At Apt Pay Inc., we are committed to protecting your personal information and safeguarding it in every transaction, at every level of our organization. We are responsible for personal information that we hold and have designated individuals to be accountable for our compliance with applicable privacy and data protection laws.
Principle 1 – Accountability
Principle 2 – Identifying Purposes
Principle 3 – Consent
Principle 4 – Limiting Collection
Principle 5 – Limiting Use, Disclosure and Retention
Principle 6 – Accuracy
Principle 7 – Safeguarding Personal Information
Principle 8 – Openness
Principle 9 – Customer Access
Principle 10 – Handling Complaints and Suggestions
We always collect, use and disclose your personal information in a fair and lawful manner that is compatible with applicable privacy and data protection laws.
WHAT IS PERSONAL INFORMATION?
Personal information is information that can identify you, as an individual. This information includes your name, home address, home phone number, gender, date of birth, language preference, email address, credit card information, bank account information, account information with us, IP address or social media user name or identification.
Information about your business title, business address, business telephone number, business email address or business fax number is not personal information.
COLLECTION AND USE OF YOUR PERSONAL INFORMATION
We collect personal information directly from you, indirectly from third parties and otherwise as permitted by applicable law. Apt Pay limits the information we collect about our customers and potential customers to what we need for internal business purposes only.
The type of information we collect about you depends on the type of dealings you have with us. For example, if you:
- sign-up to purchase our services, we will collect your name, contact details, address and other information in order to enable us to provide you with access to our websites or our services;
- submit a request to us via email or through our websites, we will collect your email address, IP address, information about your location and any information you have included in the email or website form. We use your email address to acknowledge your request and/or reply to your questions;
- request information about our services or make a support request to us, we will collect your name, address, phone number, fax number and/or email addresses. This is for the purpose of contacting you for sales or support follow-up or, when you have specifically requested it, marketing or promotional materials about our services;
- request us to process a payment, we will collect your name, credit card number and other details required to verify the transaction. We restrict access to credit card information, and credit card numbers are not provided to merchants. In the event of a customer complaint or chargeback, transaction information will be provided to the merchant, bank or card issuer; and
- apply for a job with us, we will collect the information you include in your job application, including your cover letter, resume;
We may also collect and use your personal information on the basis of our legitimate business interests, which may include collecting anonymized statistical information regarding your customer’s use of our websites or services. We may also use your personal information to detect, prevent or investigate security breaches or fraud and to protect our business. Any time we use your personal information for these purposes, we will consider the effect of those uses and will not proceed if there is a material impact on your rights and freedoms.
We will identify the purpose for which we collect and use your personal information at or before the time the information is collected. We will obtain your consent prior to each specific use, except where consent is not required by applicable law. If we wish to use your information for any other purpose, and before collecting information from third parties such as credit bureaus, we will obtain your consent.
Providing us with your personal information is always your choice and you may withdraw your consent at any time. However, some services and areas of our websites may require you to provide us with your personal information. If you choose not to provide us with your personal information or withdraw your consent in those instances, you may not be able to receive the full benefit of those services or access certain parts of our websites.
WHAT IS A COOKIE?
A cookie is a small computer file or piece of information that may be stored in your computer’s hard drive when you visit our websites. On the Apt Pay website, cookies are used to increase robustness and to provide more efficient navigation. Cookies cannot view or retrieve data from other cookies, nor can they capture files and data stored on your computer.
Apt Pay also uses Google Analytics which is a set of integrated data-and-marketing analysis products that lets us analyze consumer behavior, develop relevant insights, and then provide a more engaging brand experience. Apt Pay’s use of Google Analytics is to collect top-level information about how you use our websites. Google Analytics provides the information we need to improve the user experience and serve up the content our visitors find most useful. The Google Analytics cookies store information about what pages you visit, how long you spend on our website, how you got there and what you click on.
Our cookies do not collect or store your personal information, so this information cannot be used to identify you. For an overview of privacy at Google click here.
If you would like to browse the Apt Pay websites, you may do so without accepting cookies. However, if you choose not to accept cookies, some areas of the Apt Pay websites may not function properly or optimally.
SHARING YOUR PERSONAL INFORMATION
- the purposes you where you have provided your consent;
- to financial institutions for processing payments;
- to our suppliers, third-party service providers or agents who assist us in serving you, including for telephone support or data storage or processing; and
- where we are required or permitted to do so by law.
Apt Pay does not sell or trade your personal information to third parties.
STORING YOUR PERSONAL INFORMATION
Where you have provided your consent, we may use your personal information to let you know about us and our products and services, including promotions, special offers and events. If you have consented to receive marketing or promotional materials, you may opt out at any time.
Where you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. However, you can opt out of marketing communications at any time, by:
- using the unsubscribe feature that we include in our electronic marketing messages, such as emails; or
- using any of our contact forms found on our websites; or
- contacting us via email [email protected] or
- by visiting https://www.aptpay.com/email-preference to choose your preferences.
PROTECTING YOUR PERSONAL INFORMATION
We do our utmost to protect and safeguard your personal information. However, as no data transmission over the internet can be guaranteed as completely secure, we cannot ensure or warrant the security of any information transmitted to us and you do so at your own risk.
We believe there are measures you should take as well to protect yourself against fraud and uninvited intrusion. For example, to ensure the passwords you use are encrypted and to not share personal information with others unless you clearly understand the purpose of their request. Apt Pay does not contact customers by email or telephone requesting to provide sensitive data such as your personal information, banking and credit card details, and passwords.
RETENTION OF YOUR PERSONAL INFORMATION
We will retain your personal information for as long as is necessary in order to manage our relationship with you, fulfill the purposes for which it was collected or as necessary or as permitted or required by law. At the end of this period, your personal information will either be deleted or anonymized.
You may make a request to us to access, update, delete or correct your personal information. You may also have the right to object to our processing of your personal information, request us to restrict the use or disclosure of your personal information or ask for your personal information to be provided to you in a structured, commonly-used and machine-readable format. Before Apt Pay is able to provide you with any information, correct any inaccuracies or otherwise respond to your requests, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavour to respond to your request within an appropriate timeframe and you will be provided with a written response.
Apt Pay relies on customers or users of our websites and services to provide accurate, complete and up-to-date personal information and to provide updates on changes to their personal information. Your personal information is also available on the “Company Info” section of our websites and you may update this information at any time.
If you have a question, request or concern about privacy, confidentiality or the personal information handling practices of Apt Pay, our employees or service suppliers, please contact us at:
ATTN: Apt Pay Privacy Officer
Toronto ON, M4W 3M5
email: [email protected]
Any complaint must be in writing. Within a reasonable time after receipt of the complaint, our Privacy Officer will conduct an investigation into the complaint. After the investigation, we will take appropriate measures to rectify the complaint, if required.
Within a reasonable time after conclusion of the investigation, our Privacy Officer will inform you of:
- the result of the investigation; and
- any appropriate measures we will take to rectify the complaint.
Alternatively, you may make a compliant to your applicable privacy or data protection authority, although they may decline to hear the complaint if you have not first made a complaint directly to us. Details of the applicable Canadian privacy commissioners can be accessed from here, while the equivalent EU authorities are listed here