BLUE REWARDS PROGRAM PRIVACY POLICY

INTRODUCTION

The Blue Rewards Program (or the “Program”) is a loyalty reward program owned and operated by BMO Blue Rewards, Inc. ("us", “our”, or “we”). We focus on rewarding Canadians every day.

When Members of the Program (“Members” or “you”) transact with partners and suppliers and participate in the Program, you can receive points (“Points”), offers, and other benefits. 

AFFILIATES, PARTNERS & SUPPLIERS

Any reference to “We” or “Our” includes our affiliates such as Bank of Montreal and BMO Financial Group (collectively “BMO”).

“Partners” are businesses and organizations that give you Points or benefits, or both. Examples may include retail stores that issue Points, a service provider offer, a Partner offer, or a consumer packaged goods manufacturer that provides coupons or samples.

“Suppliers” are businesses that provide the Program with products and services that help make it work, like reward fulfillment (by companies also referred to as rewards partners), marketing, promotions, data processing, analytics, data storage, or research.

By participating in the Program, you understand and acknowledge that we and our affiliates collect, use and disclose your Personal Information as described in this Privacy Policy.

1. ACCOUNTABILITY – WHO IS RESPONSIBLE FOR PRIVACY?

The Program’s Privacy Office is led by the Chief Privacy Officer, who is responsible for the establishment of the Program’s privacy management program, including policies and practices for collecting, using, disclosing, and protecting Personal Information, and responding to requests for Personal Information.

The Program’s Data Governance Office is responsible for the implementation and management of policies, practices, and procedures for collecting, using, and disclosing Personal Information, including data usage and controls. 

The Program’s Information Security Team is responsible for the implementation and management of technological, physical and organizational safeguards that protect Personal Information.

2. PURPOSES – WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

Personal Information is information about an identifiable individual (“Personal Information”).

We collect your Personal Information so that you can participate in the Program and benefit from all that we, our affiliates, our Partners, and our Suppliers have to offer.

The purposes for which we collect Personal Information include:

   i. Administering and operating the Program

Examples of administering the Program include:        

• Processing your enrollment in the Program
• Managing and updating your Program account to accurately reflect Program activities in your Program account, including the Points you have collected and the rewards and benefits you have received
• Marketing, managing, processing and fulfilling Program reward redemptions and benefits
• Detecting and suppressing fraud within and related to the Program

   ii. Enabling you to participate in marketing and promotional opportunities

Examples of marketing and promotional opportunities that are available to you from time to time include:

• Online and offline marketing, advertising, and promotional activities of products and services that may be of interest to you, including those of our Partners, affiliates and third parties we select
• Contests
• Events

   iii. Communicating administrative information to you

Examples of communicating information and offers to you include:

• Confirming reward orders
• Sending administrative notifications
• Responding to inquiries made via telephone, email, SMS/text or direct mail

   iv. Delivering marketing and promotional content about products, services, rewards, and offers to you on behalf of the Program, its Partners, its Suppliers, our affiliates and third parties we select.

Examples of how marketing and promotional content is delivered to you include through:

• Email
• SMS or text messages
• Promotional updates during an inbound call to the Customer Care Centre
• Banner or interstitial notifications on the Program’s websites or applications
• Social media and advertising platform advertisements, for example, advertisements on Facebook or Google

   v. Analyzing and developing insights from (i) your participation in the Program, (ii) transactions with Partners, affiliates and Suppliers, and/or (iii) your digital interaction with the Program, its Partners, its Suppliers and our affiliates.  

Examples of how the Program analyzes and develops insights include:

• Conducting market research to understand your needs, preferences, and interests and the development of tailored offers, products, services, programs, and events to meet those needs, interests and preferences
• Measuring the effectiveness of marketing and promotional content presented to you on behalf of the Program, its Partners, its Suppliers and our affiliates.
• Improving offline and digital experiences based on how you interact with the Program, including through online and application activity. For more information please review the Digital Privacy Policy. Specific terms apply when you use the Program’s websites, including bluerewards.ca and earnmore.bluerewards.ca, and the Blue Rewards application.

3. CONSENT

When you enroll in the Program, we obtain your consent to use your Personal Information for the purposes described in this Privacy Policy. Information about this is also found in our Terms & Conditions. The amount and the type of Personal Information we collect is limited to what is necessary to fulfill the purposes of the Program and this Privacy Policy. We will obtain your consent before we use your Personal Information for any new purpose.

What happens if I want to withdraw my consent?

• Withdrawing your consent for the Program to use or disclose any of your Personal Information for marketing and promotional communications entirely or through a specific channel, like email, does not affect your ability to get rewards or benefits, or redeem for rewards or other benefits. It may impact the kind of marketing communications you receive, the channels that the Program uses to communicate with you, and offers that may be made available to you.
• Withdrawing your consent from the Program to use or disclose any of your Personal Information for any purpose whatsoever means that you will not be able to participate in the Program, including getting Points and redeeming Points for rewards and benefits. If you choose to withdraw your consent for the Program to use any of your Personal Information for any purpose whatsoever, you can:
  • use your Points for rewards or benefits before withdrawing your consent;
  • donate your Points to one of the charitable organizations that the Program supports; or
  • transfer your Points to another Member in accordance with the Terms & Conditions of the Program.

To withdraw consent for the use of your Personal Information for marketing, you can email the Privacy Office, call the Program’s Customer Care Centre (1-888-247-6453) or update your preferences in the Program website or application.

You can withdraw your consent for the use of your Personal Information for certain purposes; however, if you withdraw consent to use your Personal Information for all purposes, you will not be able to participate in the Program.

• To opt-out of marketing emails from us, you can unsubscribe from a marketing email you have received or respond to an SMS with “STOP”, by changing your preferences in our Blue Rewards application, or you can contact us.
• If you unsubscribe from the Program, you may still receive emails from Partners or other third parties due to your consent or communication preferences with those organizations. You must follow the instructions set out in their respective privacy policy to withdraw your consent.
• To opt-out of direct mail, please contact us
• To opt-out of digital interest-based advertising, please see our Digital Privacy Policy
• To withdraw from the Program completely or to delete your account, please contact us

To change your contact information, please log-in to your Blue Rewards account to update your profile. If you are concerned that your Personal Information held by us is inaccurate, please contact us. If your concern is not resolved, please contact the Privacy Office.

If you withdraw your consent, there may be a short time between the withdrawal of your consent and when the change takes effect as a result of internal operational processes.

4. LIMITING COLLECTION

Both the amount and the type of your Personal Information that is collected is limited to what is necessary to fulfill the purposes of the Program as identified in this Privacy Policy. Examples of instances where we collect Personal Information from you and the kind of information we collect include:

• When you enroll in the Program
  • When you enroll in the Program, we collect information that you provide when completing the enrollment form, like first name, last name, date of birth, email address, address, city, province and postal code and your loyalty number from other loyalty programs if you’ve provided it and want to link your other loyalty card with your Program number.
• When you make a purchase from, receive a benefit from, or use the services of a Partner and use your Program card or number
  • When you make a purchase, receive a benefit from, or use the services of a Partner and you use your Blue Rewards card or number, we may collect information about the transaction, including the transaction date and time, the products and/or services purchased, your email address and number of Points earned. This type of information is also generated by your use of a Card Offer and may include information about your purchases.
• When you use or redeem Points
  • When you use your Points, or redeem Points, we collect information about the reward you have selected. In some cases, we collect address and contact information required for fulfillment, and any other information required to fulfil the redemption.
• When you interact with the Program, its Partners, its Suppliers, our affiliates, in person, online, in applications, or through other electronic or digital Program features
  • We collect information when you interact with our websites, the application, emails from us and our Partners, our social media accounts and online ads, and through the use of tracking technology. Tracking technology includes cookies, beacons, pixels and the use of Data Management Platforms (DMPs). The information collected from these sources allows us to better understand how you interact with the Program online and on the application. Examples of information collected includes the date and time of your visits, the devices you use while browsing, content you have viewed, and, if applicable, transactions you complete.
  • If you use the application and your geolocation settings are on, we collect geolocation data from your device. You can change the geolocation settings on your device; however, certain personalized features of the application may no longer work.
  • Specific terms apply when you use the Program’s websites, including bluerewards.ca, earnmore.bluerewards.ca, microsites created by or for the Program, and the Blue Rewards application.
  • For more information, please see our Digital Privacy Policy.
• When you provide your Personal Information to a Partner or a Supplier in connection with the Program
  • When you use your Program card at or through other Partners’ point of sale locations, information about your transaction will be shared with BMO, Blue Rewards and Partners. This typically includes transaction date, time, merchant point of sale location, amount spent, email address and details of products or services purchased.
• When you call our Customer Care Centre
  • When you contact us with a comment, question or concern through telephone, you may be asked for information that identifies you, such as your name, Program number, and date of birth, along with any additional information we need to help us promptly answer your question, respond to your comment, or resolve your concern.
• When you complete an optional survey sponsored by the Program, a Partner, an affiliate or a Supplier
• When you participate in marketing and promotional activities, opportunities and events.
  • An example of participating in a promotional opportunity includes entering a contest that is sponsored by the Program by completing and submitting the information required in the contest entry form.

5. LIMITING USE, DISCLOSURE & RETENTION – WHY WE SHARE YOUR PERSONAL INFORMATION

We use your Personal Information for the purposes described in this Privacy Policy, including:

• If you’re a Blue Rewards member, BMO may use your personal information to deliver tailored offers and member benefits that provide value to you. This includes the use of your Personal Information in combination with other information collected from affiliates, Partners and Suppliers. For example, by understanding which goods and services you purchase from Partners, we and our Partners are better able to personalize offers for goods and services that may be of interest to you.
• The use and sharing of your personal information to improve our Program and provide you with relevant offers through analytics, and to serve you advertisements. For example, we may share your hashed email address with social media providers to make relevant offers to you on their platforms. When you use the Program, we will use your transaction history to personalize your experience by presenting you with tailored offers, recommendations, and marketing.

We do not use or disclose your Personal Information for purposes other than those for which it is collected without your consent, except as set out below or as required or permitted by law.

We retain your Personal Information only for as long as it is needed to fulfil the Program’s purposes or as otherwise required to meet legal or business requirements.

We do not disclose your Personal Information to any organization or individual other than the Program and our affiliates, or Partners and Suppliers of the Program, to fulfill the Program’s specified purposes, or as otherwise set out in this Privacy Policy.

Partners may use this information as described in their privacy policies, including:

• To better understand your product and service needs and to offer relevant information, products, services, rewards and programs, and advertising to meet those needs, including sending you communications by way of postal mail, e-mail, telephone, text message, or other type of electronic message; 
• track and analyze your purchases with that Partner, other transactions, shopping patterns, account activity, and payment history for marketing analysis purposes, and to tailor promotional offers to you or provide you with relevant advertisements through our advertising partners and platforms.

We may use your personal information to identify products that may be of interest for you, develop our relationship with you, and analyze and improve our services, website, app, and offerings. We achieve these purposes by analyzing your use of the Program, and your interactions with our website, app, and advertisements.

We may also use your personal information to generate aggregate and anonymous information and reports, lists or other data, created from our analysis of information we hold about you, including device ID, information we may collect about you through your enrollment and participation in the Program (including earning or redeeming points) and information we collect from our Partners (“Reports”). We may share Reports with our Partners. Partners may see relevant insights from your transactions, such as your interests, but they will not receive transaction-level data. The information is used to enable Partners to market their products and services to you, and (if de-identified), to improve their products, services and operations.

Please review the policies of participating Partners to learn more about their privacy practices.

 You should consult the privacy policies of Partners directly for information on how Partners collect, use, and disclose Personal Information and transactional information.

We may transfer any Personal Information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Blue Rewards or as part of a corporate reorganization or other change in corporate control.

We and our Suppliers are primarily based in Canada and the US. From time to time, there may be circumstances where your Personal Information could be processed or stored outside of your home province or Canada. For example, a Supplier may have a support function for travel services that is operated in Egypt, or a Supplier may move its support function to another province or country outside your home province or country. Safeguards and technical measures are applied in these circumstances.

We have contracts in place holding these Suppliers to the same standards of confidentiality by which we are governed. There may also be legal reasons that Personal Information is disclosed to law enforcement or other organizations.

Your Personal Information may be provided by us or a Supplier in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.