Last revised September 2016
The purpose of this Privacy Statement is to inform you about the types of Personal Information that Zoompass (as follows, "Zoompass" "we" or "us") collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.
We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act.
The following topics will be covered in this Privacy Statement:
To which companies does this Privacy Statement apply?
This Privacy Statement applies to the collections, uses and disclosures of Personal Information by Zoompass.
What is Personal Information?
"Personal Information" is any information that is identifiable with an individual, like you. This information may include but is not limited to your name, mailing address, mobile phone number, email address and banking information. Personal Information, however, does not include the name, business title or business address and business telephone number in an individual's capacity as an employee of an organization. Also, we do not consider personal information to include information that has been anonymized (such as card proxy numbers) so that it does not identify a specific user.
How do we collect your Personal Information?
We will always collect your Personal Information by fair and lawful means. We will collect Personal Information from you and from third party service providers, where we have obtained your consent to do so or as otherwise permitted or required by law.
When you visit the Zoompass website (the " Website ") and you open an account to use the Zoompass services (the " Services "), we collect the types of information identified in the registration form provided during the account opening process. This information will include:
- Your contact information - your name, address, mobile phone number, home phone number, email, and other similar information.
- Your financial information - the bank account numbers that you link to your Zoompass account.
Before permitting you to use our Services, we may require you to provide additional information we can use to verify your identity or address or manage risk, such as your date of birth. We may also obtain information about you from third parties such as identity verification services and credit bureaus. The purposes of third party questionnaires (such as through Equifax) is solely to identify your identity and used strictly as per the terms and conditions provided to us by identity verification services and credit bureaus. When you are using our Service, we collect information about your account transactions for the purpose of providing you with your transaction history and to otherwise provide information back to you – for example, in response to your inquiry, and we may collect information about your computer or other access device for the purpose of determining whether you can download and use the Zoompass mobile application. We may also collect aggregates of expenditure in certain market sectors or specific merchants for the purposes of marketing; however this data will never include any personal individual information. Finally, we may collect additional information from or about you in other ways not specifically described here, but in each case to the extent that we have obtained your consent to do so or as otherwise permitted or required by law. For example, we may collect information related to your contact with our customer support team or results when you respond to a survey.
When you access our website, we, or companies we hire to track how our website is used, may place small data files called "cookies" on your computer. In general, we use these cookies to collect your IP address and standard web log information, such as your browser type and the pages you accessed on our website, in order that Zoompass may track and generate reports, in each case on a non-identifiable basis. More specifically, we send a "session cookie" to your computer when you log in to your account. This type of cookie helps us to recognize your computer and records the time and date you logged in, and ensure that you are free to navigate the website once you have logged in. Once you log out or close your browser, this cookie expires and no longer has any effect. We also use longer-lasting cookies for other purposes such as to display your e-mail address on our sign-in form, so that you don't need to retype the e-mail address each time you log in to your account.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website.
Where do we store your Personal Information?
The Personal Information we collect will be primarily held on our behalf at a third party data centre in Toronto and subject to limited access by Zoompass personnel as required for the Purposes (as defined below). In addition, we may send Personal Information outside of the country for the Purposes, including for process and storage by service providers, and you should note that while such information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
While our service providers may, from time to time, also hold your Personal Information in connection with purposes for which you provided your consent or as otherwise permitted or required by law, we remain responsible, and remain the contacts for, such information.
How do we use your Personal Information?
We identify the purposes for which we use your Personal Information at the time we collect such information from you, and obtain your consent, in any case, prior to such use, as well as otherwise permitted or required by applicable law. In the case of your Zoompass account, we generally use your Personal Information for the following purposes (the "Purposes"), in each case to the extent that you consent to same: (i) to open and administer your Zoompass account, including for identity verification and risk management, (ii) to process, and send notices regarding, your transactions; (ii) to assist you with technical support; (iii) to gather your opinion and feedback through surveys; (iv) to enroll you in our contests or promotional programs; (v) to include you on our mailing list for targeted marketing or promotional offers; (vi) to collect aggregate expenditure data for a specific market sector or merchant; (vii) for such purposes as for which we have obtained your consent, and otherwise to the extent required or permitted by applicable law.
To whom do we provide your Personal Information?
We identify to whom, and for what Purposes, we disclose your Personal Information at the time we collect such information from you and obtain your consent to such disclosure.
For example, we may disclose your Personal Information to:
- A potential acquirer, etc., and their representatives, in connection with a transaction involving the sale/merger/reorganization, etc. of some or all of the business of Zoompass;
- Third partiesto which, and for the Purposes for which, you may otherwise consent; and
- As otherwise permitted or required by applicable law.
We will not disclose your bank account number to anyone you have paid or who has paid you through Zoompass, except with your express permission or as required or permitted by law (for example, in order to comply with a subpoena or other legal process);
Website Links to other Sites
Some of our websites may contain links to other sites. We are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they are leaving our site and to read the privacy statements of each website that collects personally identifiable information.
When and how do we obtain your consent?
We obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing.
How do we ensure the privacy of your Personal Information when dealing with our affiliated and other third parties?
How long will we utilize, disclose or retain your Personal Information?
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the Purposes for which that Personal Information was collected and as permitted or required by law.
How can you review your Personal Information that we have collected, utilized or disclosed?
If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes. You can review and edit certain Personal Information (that is, address, email address, home phone number, and bank account information) at any time by logging in to your account and clicking the My Profile tab.
How do you know that the Personal Information we store about you in accurate and how can you inform us of updates?
We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We do not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required. Mechanisms Zoompass uses to ensure accuracy and prevent fraud include conducting an identity verification process in connection with registering each Zoompass account.
At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. We may ask you for proof to confirm the changes in your Personal Information, especially when it relates to change of name. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
What safeguards have we implemented to protect your Personal Information?
We have implemented, as applicable:
- physical security measures (e.g. enforce physical access controls to our buildings and files);
- organizational security measures (e.g. the only personnel who are granted access to your Personal Information are those with a business 'need-to-know', including where their duties reasonably require such information);
- contractual security measures (e.g. providing Personal Information only to third parties which are contractually or otherwise bound to protect the information); and
- technological security measures (e.g. firewalls and data encryption) to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification.
Attn: Privacy Department
107 Atlantic Ave Unit 201
Toronto, ON M6K 1Y2