Flinks allows you to share your bank account details and transaction history, among other financial information, in order to receive financial or other related goods and services from our clients. This Privacy Statement provides information as to Flinks and its affiliates’ (“Flinks”, “we”, or “us”) practices as it relates to the collection, use, disclosure, storage, or destruction (collectively referred to as “process” or “processing”) of personal information (i.e., identifiable information about you) Flinks receives in connection with your use of any of our clients’ services that use Flinks.
This Privacy Statement has been divided into the following sections to explain:
This Privacy Statement applies to the processing of personal information by Flinks when you connect your bank or other financial account, using Flinks, with our clients’ services.
The Flinks Services Privacy Statement applies to the following services:
This Privacy Statement does not apply to the following activities:
Flinks processes the followingtypes of personal information when it provides its services to its clients:
Information you provide through Connectivity. When you connect your financial account(s), you will provide your login information required by your financial institution to access your account. Typically, this consists of a username and password, but it could also include answers to challenge questions (e.g., a family member’s name or maiden name, street you grew up on), or a security token (e.g., multi-factor authentication code or one-time pad (OTP)). Information you provide may also consist of digital copies of bank statements, cheques, or other financial documents where you are sharing these types of documents through Flinks Connectivity with one of our clients.
Information obtained from your financial institution. When Flinks connects to your financial account for the purposes of our clients’ services, we retrieve information from such financial institution that maintains the account(s). The information we retrieve may vary depending on:
Regardless of the types of information our clients require, the types of information we collect from your financial institutions will include, without limitation:
Information from your payroll or paystub provider. In addition to the ability to connect to your financial institution through our Connectivity Service, Flinks also has the ability to connect to your payroll or paystub provider. This allows Flinks to provide its clients with an up-to-date picture of your sources of income in addition to what is available from your financial institution.
Information you provide through Flinks Pay. Whether accepting an Interac e-Transfer Request for Money or entering into a pre-authorized debit (PAD) agreement with one of our clients for electronic fund transfers (EFTs), you will be required to provide certain information, namely:
This information may be collected directly by our clients, or for EFTs, through our Connectivity Service to help populate a PAD agreement and signing an electronic or paper copy of the PAD agreement.
Information from your devices. Our technology is integrated as part of our clients’ services. Thus, when you use one of your devices to connect with a client service, we may receive information about this device, including without limitation the IP address, hardware model, operating system, and other technical information about the device. We may also use cookies or similar tracking technologies to collect usage statistics and to help us improve our services.
As a service provider to our clients, Flinks has no direct relationship with you, the end-customer. As such, our clients are responsible for obtaining the necessary consent(s) from you to process your personal information for the purposes associated with providing you with their goods or services, including your consent that authorizes Flinks to (i) collect Information you provide and (ii) collect and share Information from your financial institution with our clients, and (iii) collect and share Information you provide through Flinks Pay. Flinks does have a consent screen available to clients through Flinks’ Connectivity service that takes steps ensure you understand who Flinks is and how we process your personal information. For further information as to why you have been directed to Flinks, and for what purposes the personal information Flinks receives and provides to its clients will be used for, please refer to the privacy practices and policies of the business who uses our services.
Collection of Personal Information of Children
Flinks does not market or target its services towards children (individuals under the age of 16), or any individual for that matter. Flinks is a business-to-business service provider, and as such, Flinks will not knowingly collect or ask for personal information belonging to children. Should a child connect a financial account with one of the services of Flinks’ clients, Flinks relies on the steps taken by its clients to ensure that the proper consent(s) are obtained from a parent or guardian, as Flinks will have no direct customer relationship with the child.
When we receive personal information from you, or from your financial institution related to you, we use your information for the following purposes:
Where our clients use Flinks’ Enrichment service, we will also use your personal information to derive certain insights or make certain inferences related to your financial position. Through our Enrichment product, Flinks is able to derive insights and inferences from the Information from your financial institution in order to help our clients in gaining insights into things such as:
These insights only apply to those clients who use Enrichment. If you are uncertain whether or not the service that directed you to Flinks uses Enrichment, please reach out to the company whose services you used that uses Flinks, or refer to their privacy policy to understand how they may be using Enrichment.
When you use Flinks’ Connectivity service to share your financial information with our clients (i.e., the organization with whom you have a direct relationship with that uses Flinks), depending on the type of connection that needs to be made with your financial institution, you may be providing Flinks with your account credentials to access your bank account.
As a starting point, your credentials are never shared. With anyone.
Due to the sensitive nature of the Information you provide and Information obtained from your financial institution, Flinks does not share any of your personal information with anyone other than our client whose service(s) you are using and have authorized to receive your financial information, with our service providers for the purposes of providing our clients with our services (as outlined in Our Use of Service Providers below), and as required or permitted by law (e.g., in the event Flinks must comply with a court order or is required to disclose information to protect an individual from serious or life threatening harm). In the event a part of Flinks, or all of Flinks is acquired or merged with another business, the license(s) or ownership associated with the services we use to process your personal and financial information, and any other such information Flinks processes, may be transferred to the new entity.
For Flinks Pay, Flinks will share the Information you provide through Flinks Pay with the following organizations for the purpose(s) listed:
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Organization |
Purpose(s) |
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Peoples Group |
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Interac |
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ComplyAdvantage |
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Flinks’ Third Party Auditors |
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Where Flinks has reason to believe that a suspicious or illegal transaction has occurred through Flinks Pay that may violate the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) or other applicable law(s), Flinks will report information about you and any associated transaction(s) to the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) and any other law enforcement or regulatory body as required, as well as Flinks’ parent company, National Bank of Canada (“National Bank”) as part of Flinks’ ongoing risk management and reporting obligations to National Bank.
We will store the Information you provide and Information obtained from your financial institution for as long as it is necessary to provide our clients with our services. Depending on our clients’ use case(s) for Flinks’ services, the duration for which we store your personal information may vary.
Flinks uses industry leading service providers to process your personal information (also sometimes referred to as “subprocessors”). At no point will these service providers exercise any control over how personal information is used. With all of our service providers, contractual provisions and technical measures are in place to ensure that, among other things, your personal information is stored in secure environments, that the confidentiality of your personal information is maintained, and that no employees of our service providers may access the environments containing your personal information except with the express authorization from Flinks for the purposes of carrying out maintenance or support and under confidentiality terms equal to the confidentiality terms Flinks has entered into with its clients. Flinks uses the following categories of service providers in the provision of its services:
For residents of the Province of Québec, this may mean that your personal information is stored in data centres located outside of the province. Should you wish to learn more about the service providers we use, please contact Flinks’ Privacy Officer.
To learn more about how we store and protect your personal information, please visit our Security page.
Depending on where you reside, you may be entitled to exercise certain rights with respect to your personal and financial information. At Flinks, we want all of our clients’ customers to have equal privacy rights, and that’s why no matter where you reside, we will use our best efforts to afford you the same rights as others, even where we aren’t required to.
Specifically, Flinks recognizes that individuals have the following privacy rights:
Because Flinks has no direct relationship with you in providing our Services to our clients, we ask that you direct your request(s) that are related to Flinks’ processing of your personal information to the client with whom you have connected your financial account with. In your request to them, please be sure to copy Flinks’ Privacy Officer on your e-mail ([email protected]) and indicate:
If you are unsure of who to contact in order to make your request, please reach out to Flinks’ Privacy Officer and they will be able to assist you in facilitating your request.
You may be asked by our client to verify your identity by answering some questions (e.g. name, e-mail address registered with client, or other identifying information). Flinks may also request that your identity first be verified before processing your request. In the event Flinks receives a request from a parent or guardian on behalf of an individual, Flinks or our clients may also ask for further information to prove the relationship before facilitating the request.
Our clients have the capability to fulfill any of your requests as it relates to Your Rights and the personal information processed by Flinks through our services. Where our clients require assistance in fulfilling any request, we will provide the necessary assistance to fulfill your request. While our clients are responsible for facilitating your requests, Flinks’ Privacy Officer will nonetheless endeavour to assist in making sure your request is processed within 30 days of your request being received and may notify you once your request has been completed. If an extension is required to respond to or facilitate your request, Flinks’ Privacy Officer or the organization using Flinks’ services will inform you of such an extension and the reasons for it nevertheless within the first 30 days.
Flinks reserves the right to refuse to address requests, questions, or complaints if, in the opinion of Flinks’ Privacy Officer, such request, question, or complaint is vexatious, unfounded, or repetitive in nature.
For any of Your Rights listed above, or any other inquiries related to this Privacy Statement or other privacy-related inquiries related to Flinks or its services, please direct all inquiries to Flinks’ Privacy Officer at [email protected].
This Services Privacy Policy was last updated on April 19, 2024. From time to time, Flinks may update this Services Privacy Policy to reflect changes to Flinks’ services or purposes for which Flinks processes personal information, or to comply with new legal requirements.
Whenever Flinks makes an update to this Policy, Flinks will update its website to provide notice that changes have occurred, and direct individuals to the updated Services Privacy Statement.