1. Who we are
Noble Shift (“Noble Shift”, “we”, “us” or “our”) provides financial-learning programs through our website and member portal. This Privacy Policy applies to our website, member portal, programs and communications (together, our “services”).
We handle personal information in line with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws. We are responsible for the personal information under our control and have designated a Privacy Officer, who can be reached at info@nobleshift.ca.
2. Information we collect
Identity and contact information
- Full name, email address, phone number and mailing address
- Date of birth and province or territory of residence
- Government-issued photo ID, where we ask for it to confirm your identity
Banking and income information
- Bank account details, income information and transaction history, accessed on a read-only basis through a secure bank verification provider with your permission
- Pre-authorized debit details, handled by our payment processor
We do not receive or store your online banking username or password.
Program and account information
- The program and payment schedule you choose, your payment history and the status of your enrollment incentive
- Your activity in the member portal, such as lessons completed
- Messages you send us and records of our conversations with you
Website and device information
- IP address, browser and device type, pages visited and the site that referred you, collected through server logs, cookies and similar technologies
3. How we use your information
We use personal information to:
- confirm your identity and eligibility and review your application;
- set up and administer your membership and payment schedule;
- send your enrollment incentive;
- process scheduled payments and manage returned payments or amounts owing;
- provide the member portal, program content and customer support;
- send messages about your account and, with your consent, newsletters and offers;
- prevent fraud and keep our services secure;
- improve our programs and website; and
- meet our legal, tax and record-keeping obligations.
We do not sell your personal information. If a credit check is ever part of reviewing your application, we will ask for your consent first and tell you whether it could affect your credit score.
4. Your consent
When you enroll, you give your express consent to the collection, use and sharing of your personal information as described in this policy, including the bank account verification described in section 2. When you browse our website, we rely on your implied consent for the basic website information described above.
You may withdraw your consent at any time by contacting us, subject to legal or contractual restrictions and reasonable notice. If you withdraw consent, we may not be able to continue providing some or all of our services.
5. How we share information
We share personal information only as needed to run our services, with:
- Service providers who act on our behalf, including providers of payment processing, bank account and identity verification, e-Transfer delivery, email and text message delivery, website hosting, customer support and analytics. They must protect your information and may use it only to provide their services to us.
- Authorities and others where required by law, for example in response to a court order or to prevent fraud.
- A successor business, if Noble Shift is involved in a merger, acquisition or sale of assets, under confidentiality obligations.
6. Storage outside your province or Canada
Some of our service providers, such as our website host, may store or process personal information outside your province or outside Canada, including in the United States. While it is there, it may be accessible to courts, law enforcement and national security authorities under the laws of that jurisdiction.
7. Cookies and similar technologies
We use cookies and similar technologies that our website and member portal need to work, and we may use analytics tools to understand how our website is used. Our website also loads content, such as web fonts, from third-party providers, who receive your IP address when your browser requests it. You can block or delete cookies in your browser settings, although some features may not work without them.
8. How long we keep information
We keep personal information for as long as your membership is active and afterwards for as long as needed to meet the purposes it was collected for, including legal, tax, accounting and record-keeping requirements and the resolution of any dispute. When it is no longer needed, we securely delete it or make it anonymous.
9. How we protect information
We use administrative, technical and physical safeguards suited to the sensitivity of the information, including encryption in transit and access limited to people who need it to do their work. No method of transmission or storage is completely secure, so please contact us right away if you suspect unauthorized access to your account.
If a privacy breach creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as required by law.
10. Your rights
You have the right to:
- ask what personal information we hold about you and receive a copy of it;
- ask us to correct information that is inaccurate or incomplete;
- ask how your information has been used and with whom it has been shared; and
- withdraw your consent, as described in section 4.
To make a request, contact our Privacy Officer at info@nobleshift.ca. We may need to confirm your identity first. We will respond within 30 days, or tell you if we need more time as the law allows.
If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada or, where applicable, your provincial privacy commissioner.
11. Marketing choices
We send newsletters and offers only with your consent. You can unsubscribe at any time using the link in any email or by replying STOP to any text message. You will still receive messages needed to administer your membership.
12. Minors
Our services are intended for people who have reached the age of majority in their province or territory. We do not knowingly collect personal information from minors.
13. Changes to this policy
We may update this Privacy Policy from time to time. We will post the updated version on this page with a new “last updated” date and will notify active members by email of any significant change.
14. Contact us
Privacy Officer, Noble Shift
Email: info@nobleshift.ca