UGO Wallet Privacy Policy


This Privacy Policy explains how, and why, UGO Mobile Solutions, a division of The Toronto‑Dominion Bank (“UGO”, “we”, “us”, “our”), handles your personal information.


You agree to this Privacy Policy when you interact with us, including when you:

  • Download and register to use UGO’s digital wallet application (“UGO Wallet”);
  • Store and use gift, loyalty, membership and other cards (“Cards”);
  • Visit our website; or
  • Contact us with a comment, question or complaint.


In this Policy, “information” means your personal information, and “merchant” means the company or companies that are tied to your Cards.


Collecting and Using Your Information


Types of information we collect


The types of information we collect depends on the information you choose to share and how you interact with us. This can include:

  • "Contact information" – Information like your name, email, address, and phone number
  • "Card information" – Information about your Cards, like their balance, date issued, merchant, and the people who gifted the Card
  • “Transaction information” – Details on transactions involving Cards you manage, including the date, amount and location of the transaction, and the items purchased
  • “Technical information” – Information related to your interactions with us, including your internet protocol (IP) address (which can indicate your location), your use of UGO Wallet and our website, and information about your device
  • “Preferences and interests” – Information about you that informs what products and services you may be interested in


When and why we collect and use your information

As a summary, the main reasons why we collect and use your information are:

  • to confirm your identity and protect you from fraud and error,
  • to comply with legal and regulatory requirements,
  • for analytics and reporting, and
  • to otherwise provide and enhance the UGO services.

Here are the details on when and why we collect and use your information:

  1. Downloading UGO Wallet: When you download the UGO Wallet app, we may collect technical information (as outlined in more detail below) to determine whether your device can use the app.
  2. Using Cards: When you use a Card that you have added, UGO and the merchant will use the Card’s information in order to facilitate and complete the transaction. UGO may also collect transaction information including the date and amount of the transaction.
  3. Other communication: When you register with UGO or use your UGO Wallet, we may contact you by e-mail, phone, mail, text message, push notification or other similar methods with surveys or information that we believe may be of interest to you.
  4. Customer Service: We may ask for your contact information when you interact with us, including when you contact us or leave a comment on our website or social media sites. We may also ask you to provide other information that will help us respond to you or that is relevant to your communication with us. We may also retain this information to assist you in the future and to improve our customer service and product and service offerings.


Collection and use of technical information


UGO Wallet

When you use UGO Wallet, we collect the IP address and other device-related information such as the make and model of your device, its operating system, mobile device identification number (IMEI), advertising ID, and Media Access Control (MAC) address.

We use this information to operate and monitor UGO Wallet. This includes purposes related to internal analytics and helping us understand how our users use the UGO Wallet app.

Your device-related information may also be used as a mobile marketing identifier to offer UGO content and advertisements to you. You can disable this feature by adjusting the advertising settings on your device.

Please note that the ability to collect this type of personal information is controlled by your device. Please refer to the resources for your device regarding how to allow or block the collection of location or device information. If you choose not to provide location or certain device information, some services you request, including some from us, may not operate the best.


Sharing Your Information

We may transfer or disclose your information to third parties for the following reasons:

  1. Provide our Products and Services: we transfer or disclose your information to provide our products and services, including to support UGO Wallet’s functions. This includes sharing your information with:
    • Service providers. We may transfer your personal information to third parties who provide services on our behalf. For example, we may use service providers to host UGO Wallet-related services, facilitate transactions, or send offers or other communications on our behalf.
  2. Sale of Business: We may transfer or disclose any information we have about you in connection with a merger or sale involving all or part of UGO or as part of a corporate reorganization, stock sale, or other change in corporate control.
  3. Protect our Legal Interests: UGO and other members of the TD Bank Group may disclose your personal information in response to a search warrant or other legally valid inquiry or order, to meet requests for information from regulators or to satisfy legal and regulatory requirements applicable to us, or as otherwise required by applicable law. We may also disclose information for the establishment, exercise or defence of legal claims, protecting our rights or property, or as otherwise permitted by law.


Safeguards

We have implemented administrative, technical and physical safeguards designed to protect personal information in our custody and control against unauthorized access, use, modification and disclosure, including appropriate measures to protect the safety of Card information.

All e-Gift Card purchases made in UGO Wallet are processed by TD, and all the information that you save into UGO Wallet is stored in a way that meets TD’s information security standards. We review our procedures and security measures regularly to help make sure they remain effective and appropriate. Some of the ways we use your information as described in this Policy also support our efforts to protect your security. Some of the information we ask you to provide allows us to authenticate you and prevent unauthorized access to your information.

You can do your part to protect your information by setting up enhanced security measures on the UGO Wallet app. You can enable and set a passcode to be entered every time you open UGO Wallet. To enable this feature, tap on My Profile in the bottom right-hand corner of the home screen. Then, tap on Login & Security and turn on Enhanced Security. If you're using an iPhone you can set up Touch ID or Face ID instead of a passcode.


Transfers of Your Information to Other Regions

TD is a global organization and may transfer your information to affiliates and service providers across Canada and in other countries. These countries may include the USA, UK, European states, India, or others. We take measures to protect your information wherever we or our service providers use, store or access your information. However, like in Canada, we and our service providers may disclose your information in response to valid demands or requests made by governments, regulators, courts and law enforcement authorities in other regions.


Retaining and Destroying Your Information

We retain your information only as long as we need it for the purposes for which it was collected, used or disclosed. We have procedures to help us determine the appropriate length of time we will retain your information. The length of time we retain the information depends on the product or service, the sensitivity of the information, and the purposes for which we use it. This period may extend beyond the end of your relationship with us in certain circumstances, including:

  • when we need your information to respond to issues that may arise at a later date,
  • for legal or regulatory purposes, and
  • for security and business modelling purposes.

We have procedures to guide what we do when we no longer need your information for these purposes. We may securely destroy, delete, erase it, or convert it to an anonymous form.

You can contact us using the contact information below if you have questions about how long we retain your information.


Your Rights to Access and Correct Information


Accessing your information

Upon request, we will give you access to the information we retain about you. If you ask us, we will help you make your request.

You can access most of your information, including your current Cards, through the UGO Wallet app. If you need information not found in the app, simply call us or send us a written request using the information under “Contact Us” below. We may ask you for your information to confirm your identity.


Correcting your information

We make reasonable efforts to keep your information accurate and up to date.

This helps us give you better service. We have procedures and practices to help us maintain the accuracy of your information, but you can help by keeping us informed of any changes. If you find any errors in our information about you, let us know right away. We will make the corrections. If we do not agree with your requested change, we will note your request in your file.


Contact Us


Questions

If you have any questions on this Privacy Policy, please contact us at contactus@ugo.ca .

If this does not answer your question, you may contact TD’s Chief Privacy Officer at:

Email: TD.Privacy@td.com

Mail:

Toronto-Dominion Centre, P.O. Box 193

Toronto, ON M5K 1H6

Attn: TD's Chief Privacy Officer


Complaints

We take your concerns seriously. We are committed to helping resolve any complaint about how we handle your information.

If you have a complaint about how we handled your information, please review our complaint resolution process here:

If your complaint is not resolved by TD and it relates to a potential violation of privacy law you may contact:

The Office of the Privacy Commissioner of Canada
Website: www.priv.gc.ca
Phone: 1-800-282-1376 Fax: 1-819-994-5424
Mail: 30 Victoria Street, Gatineau, QC K1A 1H3


Privacy Policy Updates

We may change this Privacy Policy from time to time. The current Policy will be available on our website at www.ugowallet.com/privacy.