prevent fraud or other illegal activity perpetrated through the Service; or

Act in urgent circumstances to protect the personal safety of users of our services or the general public.

We encourage you to review the privacy statements and policies of those third parties so that you can understand how those third parties collect, use and disclose your personal information.

We may share your personal information with our financial and legal advisors or auditors if reasonably required, or in the event we would be required to do so to defend our rights and interests.

In the case of a merger or acquisition, sale of assets, corporate reorganization, bankruptcy filing, insolvency procedures or similar circumstances, your personal information would be considered our assets and property. In these circumstances, ownership of the personal information we collected may be transferred or we may have to share some of your personal information to conclude, negotiate or discuss with third parties. We will only share what we are required to share for these specific purposes.

8. To whom do you disclose my personal information to?

Your personal information may be disclosed and stored outside your province, state, territory or country of residence.

Our business partners and service providers may be located in Canada or other countries. Please be aware that we have contractual agreements with these third parties and suppliers to ensure that your personal information is handled in accordance with the laws applicable to us. Where applicable, we conduct privacy impact assessments prior to any transfer of personal information to another jurisdiction, such as outside Quebec.

9. How long do you retain my personal information?

We will retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, in accordance with our internal document retention policies, to comply with applicable legal, tax or regulatory requirements or until you request us to destroy it. After such period, any personal information concerned and held by Trampoline will be destroyed, deleted or anonymized.

10. How do you keep my personal information secure?

The security of your personal information is a priority for us.

Your personal information is hosted by our service providers who are committed to using reasonable security measures to preserve the integrity and confidentiality of your personal information.

Our employees and suppliers are informed of the confidential nature of the personal information collected and are made aware of the appropriate security measures to prevent unauthorized access to personal information.

We maintain our service and all associated data with technical, administrative and physical safeguards to protect you against loss, unauthorized access, destruction, misuse, alteration and improper disclosure of your personal information. These safeguards vary according to the sensitivity of the data in our possession and are based on the best industry standards. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

If you have any questions about the security of your interaction with us (if, for example, you believe that the security of any account you may have with us has been compromised), you may[A1] (#_msocom_1) contact us.

11. Can I manage my Cookie preferences?

You can always manage your Cookie preferences. However, some functionalities may require Cookies in order to perform as expected, or for security purposes. You can control your Cookie preferences through your browser. Depending on the browser that you are using, different instructions are applicable. Click on your browser for more information:

Google Chrome
Firefox
Safari
Internet Explorer
Opera

12. Do I have any rights regarding my personal information?

Depending on applicable laws, where you live and how you interact with the Site, Application or Platform, you may be granted certain rights with respect to the Personal Information we hold about you.

For example, you may be entitled to:

Obtain access to the personal information we hold about you;
To correct personal information we hold that is inaccurate, misleading or incomplete;
Request the deindexing of your personal information;
To obtain additional information, for example on the categories of third parties to whom we communicate your personal information;
To object to the processing of your personal Information carried out on the basis of our legitimate interests and ask us to restrict the processing of your personal information;
To request the portability of your personal information in a structured, commonly used and machine-readable format;
To withdraw your consent at any time, if we have collected and processed your Personal Information with your consent. Withdrawal of your consent will not affect the lawfulness of the processing we carried out prior to your withdrawal, nor the processing of your personal information carried out on the basis of legitimate processing grounds other than consent;
To refuse promotional communications from Trampoline;
File a complaint with a privacy control authority, such as a privacy commissioner or the Commission d'accès à l'information.

File a complaint

You may file a complaint with Privacy Officer of Trampoline if you are dissatisfied with our handling of your personal information or compliance with this Policy.
You are also entitled by law to lodge a complaint with a privacy commissioner or any other competent supervisory authority for the protection of personal information.

Exercising your rights

You may review, correct, update, modify or delete the personal information you have provided to us using your account. Simply log in to your account and make the changes.
You can also exercise your rights listed above by sending a written request to our Privacy Officer. He will be happy to assist you in any way he can.
For your protection, we will only process requests to exercise your rights from the same e-mail address you use to log in to your account. We may also need to verify your identity before processing your request. Depending on the applicable laws, we will inform you of the procedure to follow, the processing time and the information required, if any. We aim to respond to requests promptly, usually within 30 days.

13. Can we change this Policy?

We revise the Policy from time to time to comply with applicable laws and our operations. If we update this Policy in a material way, we will notify you by sending you a notice either while using our Services or by e-mail. However, in all other circumstances, the posting of a new version of the Policy on our Websites or your continued use of our Services will suffice as notice and consent to the Policy changes.