Privacy Policy
Latest update: August 5th, 2025
1. About this policy
Trampoline Finance Inc. (“Bounce”, “we”, or “us”) takes the protection of your privacy seriously. This is why this Privacy Policy (the “Policy”) provides you with the information about how we collect, use and disclose (collectively, “process”, “processed”, “processing”) your personal information when you use our services. In particular, this Policy contains information about how we process your personal information when you are using our services, including when: (a) navigating our public websites such as www.bouncepay.ca (http://www.bouncepay.ca) (the “Website(s)”); (b) using our application currently named Bounce (the “App”); and (c) exchanging with us by e-mail, social media or otherwise.
However, 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. These third parties may process your personal information in accordance with their respective privacy policies. We are not responsible for such processing, and we invite you to consult these third-party policies carefully.
2. Personal information
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 which relates to a natural person and directly or indirectly allows that person to be identified.
Depending on your use of our services, we may collect your personal information, including but not limited to your name, contact information, e-mail address, location, financial information, and information about your mobile and/or computer devices. Note however that we can never see, nor store, any of your banking credentials (namely, user ID, e-mail addresses, card numbers and passwords used for authentication purposes).
3. How do we collect your personal information?
Directly from you
Generally, we obtain personal information that we need directly from you, for example, when you use our services or communicate with us.
With a legal basis such as your consent
The legal basis for processing your personal information is generally your consent, unless applicable law provides another permissible legal basis (for example, to comply with our legal obligations, where necessary to establish, exercise or defend a legal claim or legal proceeding).
Refusal of collection and withdrawal of your consent
You have the right, if you wish, to refuse the processing of your personal information. You may also, at any time, and subject to reasonable notice and any applicable legal or contractual restrictions, withdraw your consent (if any) to the processing of your personal information in our possession by contacting us. You should be aware, however, that if you choose not to provide your personal information, this may prevent you from, for example, using the App, as this information is essential to the access to the App. You may contact us as indicated in the “How to contact us?” section to submit any requests in this regard.
4. Why do we have access to your personal information?
When using our services, we may have access to the following personal information for the purposes listed below.
Personal information | Purposes |
|---|---|
Device data such as IP addresses | This information is collected automatically by our services to diagnose issues with our services, to fix bugs, to identify fraud risk and 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. |
Communication data such as e-mail addresses | If you communicate with us by e-mail, on social media, by subscribing to our services-related news communications on our Websites or by any other means, we will collect communication data to respond to your queries and provide you with information about our services. |
Registration data such as your name, e-mail address and personal identification number | We collect this information to create your account on the App. and to enable you to log in to our App. We also use your e-mail address to communicate with you about the App, such as for updates or maintenance. |
Authentication data | In the event that you decide to use the feature that allows you to authenticate yourself using your fingerprint or facial recognition system when reopening the App, any biometric data will remain strictly stored on your personal device and won’t be shared with us or one of our partners. |
Identity verification data such as user’s photo and ID Document (government issues ID card, passport or else) | We use your identity document and photo to verify your identity as required by law and to protect users from identity theft and fraud. Our identity verification provider, Sardine, collects, stores, and processes this information as needed for us to meet these obligations, and we do not collect or store this data on our end. Sardine retains your face data, including the photos of your document and your face, for up to 2 weeks to allow Bounce to conduct manual identity verification reviews if necessary, after which it is deleted. Sardine does not retain any facial templates or biometric information beyond this period. All access to this sensitive data is restricted to trained and authorized personnel. We do not use your face data for any other purpose, nor do we sell or repurpose it. Please note that Sardine may also share your data with its own third-party service providers strictly for data processing purposes. However, under Sardine’s contractual agreements, these providers are permitted to process your data only for the sole purpose of identity verification as described here, and not for any other use. |
Transactions metadata (e.g. names, photos and emoji reactions) | This information is used to provide you with the functionalities of the App, such as performing search through its transactions as well as social features. |
IP addresses | With your consent, we use geolocation cookies to identify your location. This information is used strictly to secure your transfers and prevent fraud. IP addresses may also be used with Cookies as set forth in the section “How do we use Cookies?” below. |
Financial information (provided by third parties), except for banking credentials | 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 and routing number, historical 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. |
Inquiries data | As part of the App, we offer support to our 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. |
Contact information | If you consent to receive our communications, we will send you e-mails about updates and specific app information. You can unsubscribe at any time directly in the e-mails or by contacting us. |
Social media data | 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. |
5. Do we share your personal information with third parties?
Bounce does not rent nor sell any of your personal information to third parties and will not share it with third parties without your consent, unless it is necessary to do so by law or for the purposes set forth above.
With our employees
In the course of their work, our employees may need to access your personal information, for example, when you contact us or request support. Their access is limited to what is necessary to perform their duties and we enforce strict security measures and guidelines in order to prevent misuse of your personal data
With strategic partners
We may share your personal information with our partners to the extent that such disclosure is required for the purposes listed above. Bounce may use third parties to facilitate its business, such as integration partners, hosting services providers, and marketing partners. In connection with these business operations, Bounce’s service providers may have access to your personal information for use for a limited time in connection with these business activities. Where Bounce utilizes third parties for the processing of any personal information, Bounce implements reasonable contractual and technical protection for such third parties to keep all personal information they process strictly confidential. Please note that these third parties may be in jurisdictions other than your location in which case appropriate measures are taken by Bounce as set forth below.
When required by applicable laws
We may also share your personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) conform with the law; (b) comply with the order of a competent judicial authority in any jurisdiction; (c) comply with legal process served on Bounce; (d) protect and defend the rights or property of Bounce; (e) enforce or verify your compliance with any part of the agreements that you have entered into with Bounce, if any; (f) prevent fraud or other illegal activity perpetrated through the services; (g) act in urgent circumstances to protect the personal safety of users of the services or the public at large; or (h) fulfill our regulatory obligations as a registered Money Services Business (MSB) under FINTRAC, including mandatory reporting of suspicious transactions, large cash transactions, and other prescribed financial activities as required by Canada's anti-money laundering and anti-terrorist financing legislation.
During business transfers
We may share your personal information without your permission when our operations require it (in the event of a merger, acquisition, bankruptcy or sale of assets, for example). In this kind of event, we may also share some or all of your personal information to the relevant third-party (or its advisors) as part of a due diligence process.
For other purposes with your consent
Where you have expressly consented, your personal information may be shared with other third parties.
6. How do we use cookies?
A cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet or other device when you use your browser to visit an online service. Other tracking technologies, such as web beacons and tracking pixels, may be used for similar purposes. In this Policy, all such tracking technologies are collectively referred to as “Cookie(s)”.
Any personal information collected through the use of Cookies by or on behalf of Bounce is treated with the same level of confidentiality as any other personal information held by Bounce.
Strictly necessary Cookies
These Cookies are necessary for the services to function and be secured and cannot be switched off in our systems. Strictly necessary cookies must be present for the services to provide basic functions. They allow for a user to navigate back and forth between pages without losing their previous actions from the same session.
Non-essential Cookies
If you have consented to their use (to the extent required by applicable laws), Bounce and/or its third-party partners may also use non-essential Cookies in connection with the services, including the following:
- Functional Cookies. These Cookies enable the services to provide enhanced functionality and personalisation. If you have consented to their use, functional Cookies allow the services to remember the preferences and choices that you make including your username, region, and language.
- Social media Cookies. If you have consented to them, we may use social media Cookies such as the Facebook pixel to provide you with personalised offers, to measure, optimize and build audiences for advertising campaigns served on social media platforms. The services may also use Cookies for sharing content with social media (such as Facebook, LinkedIn, Twitter and Instagram). Using the share buttons will set a Cookie to link the content viewed on our website to your user account with such networks, if any.
- Advertising Cookies. If you have consented to their use, we may use advertising Cookies to gather information from you on your devices to display advertisements to you based on relevant topics that may be of interest to you. If you want more information about how to manage and/or disable Advertising Cookies, visit http://www.youronlinechoices.com/ (http://www.youronlinechoices.com/). You can also refuse the use of such Cookies by following the instructions listed below.
- Analytic Cookies. We may use analytic Cookies to understand traffic patterns on the services. These Cookies are used for statistical purposes only.
How to manage Cookies?
Except for strictly necessary Cookies, we will only place Cookies on your devices if you consent to it, and such Cookies will be kept for a maximum period of thirteen (13) months from when they are placed on your devices. At the end of this period, your consent will be required again.
To the extent that Cookies are being used, they can be managed and/or disabled through your browser’s Cookie settings, mobile device’s advertising settings. To the extent social media Cookies (“plugins”) are being used, they can also be managed by consulting the following networks’ policies:
- Facebook: https://www.facebook.com/privacy/policy/
- LinkedIn: https://www.linkedin.com/legal/privacy-policy
- X: https://x.com/en/privacy/previous/version_16
- Instagram: https://privacycenter.instagram.com/policy
However, if you refuse Cookies, you may not be able to use all the features of the services, and to the extent that advertising is being displayed on our services, you will still be served with advertising, but such advertising will no longer be as tailored to you. If you want more information about how to manage and/or disable non-essential Cookies, please visit http://www.allaboutcookies.org/manage-cookies/, and https://optout.aboutads.info/?locale=en-US.
7. Interest-based advertising (IBA)
Bounce and its third-party partners may collect your personal information to provide advertisements about goods and services likely to be of interest to you. Such personal information may be collected with social media Cookies and/or advertising Cookies as set forth above. Depending on the preferences that you have expressed on your mobile devices, Bounce and its advertising partners may also use your mobile advertising identifier to target and measure the effectiveness of their advertising campaigns. In iOS, this identifier is called “IDFA” (ID for Advertising); in Android (Google Play), this identifier is called “AAID” (Android Advertising ID). You can access and reset your mobile advertising identifier or limit its use through the settings on your mobile devices’ operating system. In no event will we permit advertising directed at children where we have actual knowledge that the user is under the age of 13. To learn more about our advertising practices, please contact use as set forth in the Section “How to contact us?”.
8. Where do we store my personal information?
Your personal information may be held by Bounce in locations other than your province, territory, state, or country of residence, including in Canada (including in the province of Quebec) and the United States. Bounce may also subcontract processing to or share your personal information with third parties located elsewhere, including locations other than your province, territory, state, or country of residence. In such case, Bounce will ensure that your personal information is adequately protected by appropriate technical, organizational, contractual, or other lawful means. If you would like to obtain more information on these security measures, please contact Bounce as set forth in the Section “How to contact us?”.
9. How long do we 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 Bounce will be destroyed or anonymized.
10. How do we protect your personal information?
In accordance with our privacy program
In order to protect your personal information, we have put in place a privacy program related to the management of the personal information we hold which includes policies, practices and procedures. These internal policies, practices and procedures govern the processing of personal information under our control or custody, as well as complaint handling, information security and data governance at Bounce. 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, practices and procedures have been approved by our Privacy Officer. The processing of your personal information through our services complies with the requirements of this program.
With necessary and appropriate security measures
We strive to apply the necessary and appropriate security measures to ensure the confidentiality of personal information under our control or custody. In doing so, we follow generally accepted industry standards. Personal information under our control or custody is therefore only accessible to those individuals who have the authority to access it and who only consult it when necessary for the performance of their duties. Appropriate contractual, physical, technical and administrative safeguards and security measures have been put in place and are maintained to minimize the risk of incidents. If you believe your personal information has been compromised, we invite you to contact us.
Children’s privacy
The services are only available to persons 14 years of age or older. Bounce does not knowingly process personal information from children under the age of 14, unless a parent or legal guardian has consented. If you believe that personal information has been collected from children under the age of 14 without your prior consent, you may contact Bounce as described in the “How to contact us?” section.
11. What are your rights?
Depending on applicable laws, you may be granted certain rights with respect to the personal information under our control or custody. For example, you may be entitled to:
- To obtain access to the personal information we hold about you;
- To correct personal information we hold that is inaccurate, misleading or incomplete;
- To obtain additional information, for example on the categories of third parties to whom we communicate 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.
- To refuse promotional communications from Bounce;
- To file a complaint with the Privacy Officer of Bounce 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.
- To request that your personal information be deleted. When doing so, we will delete or anonymize all data we collected about you, but certain information might be kept for compliance purposes for a certain period of time.
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, whose contact information is provided below. 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 will endeavour to process your request within 30 days from the date your request is received. We will inform you if this timeframe is not achievable and extend this timeframe as permitted as applicable law.
12. Changes to this policy
We may review this Policy from time to time to comply with applicable laws and our operations. If we update this Policy in a meaningful 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 services or your continued use of our services will suffice as notice and consent to the Policy changes.
13. How to contact us?
Please feel free to contact us with any questions, inquiries, comments, or complaints regarding your personal information. To do so, we invite you to contact us at the following address:
Privacy Officer
Place Ville Marie # 12102
Montréal, QC
H3B 3Y1
privacy@bouncepay.ca