Canada Privacy Policy
Last Updated: August 7, 2026
This Privacy Policy ("Privacy Policy") describes how Choice Digital Canada Corp. ("Choice Digital Canada," "we," "our," or "us") collects, uses, discloses, and safeguards personal information in connection with our website, our client and program materials, and the disbursement and prepaid card program we administer as program manager for Peoples Trust Company (collectively, the "Services").
Choice Digital Canada acts as program manager for a disbursement and prepaid card program under which Peoples Trust Company ("PTC") is the issuing bank. This Privacy Policy does not govern PTC's handling of personal information in its capacity as issuer. PTC collects, uses, and discloses personal information directly in connection with issuing and administering the card and account itself, and that handling is governed by PTC's own privacy policy, available at peoplesgroup.com/about-us/legal/privacy-security/privacy-policy. This Privacy Policy covers only the personal information that Choice Digital Canada itself collects, uses, and discloses in its capacity as program manager.
Choice Digital Canada reserves the right to modify this Privacy Policy at any time. If we make changes to how we collect, use, or share personal information, we will post the updated Privacy Policy on this page and, where required by applicable law, provide additional notice. Your continued use of the Services following such an update constitutes your acknowledgement of the changes.
This Privacy Policy covers the following topics:
Personal Information We Collect
Consent
How We Use Your Personal Information
How We Share Your Personal Information
Cookies and Tracking Technologies
Your Choices
International Transfers of Personal Information
Data Retention
Security of Personal Information
Your Privacy Rights
Additional Information for Quebec Residents
Children's Privacy
Other Sites and Services
Changes to This Privacy Policy
Contacting Us
1. PERSONAL INFORMATION WE COLLECT
The personal information we collect depends on whether you are a website visitor or prospective business client, or a recipient of funds through the program we administer for PTC.
Website and Business Contacts
Contact details, such as your name, business email address, and phone number.
Professional information, such as your company name, job title, and company location.
Communications, such as information associated with your inquiries or requests for support.
Marketing information, such as preferences you set in connection with our communications.
Disbursement Recipients and Cardholders
Contact information, such as your name, mailing address, email address, and phone number.
Identity information, such as your date of birth, and, when we are required to verify your identity, government-issued identification or your Social Insurance Number.
Financial and transaction information, such as the amount and source of a disbursement, your payment history, and information about your use of the card or e-Transfer disbursement, if applicable.
Screening information, such as the results of identity verification, fraud, and sanctions screening performed before a disbursement is made.
Information about the corporate client or payor on whose behalf we are administering a disbursement, such as the reason for the payment.
Automatically Collected Information
Device and browsing information, such as your IP address, browser type, device type, and general location information.
Usage information, such as pages viewed, session duration, and navigation activity on our website or program portal.
Information from Third Parties
Identity verification, fraud, and sanctions screening providers.
The corporate client or payor who has engaged Choice Digital Canada to administer disbursements to you.
Credit or consumer reporting agencies, where applicable to a specific program.
2. CONSENT
Except as described below, we collect, use, and disclose your personal information only with your express consent, and only for the purposes described in this Privacy Policy. We will not use or disclose your personal information for a purpose that is not described in this Privacy Policy without your additional consent.
When We Collect Your Consent
If you are a disbursement recipient or cardholder, we obtain your express consent when you activate your disbursement or card. At that point, we present this Privacy Policy and require you to affirmatively accept it before we collect any additional personal information, such as your date of birth, government-issued identification, or Social Insurance Number, and before your disbursement or card is made available to you.
When Your Consent Is Not Separately Required
In some cases, a corporate client or payor engages us to disburse funds it already owes you, and provides us with your basic contact information, such as your name and email address, so that we can notify you of, and process, that disbursement. In this circumstance, we act as the corporate client's or payor's service provider, and our receipt and use of your contact information for this limited purpose does not require your separate consent to us, provided we use it only to complete the disbursement you are owed. The corporate client or payor remains responsible for ensuring it has appropriate authority to share your information with us for this purpose. Your consent is separately required, as described above, before we collect any additional personal information from you or use your information for any purpose beyond completing that disbursement.
We do not require your consent where permitted or required by law, including where necessary to comply with a legal obligation, to investigate or prevent fraud, or to respond to a request from a law enforcement or regulatory authority.
How We Collect, Track, and Retain Your Consent
Where your consent is required, we collect it through an affirmative action, such as clicking to accept this Privacy Policy at activation. We retain a record of the date, time, and version of the Privacy Policy you accepted.
Withdrawing Your Consent
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us using the information in Section 15. If you withdraw your consent, we will explain the implications, which may include our inability to continue administering your disbursement or card.
3. HOW WE USE YOUR PERSONAL INFORMATION
We use personal information to:
verify your identity and eligibility to receive a disbursement or card;
process, deliver, and service disbursements made through Interac e-Transfer or the prepaid card program;
communicate with you about your disbursement, card, or any inquiries you raise with us;
detect, investigate, and prevent fraud and other harmful or unauthorized activity;
comply with applicable law, including responding to lawful requests from courts, regulators, and government authorities;
maintain the records we are required to keep in connection with administering the program;
improve and operate our Services; and
where you have consented, send you marketing communications, which you may opt out of at any time.
4. HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your personal information with:
Peoples Trust Company
, as issuer of the card and holder of the underlying account, for purposes of issuing, funding, and administering your disbursement or card. PTC's own handling of your information as issuer is governed by its privacy policy, not this one.
Payment networks
, including Interac Corp. and Mastercard, as needed to process and deliver a disbursement or facilitate use of the card.
Identity verification, fraud, and sanctions screening providers
, to verify your identity and screen for prohibited parties before a disbursement is made.
Cloud hosting and technology service providers
, including our U.S. affiliate, Choice Digital Corp., which provides infrastructure, hosting, and operational support to Choice Digital Canada under an intercompany services arrangement. See Section 7 below for more on cross-border processing.
The corporate client or payor
on whose behalf we are administering your disbursement, limited to the information needed to confirm delivery and status of the payment.
Professional advisors
, including our legal, accounting, and compliance advisors.
Courts, law enforcement, and government authorities
, where required or permitted by applicable law.
A successor entity
, in connection with a merger, acquisition, financing, or sale of some or all of our business.
We do not sell your personal information for monetary consideration.
5. COOKIES AND TRACKING TECHNOLOGIES
Our website uses cookies and similar technologies, including Google Analytics, to help us understand how our website is used and to improve it. You can manage or disable cookies through your browser settings, though this may affect functionality. To learn more about managing cookies generally, visit www.allaboutcookies.org. To opt out of Google Analytics, you can install the Google Analytics Opt-out Browser Add-on. Our website does not currently respond to browser "Do Not Track" signals.
6. YOUR CHOICES
Marketing communications
: you may opt out of marketing emails at any time by clicking "unsubscribe" or contacting us using the information in Section 15. You will still receive communications necessary to service your disbursement or card.
Cookies
: see Section 5 above.
Access and correction
: see Section 10 below.
7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Choice Digital Canada is affiliated with Choice Digital Corp., based in the United States, which provides hosting, infrastructure, and operational support to Choice Digital Canada under an intercompany services arrangement. As a result, personal information collected by Choice Digital Canada may be processed and stored in the United States. Privacy laws in the United States may differ from those in Canada. Where personal information is transferred in this manner, we require contractual protections designed to provide a comparable level of protection to that required under Canadian privacy law. These protections include contractual obligations restricting use of your personal information to the purposes described in this Privacy Policy, as well as technical safeguards such as encryption and restricted access controls. By providing your personal information to us, you acknowledge this cross-border processing.
8. DATA RETENTION
We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, including to meet the recordkeeping obligations associated with administering the program, and to comply with applicable law. When personal information is no longer required, we securely destroy, delete, or anonymize it.
9. SECURITY OF PERSONAL INFORMATION
We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. Our internal security practices are governed by our affiliate Choice Digital Corp.'s Information Security Policy and Data Protection Policy. No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
10. YOUR PRIVACY RIGHTS
Subject to limited exceptions under applicable law, you have the right to:
request access to the personal information we hold about you;
request correction of inaccurate or incomplete personal information; and
withdraw consent to our collection, use, or disclosure of your personal information, subject to legal or contractual restrictions and the effect this may have on our ability to administer your disbursement or card.
To exercise these rights, contact our Privacy Officer using the information in Section 15. We may need to verify your identity before responding to your request. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at priv.gc.ca.
11. ADDITIONAL INFORMATION FOR QUEBEC RESIDENTS
In accordance with Quebec's Act respecting the protection of personal information in the private sector ("Law 25"), Choice Digital Canada has designated the following individual as responsible for the protection of personal information:
Title: Data Protection Officer Contact: privacy@cdco.io
If you are a resident of Quebec, your personal information may be processed and stored outside Quebec, including in the United States, as described in Section 7 (International Transfers of Personal Information). The contractual and technical safeguards described in that section, including encryption and restricted access controls, apply to protect your personal information when it is transferred outside Quebec.
In addition to the rights described in Section 10, Quebec residents have the right to:
receive their personal information in a structured, commonly used technological format (data portability); and
be informed of, and request human review of, any decision made about them based solely on automated processing that produces significant effects.
If we become aware of a confidentiality incident involving your personal information that presents a risk of serious injury, we will notify both the Commission d'accès à l'information and affected individuals as required by law.
12. CHILDREN'S PRIVACY
Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If you believe we have inadvertently collected personal information from a child under 13, please contact us using the information in Section 15, and we will delete that information promptly.
13. OTHER SITES AND SERVICES
Our Services may contain links to third-party websites, including PTC's website. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies directly.
14. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. Material changes will be posted on this page, and, where required by applicable law, we will provide additional notice.
15. CONTACTING US
If you have questions about this Privacy Policy or wish to exercise a privacy right described above, please contact our Privacy Officer:
Choice Digital Canada Corp. Attention: Data Protection Officer, 30 Wertheim Court, Unit 12, Suite 201, Richmond Hill, Ontario L4B 1B9, Canada or via Email: privacy@cdco.io.