We're committed to your privacy. Our Privacy Policy is a clear explanation of how we collect, use, disclose, transfer, and store your information.

Welcome to WorkPerks® (the "Program”), owned and operated by Venngo Inc. ("Venngo") and licensed to Morgan Stanley ("Licensee"). In this document Venngo is referred to as "we", "our" or "us". We are committed to protecting your privacy.

In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. By accessing and using the Program you agree to this policy governing your use. If you do not accept this policy, please do not use the Program or provide us with your Personal Information.

Please see below for more information about what Personal Information we collect and why.

COLLECTION OF PERSONAL INFORMATION

We collect, process, and use your information when you:

1. Register for our Program or sign in to an existing account;
2. Visit our website(s);
3. Access our mobile application(s);
4. Connect to our Program using third-party accounts, such as your email, social media, enterprise sign in, or payment account(s);
5. Contact us for support;
6. Participate in our Program;
7. Purchase products or services through our Program;
8. Enter a contest, promotion, survey, or poll;

Further, we and our service providers automatically collect certain information about you through:

1. Interaction with our Program and services;
2. Cookies and other tracking technologies;
3. Location-identifying technologies;
4. Monitoring and analyzing trends, usage, and activities;
5. Information we obtain from service providers related to the Program, including information about qualifying transactions such as merchant name and location, purchase amount, date and time, and applicable payment card network. For clarity, our service provider will not provide us with your 16-digit linked card account number. Please refer to our service provider's privacy policy for details about how your linked card account number is collected, handled, and stored.

The Personal Information you may provide to us includes:

1. First name and last name
2. Email address
3. Address (mailing, billing, and/or shipping address)
4. Payment information (such as payment account name, payment account number, payment card expiration date, and billing address)
5. Your geolocation (GPS)
6. The products or services requested or purchased through the Program;
7. Information you provide in connection with your use or receipt of the services within the Program
8. Connection information including your IP address, unique device identifiers, device or session IDs, and information regarding the network and connected hardware (e.g., computer or mobile device)
9. Browsing, shopping, and purchase history
10. Analytics data (the page-by-page paths you take as you browse through our Program)

USE OF THE INFORMATION WE COLLECT

We, including Licensee, may use your Personal Information for purposes including:

1. To verify your identity and provide you with access to the Program;
2. To create your account for the Program;
3. To customize/personalize your experience with the Program;
4. To identify opportunities for offers and/or rewards;
5. To deliver a product or service offered through the Program;
6. To complete a purchase;
7. To track your purchases;
8. To confirm a qualifying transaction, and facilitate the delivery of rewards or payments to you;
9. To inform you about new features, promotions, special offers, products or services that may be of interest to you. You may opt out of receiving these communications by changing your preferences within your account settings; 
10. To facilitate administrative tasks and/or communicate with you regarding the Program’s operations including technical notices, updates and security alerts and your membership;
11. To notify you regarding any change in services, or continuation of services in the event that our engagement with the LICENSEE ends;
12. To help us improve our services and better understand the current and future needs of our members;
13. To administer contests, surveys, or promotions;
14. To report on Program and offer performance;
15. To create aggregated or non-personalized data for market research and other services;
16. To provide you member services regarding your account and reply to questions, comments, or requests; and
17. To comply with valid requests for information about you from regulators, government agencies, public bodies or other entities who have a right to issue such requests.

RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

SECURITY

We are committed to ensuring the security of your Personal Information. We value your trust in providing us your Personal Information. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the Personal Information and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your Personal Information secure. No method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

We, our outside suppliers and other third parties to whom we disclose information under this policy may perform activities outside of Canada (including, without limitation, the United States). As a result, your information may be securely used, stored, or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries.

SHARING

We may provide third parties with certain aggregated, anonymous data about your use of the Program. It will not include information that could personally identify you. We reserve the right to access and to disclose personal information to comply with applicable laws and lawful government requests, requests by regulatory bodies.

We will not sell, trade, or rent personal information you provide to us. However, in the case of a sale, merger, consolidation, change of control, transfer of assets or reorganization of Venngo, we may transfer, sell or assign any of the personal information described in this privacy policy.

THIRD PARTY SERVICES, WEBSITES AND APPS

We link to third parties as part of the Program. Our Privacy Policy does not apply to how third parties define personal data or how they use it. These third party (external) sites are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We advise you to review the privacy policies of these third parties before interacting with them.

COOKIES

The collection of information may involve the use of cookies and tracking images. Cookies are small pieces of information sent to your browser from the Website server and are stored on your computer's hard drive. Cookies make your web-browsing experience faster and easier by performing certain functions like saving your personal preferences. Most Internet browsers accept cookies automatically, but you can choose to change the settings of your browser to erase cookies or prevent automatic acceptance. If you choose not to receive our cookies, we cannot guarantee that your experience with the Website will be as quick or as complete as if you do receive cookies. A tracking image is an image placed on a web page that is designed to allow us to monitor visitors to the Program.

The information collected by cookies and tracking images includes general information about your computer settings, your connection to the internet, operating system, IP address, browsing patterns on the Program and your geographical location.

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time consistent with applicable privacy laws and guidelines. If we make changes to this Privacy Policy, we will notify you by revising the date on this Privacy Policy. You should periodically review this privacy policy when you use the Program. Your continued access or use of the Program shall be deemed your acceptance of the modified privacy policy.

CONTACT US

If you have any questions about this Privacy Policy please contact us via email at privacy@venngo.com or by mail at Venngo Inc., 155 Rexdale Boulevard., Suite 207, Toronto, Ontario, M9W 5Z8.

Last updated February 3, 2022