ZERO BOOST PAYMENTS CORP., incorporation No BC1515420, at #250 - 997 Seymour St. Vancouver, BC, Canada V6B 3M1 (“COMPANY”), registered at FINTRAC as money service business under the No. C100000720, and its subsidiaries (“we”, “us”, “COMPANY”) are committed to maintaining the accuracy, confidentiality, and security of Personal Information.
We respect rights under applicable privacy laws and only collect, use, and disclose Personal Information in accordance with those laws.
This Privacy Statement describes the Personal Information we collect, use, and disclose in the course of providing services to our merchants, partners, and other customers, including payment processing services, value-added services or hardware and hardware support services, as well as information we collect from prospective customers, applicants, and website visitors.
If you are COMPANY merchant’s customer or a partner’s customer, please refer to the merchant or partner’s own privacy policy or reach out to them directly for more information about their privacy practices.
To learn more about privacy at COMPANY, please click on the applicable section below or download a PDF version of the complete Privacy Statement.
COMPANY’S PRIVACY MANAGEMENT PROGRAM
COMPANY maintains a comprehensive privacy management program (the “Privacy Management Program”) applicable to COMPANY and some of our subsidiaries, complete with policies, practices and standards addressing information security, and the collection, use, disclosure, storage, and destruction of Personal Information held by COMPANY.
This Privacy Management Program includes the following measures.
• Appropriate safeguards to protect the Personal Information that COMPANY collects, stores, and uses.
• Established processes for the maintenance of appropriate data management including classification, record keeping and disposal/destruction systems for Personal Information and their related uses.
• Established processes to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Privacy Statement and applicable privacy laws.
• Clearly established roles and responsibilities of business groups and individuals for the protection of Personal Information, and an accountability framework which is further described below.
• Yearly employee privacy awareness training.
• Regular assessments, audits, and revisions of our privacy practices to ensure they meet or exceed applicable legislative requirements, internal policies, industry standards and best practices.
• A process for the maintenance of a privacy incident management and reporting methodology for incidents involving the unauthorized collection, use or disclosure of Personal Information.
Respective teams also play key roles in COMPANY’s Privacy Management Program by ensuring that appropriate safeguards to protect the Personal Information (and other data) that COMPANY collects, stores and uses are in place and effective.
WHAT PERSONAL INFORMATION WE COLLECT
From Existing and Prospective Merchants, Partners, and Other COMPANY Customers
COMPANY may collect the following Personal Information from existing merchants, prospective merchants, partners, and other COMPANY customers, to open and manage accounts, and to provide various products and services.
• names
• roles or positions
• financial information
• mailing addresses
• email addresses
• telephone numbers
• birth dates
• banking information
• recordings of calls to our call center to better serve our customers, ensure quality control, and for training purposes
• information about complaints
• certain other information that COMPANY may collect with appropriate consent
We may obtain consent to collect personal and credit information from a credit reporting agency (including credit score).
In limited circumstances, COMPANY may seek consent to collect social insurance numbers to confirm identities with credit reporting agencies.
As a Service Provider to our Merchants, Partners, and Customers
When acting as service provider to merchants, partners, or other customers, COMPANY may have access to the Personal Information of their end-users (for example their payment card data).
In such circumstances, COMPANY relies on its merchants, partners, and other customers to ensure that they have the necessary authority and consent required by applicable privacy laws to provide their end-user’s Personal Information to COMPANY.
If you are a COMPANY merchant or partner’s customer, please refer to the merchant or partner’s own privacy policy or reach out to the merchant or partner directly for more information about their privacy practices.
From Website Visitors
COMPANY also collects information from visitors to our websites.
These practices are described under the heading “Cookies, interest-based advertising, and website data” below.
HOW WE COLLECT PERSONAL INFORMATION
COMPANY may collect Personal Information in several ways.
Information provided directly to COMPANY
COMPANY collects Personal Information through its websites (for example through cookies), as well as information directly provided via email, in person, or by phone, including where a person contacts our customer service lines or submits an inquiry.
COMPANY also collects information as part of providing products and services, from applications for services by existing and prospective merchants, applications for employment opportunities, and in relation to adjudication and onboarding processes.
Information about COMPANY merchants or potential merchants received through third parties
COMPANY collects Personal Information that we receive from third parties, such as credit reporting agencies, financial institutions and references provided by its merchants as part of onboarding and offering merchants products and services, including to continue to understand our credit risks.
COMPANY also receives information about prospective and existing merchants from its partners, including sales and referral partners.
Information received through COMPANY merchants, partners and other customers about their customers
As a service provider to COMPANY merchants, partners and other customers, COMPANY may have access to Personal Information that we receive from merchants, partners, and other customers as part of credit or debit transactions and related value-added services.
Information about job applicants from third parties
COMPANY collects the Personal Information of certain job applicants from their references and from service providers performing background checks such as credit and criminal record checks.
THE PURPOSES FOR WHICH WE USE PERSONAL INFORMATION
COMPANY uses Personal Information for the following purposes.
• to provide products and services (including support) for our merchants, partners, and other customers
• to assess the financial situation and credit risk rating of our merchants by collecting credit and other financial information from credit reporting agencies, financial institutions, and from references provided by our merchants (as part of the onboarding process and in relation to the ongoing provision of products and services)
• to meet obligations related or owed to credit and debit card issuers, payment card network associations (for example Visa, MasterCard, and Interac) or regulators (for example Bank of Canada, Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), or the Financial Consumer Agency of Canada (FCAC))
• to safeguard our products, services, systems, data and otherwise protect merchants, partners, and other customers in their dealings with COMPANY
• to detect and investigate potentially fraudulent or otherwise questionable activities linked to merchant accounts or use of other COMPANY services
• to respond to customer inquiries and investigate disputes
• to communicate with COMPANY merchants, partners, and other customers (for example via email or text message) to offer additional products and services that COMPANY believes might interest them
• to evaluate applications for employment at COMPANY
• to create aggregated, de-identified or anonymized data
• to maintain quality customer service
• as otherwise required or permitted by applicable laws and regulations
HOW WE DISCLOSE PERSONAL INFORMATION
Before COMPANY discloses Personal Information to a third party, COMPANY ensures that the information will be safeguarded by appropriate information security practices, contractual provisions, and considers the legal framework of the jurisdiction where the Personal Information resides, in addition to other practices and considerations designed to protect Personal Information.
Further, COMPANY only discloses Personal Information to the extent required for third parties to perform their designated functions and those third parties are not authorized to use or disclose that Personal Information for their own purposes (for example marketing).
Third Party Service Providers
COMPANY may disclose Personal Information to third party service providers to provide merchants, partners, and other customers with a variety of products and services.
In some cases, our third party service providers may provide COMPANY with services, in other cases they may provide services on behalf of COMPANY.
COMPANY may disclose Personal Information in relation to the following services.
Technology services
COMPANY may disclose Personal Information to certain providers of technology software and services, including cloud providers (for example for email, infrastructure, webhosting and storing data including call recordings), customer relationship management solutions, advertising, analytics and marketing providers, and call center solution providers.
Financial services
COMPANY may disclose Personal Information to certain financial service providers such as collection agencies, debit and credit card issuers, payment card network associations and their members (for example Visa, Mastercard, or Interac), banks, credit bureaus, other financial bodies, and other participants in the payments ecosystem, for example to provide payment services, evaluate credit worthiness, and comply with card brand rules.
Advisory and other services
COMPANY may also disclose Personal Information to lawyers, accountants, auditors, financial advisers, consultants, and other COMPANY representatives.
Affiliates and Partners
COMPANY may disclose Personal Information to its subsidiaries and affiliates.
In addition, COMPANY may disclose Personal Information to its partners and other service providers where required to provide services.
Regulators, Courts, and Law Enforcement
COMPANY and our Canadian, US and other foreign service providers may disclose Personal Information in response to a search warrant, other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement, contravention of law, or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable law or legal process.
This includes disclosing Personal Information to regulators such as the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and other competent authorities.
In addition, COMPANY may disclose Personal Information 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.
Corporate Restructuring and Financial Events
COMPANY may disclose Personal Information in connection with a proposed or completed merger, acquisition, sale (including as part of insolvency or bankruptcy proceedings) involving all or part of COMPANY, as part of a corporate reorganization, or in relation to other changes in corporate control.
WHERE WE PROCESS PERSONAL INFORMATION
In providing services to merchants, partners, and other customers, Personal Information may be collected, stored, accessed, used or disclosed by COMPANY or our service providers outside of the home province of the individual to which the information belongs, and in countries outside of Canada including the United States, the United Kingdom, the European Union, India or the Philippines.
COMPANY will continue to maintain protection of Personal Information in accordance with this Privacy Statement.
HOW WE SAFEGUARD PERSONAL INFORMATION
COMPANY has a dedicated Information Security team responsible for the implementation of physical, technical, and administrative safeguards to protect COMPANY’s information assets, including Personal Information.
COMPANY maintains policies and standards which provide direction for our information security practices, including by establishing clear roles and responsibilities for the protection of information.
COMPANY’s information security policies and standards align with relevant industry standards and frameworks including the Payment Card Industry (PCI) Standards, the National Institute of Standards and Technology Cyber Security Framework (NIST CSF), and other information security requirements specific to COMPANY’s operations.
Our security practices are periodically reviewed and updated, as are the technological tools we leverage to protect the confidentiality and privacy of Personal Information.
COOKIES, INTEREST-BASED ADVERTISING, AND WEBSITE DATA
Cookies
COMPANY uses automatic data collection tools including cookies and web beacons (for example tracking pixels) on our websites.
Web beacons allow us to determine whether a user accessed content on a webpage.
A cookie is a small piece of data that a website may store on your computer and later retrieve to recognize a user’s computer or device when they return.
For privacy purposes, COMPANY uses the term “cookie” to refer to all such technologies.
Cookies may also be used on COMPANY portals, products, and hosted payment solutions.
COMPANY uses cookies for the following purposes.
Strictly necessary cookies.
These cookies are required for the operation of our websites, including enabling secure login areas.
Functionality cookies.
These cookies recognize returning users and allow personalization of website content.
Analytical cookies.
COMPANY may use third party cookies such as Google Analytics to analyze website activity and improve the user experience.
Advertising cookies.
These cookies allow advertising networks to build a profile of your interests and display relevant advertisements across websites.
Other cookies.
COMPANY or its partners may use cookies for risk management tools or other service features.
PRIVACY CHOICES AND RIGHTS
Marketing Communications
If you are a COMPANY merchant, partner, or customer, or if you have made an inquiry or opted to receive marketing communications, COMPANY may send electronic messages such as emails or text messages.
You may unsubscribe by using the unsubscribe link included in such communications.
From time to time, COMPANY may contact merchants and customers to offer products and services that may be of interest.
Right to Access and Portability of Personal Information
If COMPANY holds your Personal Information, you may request access to, update, or correct that information.
You may also request that your Personal Information be provided to you or another service provider in a structured, commonly used, and machine-readable format where technically feasible.
Such rights may be subject to legal limitations or restrictions.
COMPANY strives to keep Personal Information accurate, complete, and up to date.
To update information, COMPANY may need to verify your identity.
Withdrawing Consent
You may withdraw your consent to the collection, use, or disclosure of your Personal Information at any time, subject to legal or contractual restrictions and reasonable notice.
If consent is withdrawn, COMPANY may be unable to provide some or all of its services.
UPDATES TO THIS PRIVACY STATEMENT
COMPANY will update this Privacy Statement from time to time to reflect changes in our Personal Information practices.
Any updates will take effect as of the modification date noted above unless otherwise stated.
QUESTIONS, CONCERNS OR COMPLAINTS
If you have questions, concerns, or complaints regarding this Privacy Statement or COMPANY’s handling of Personal Information, or if you wish to exercise your privacy rights, please contact:
ZERO BOOST PAYMENTS CORP.
#250 - 997 Seymour St. Vancouver, BC, Canada V6B 3M1
Email: info@finflare.com