Our Commitment
H&R Block Canada Advantage Card Program Manager (“Program Manager”) is committed to protecting your privacy and confidential information while maintaining strong practices in the handling of all Personal Information.
This Privacy Policy sets out how the Program Manager uses and protects all information that you provide to us (“your information”) in accordance with the applicable privacy legislation, Personal Information Protection and Electronics Document Act (PIPEDA). By visiting the H&R Block Canada Advantage Card Cardholder website and app, and providing your Personal Information, you consent to the Program Manager collecting, storing, using and disclosing your Personal Information in accordance with the terms of this Policy. This Policy applies to the Personal Information of H&R Block Canada Advantage Card cardholders.
This Privacy Policy may be updated periodically to reflect changes to our Personal Information practices. We strongly encourage you to refer to this Privacy Policy often for the latest information about our Personal Information practices.
“Personal Information” means “information about an identifiable individual”. Personal Information
includes any factual or subjective information, recorded or not, about an identifiable individual.
This Policy applies to the personal information of the Advantage Card cardholders. Personal
Information does not include information that is anonymous, aggregated, or is no longer
identifiable to a specific person. The following types of information about individuals are not
considered Personal Information:
- Public telephone directory information, where the subscriber can refuse to be listed;
- Professional and business directories available to the public;
- Certain public registries and court records;
- Certain other publicly available printed and electronic publications.
Data Collected
Program Manager receives information from H&R Block Canada in order to provide customers
with services related to the Advantage Card. Personal Information is provided by customers so
they can benefit from the Advantage Card program.
H&R Block Canada collects the personal information from individual’s directly and then they pass this information to the Program Manager to facilitate the services related to the Advantage Card.
In addition, information may be obtained from other sources, including from public and
government records, credit reporting agencies, service providers, agents with whom have
arrangements or in accordance with their respective terms and conditions and/or privacy
policies, or any other source, with your consent or as permitted or required by law. This
information may be obtained by telephone, in writing or electronically.
Information we may collect includes the following, but is not limited to:
- Name, date of birth, occupation, phone number, email address and other contact
particulars for client contacts, such as driver’s license, passport, etc;
- Information relating to ongoing transactions with Advantage Card, including payment
history, inquiries or complaints and similar information; and
- Other information with your consent (written or implied) or as permitted or required by
law.
Why do we collect this data?
All the data collected by us is required in order for the Program Manager to provide you with a
trusted service. We may collect data for internal record keeping, to use as feedback to improve
our products and services delivered to you. The Program Manager and its service providers will
not sell or share your Personal Information to third parties for promotional purposes.
We may ask you for your Personal Information for the following reasons:
- To establish business relationship with the customer;
- To process their transactions ;
- To verify your identity and protect against fraud;
- To set up and manage products and services you have requested,
- To troubleshoot problems with the Service;
- To collect survey information that will be used to monitor or improve the use of our
Service;
- and overall customer satisfaction;
- To comply with legal, regulatory and contractual requirements: such as those relating to
- PCMLTFA (terrorist financing, and anti-money laundering requirements );
- PIPEDA;
- Other regulatory and issuing bank requirements.
We retain your personal information for as long as necessary to fulfill the purposes for which it
was collected, as outlined in this Privacy Policy, or as required to comply with legal, regulatory, or
contractual obligations.
Consent and Security
We will seek consent before collecting any Personal Information from you. Generally, you will be
asked to provide written or electronic consent, however in some circumstances we may accept
verbal consent or determine that consent is implied through your conduct. Express consent may
be obtained verbally, electronically or in writing. Implied consent may be obtained through your
use of a product, or when you approach us to obtain information, inquire about or apply for
products or services from us.
Once we have obtained your consent, we are committed to ensuring that your information is
secure. In order to prevent unauthorized access or disclosure, we have implemented suitable
physical, electronic and managerial procedures to safeguard and secure the information we
collect online. During the receipt of your Personal Information by the H&R Block Canada and
Program Manager to its service providers, we will apply privacy safeguards and will only conduct
business with companies who have committed to safeguarding Personal Information at a similar
standard applied by the H&R Block Canada and Program Manager. Authorized employees and
agents will have access to your personal information in order to perform their functions. We audit
our procedures and security measures regularly to help ensure that they are being properly
administered and that they remain effective and appropriate to the sensitivity of the information.
Subject to legal, regulatory and contractual requirements, you may refuse to consent to our
collection, use or disclosure of information about you at any time by giving us 30 days notice.
Depending on the circumstances, however, withdrawal of your consent may prevent us from
providing you or continuing to provide you with some services or information that may be of
value to you.
H&R Block Canada and the Program Manager for the Advantage Card program may use your
personal information for the below purposes:
- Identity Verification and Authentication: Confirm your identity and to authenticate you
when you contact us or we contact you.
- Eligibility Evaluation for Products and Services: Assess your eligibility for our products and
services.
- Application and Transaction Processing: Review and process your application, account,
transactions, and reports.
- Account Management: create and administer your accounts and services with us.
- Provision of Requested Products and Services: Deliver the products and services you
request.
- Communication: Engage in communications with you.
- Risk Management and Relationship Support: Assist in managing risks, operations and
maintaining our relationship with you.
- Fraud Prevention: Prevent, detect, and investigate fraudulent or criminal activities.
- Outstanding fees or payments: Collect amounts owing to us.
- Compliance with Legal and Regulatory Obligations: Adhere to legal, regulatory,
governmental, and contractual requirements.
Use of your email address.
Consent-Based Messages: With your permission, we may occasionally send you emails. These
could be for feedback requests, marketing offers tailored to your interests, or updates on our
products and services. With each email you will have the opportunity to opt out of receiving
future commercial electronic messages at that email address.
Customer Account Information: If you're a customer, we may use your email to keep you
informed about your Advantage Card account details, relevant program updates.
Email Engagement Tracking: To make our emails more relevant and effective, we might track
the activity of an email. This includes whether you open the email, click on links, or view graphics.
This helps us tailor future communications and ensure we’re delivering information you find
valuable.
Other Uses: Your personal information, including your email, might be used for additional
purposes where you’ve given consent, or as required by law. Should there ever be a need to use
your information for a new purpose, we will ask for your consent before we proceed.
The Program Manager may share your Personal Information only for everyday business
purposes. The below lists the circumstances in which we may share the customer’s Personal
Information:
- The Program Manager may share your information for everyday business purposes, such
as verifying your identity, processing your transactions, maintaining your account(s),
providing services, etc.
- The Program Manager may use third party service providers to provide certain services
and we may share your Personal Information with such service providers. We require any
company with which we may share your Personal Information to protect that data in a
manner consistent with this policy and to limit the use of suh Personal Information to the
performance of services.
- The Program Manager may disclose your Personal Information under special
circumstances, such as to comply with court orders and legal investigations requiring us
to do so and to satisfy audit, insurance, self-regulatory and regulatory requirements
applicable to the Program Manager.
- The Program Manager does not sell or otherwise provide information to the third-party companies for the marketing and promotional purposes of their own products and
services.
We do not disclose your personal information to third parties except: as described in this Privacy
Policy, with your consent, or as permitted or required by law. In some cases, our Service Providers
that we work with to facilitate the Advantage Card program may be located outside Quebec or
Canada. Accordingly, personal information provided to these companies for storage or
processing may be located outside Quebec or Canada, and may therefore, in addition to
Canadian and Quebec-specific laws, also be subject to the laws of those countries.
If we collect personal information from individuals in Quebec, we will make the necessary
declarations to the Commission d’accès à l’information (CAI), which includes filing a declaration
of our privacy practices when required by the regulations. Furthermore, we will notify the CAI in
the event of any significant privacy breach affecting the personal information of Quebec
residents.
Privacy Principles
To fulfill our commitment to you, we observe the following 10 principles when dealing with your
Personal Information.
1. We are Accountable to You
The Program Manager is responsible for all Personal Information in its possession or custody,
including any Personal Information disclosed to third parties for processing or other
administrative functions. We have a Chief Privacy Officer, who oversees the implementation of
our privacy program. To contact the Program Manager Compliance & Privacy Officer please refer
to the 'Contact’ section below.
In addition, our employees are committed to ensuring the privacy and protection of your
personal information in accordance with this Privacy Policy and applicable laws. Employees are
responsible for collecting, using, and disclosing personal information only for the purposes
communicated to you and for which consent has been obtained. The employees are required to
follow strict security protocols to protect your data from unauthorized access, misuse, or
breaches. Employees are also required to report any privacy incidents immediately to ensure
timely action. To maintain the highest privacy standards, our team participates in ongoing
training and awareness programs. Furthermore, employees assist in responding to your requests
regarding the access, correction, or deletion of personal information in a prompt and respectful
manner. By adhering to these responsibilities, our employees help safeguard your privacy across
all of our services and interactions.
2. We will Identify the Purpose for Collecting your Personal Information
H&R Block Canada and the Program Manager will identify and document the purposes for which
we collect your Personal Information.
3. We will Obtain Valid Consent to Manage Personal Information
The Program Manager will make a reasonable effort to make sure you understand how your
Personal Information will be used and will obtain your consent before or at the time we collect or
use the Personal Information. Your consent can be express, implied, or given through an
authorized representative:
- The Program Manager will collect your express consent (verbal, written or electronic)
when the Personal Information is sensitive or its collection, use or disclosure is outside of
the reasonable expectations of you providing it, or that creates a meaningful risk of
significant harm that is not otherwise mitigated.
- The Program Manager may rely on implied consent in the following scenarios:
- a customer relationship already exists;
- express consent has previously been given for the same or similar use of the
Personal Information; and
- where the intended use of the information is reasonably obvious from the context
in which it is obtained and you provide the information voluntarily.
Subject to legal, regulatory and contractual requirements, you may withdraw your consent to our
collection, use or disclosure of your Personal Information. However, depending on the
circumstances, the withdrawal of your consent may prevent us from providing you or continuing
to provide you with some services or information that may be of value to you. In addition, you
should be aware that we may collect, use or share your Personal Information without your
knowledge or consent in exceptional circumstances where such collection, use or disclosure is
permitted or required by law. For example, we may collect, use or share your Personal
Information to investigate a breach of an agreement or law, in response to a demand, search
warrant or court order we believe to be valid, to realize security pledged, or to investigate and
deter fraud.
4. We will Limit the Collection of Your Personal Information
The Program Manager limits the amount and type of Personal Information we collect to what is
necessary for the purposes we have identified to you. We will only collect Personal Information
using practices that are fair and lawful, and as described in this Policy.
5. We will Limit the Use, Disclosure and Retention of Your Personal Information
The Program Manager will use or disclose Personal Information only for the purposes it was
collected, unless you give consent to use or disclose it for another reason, or it is permitted or
required by law. Under certain exceptional circumstances, The Program Manager has a legal
duty or right to share your Personal Information without your consent to protect The Program
Manager’s and/or the public interest. The Program Manager will only keep your Personal
Information as long as necessary for the purposes identified at the time of collection.
6. We will Keep Your Personal Information Accurate
The Program Manager will make a reasonable effort to keep your Personal Information up to
date, accurate and relevant for its intended use. However, we also rely on you to tell us when
your information changes as soon as possible. You may, in writing, request access to your
Personal Information to verify the accuracy and completeness and request that it be amended
as appropriate. To access your Personal Information, please contact the Compliance
Department as directed in the 'Contact section below. Keeping customers’ information accurate
and up-to-date allows us to continue to offer high quality services.
7. We will Safeguard Your Personal Information
The Program Manager maintains reasonable administrative, technical and physical safeguards
in an effort to protect the Personal Information in our custody and control against unauthorized
access, use, modification and disclosure of. We train our employees to keep clients’ Personal
Information strictly private and confidential. We require all of our staff to sign our privacy
document that obliges them to respect and protect clients’ Personal Information. We ensure that
departing staff understand they remain contractually obliged to respect the privacy of clients’
Personal Information.
During the collection, processing, and sharing of your personal information with our service
providers, we implement a range of privacy safeguards to protect your data. These safeguards
include both technical and organizational measures to ensure your information remains secure
at every stage. Specifically:
- Encryption: We use encryption protocols to protect personal information during
transmission and storage, ensuring that data is unreadable by unauthorized parties.
- Access Control: We limit access to personal information to only those employees,
contractors, and service providers who need it to perform their job functions, and we
require that access be granted through secure authentication methods.
- Data Minimization: We ensure that only the necessary personal information is collected,
shared, or used for the specified purposes, reducing the risk of exposure.
- Contractual Safeguards with Service Providers: We require all third-party service
providers to sign agreements that include privacy and confidentiality obligations,
ensuring they handle personal information in accordance with applicable laws and our privacy policies.
8. We will Make Information about Our Privacy Program Available to You
The Program Manager is open about the way we manage your Personal Information. You may
request access to more information about our privacy practices, and we will make it available to
you in a manner that is easy to understand.
9. We will Give You Access to Your Personal Information
You may make a request in writing for access to your Personal Information. After verifying your
identity, we will, within a reasonable timeframe (within 30 days) barring exceptional
circumstances as outlined in PIPEDA and other substantially similar provincial legislation, tell you
what Personal Information we have, what it is being used for, and to whom it has been disclosed.
In certain situations, however, we may not be able to give you access to all your Personal
Information. In these situations, we will, except where prohibited by law, explain the reasons for
this lack of access and advise you of any recourse you may have.
10. Challenging compliance
The Program Manager will respond to your questions, concerns and complaints about the
protection of your Personal Information in a timely manner, typically within thirty (30) days. If we
need to extend the time, or if we refuse your request, we will tell you why and notify you of the
new deadline.
Links to external websites
The Advantage Card Web portal or App may contain links to external websites which are not
supported by the Program Manager. Once you have been directed to an external website, the
Program Manager does not have control over the contents and information that you share. We
cannot be responsible for the protection and privacy of any information which you provide whilst
visiting an external website as those sites are not governed by this Privacy Policy.
The Program Manager takes your privacy and the protection of your information seriously and
takes commercially reasonable measures to ensure its security. However, no transmission of
information over the internet can be guaranteed to be uninterrupted or completely secure.
Accordingly, we cannot guarantee that your information will not be unlawfully accessed by a
third party and any external website visited is at your own risk.
Canada’s Anti-Spam Legislation (“CASL”)
The Program Manager is committed to protecting your privacy and your Personal Information.
The Program Manager complies with Canada’s Anti-Spam Legislation (“CASL”) and we are
committed to ensure that you only receive the electronic communications that you want from
us. These legislations protect consumers and businesses from the misuse of digital technology,
including spam and other electronic threats.
The Program Manager will never send you unsolicited emails in connection with the marketing of
the Program Manager, its services or products. If you prefer not to receive these types of emails
you may opt-out by clicking the “Unsubscribe” link contained in any such electronic message.
If you have questions or a complaint related to CASL you may contact our Compliance
Department. The contact details are located in the “Contact” section of this Policy.
Individuals have the right to access, update, correct inaccuracies and request deletion of their
Personal Information in the Program Manager’s custody and control, subject to certain
exceptions prescribed by law. Otherwise, an individual wishing to request access, updating,
correct inaccuracies and request deletion of their Personal Information in our possession or
control may send a request to this effect to the Program Manager’s Privacy and Compliance at
the contact information below. We may request certain Personal Information for the purposes of
verifying the identity of the individual seeking access to their Personal Information records.
We will respond to your request within 30 days, in accordance with the timelines set out under
the federal and provincial regulatory requirement. In some cases, if additional time is needed
due to the complexity of the request, we may extend the response time by an additional 30 days,
and you will be notified of this extension within the initial 30-day period along with the reasons for
the delay.
In certain circumstances the Program Manager may not be able to provide you with access to
your personal information, (e.g., if disclosing the information would reveal confidential
commercial information or information about a third party). If this is the case, we will inform you
of the reasons that we were unable to provide you access. Additionally, the Program Manager
does not discriminate against our pricing or services when an individual exercises these rights.
If you have a question or concern about our processes to use, protect and disclose your Personal
Information, or if you want to report a privacy breach, please contact us at:
H&R Block Canada Advantage Card Program Support
Attention: Privacy Officer
221 Lakeshore Road E, Suite 300
Oakville ON, L6J 1H7
If your concern remains unresolved by the Program Support, you may contact the Privacy
Commissioner of Canada at:
Office of the Privacy Commissioner
30 Victoria Street
Gatineau, Quebec, K1A 1H3
Toll Free: 1-800-282-1376
Privacy Policy Last Updated: October 2024