FintechWerx Privacy Policy
Last updated: August 11, 2022
FintechWerx International Software Services Inc., doing business as FintechWerx (“FTW”, “we” or “us”) values your privacy. This policy (the “Privacy Policy”) applies to any use of the services available through the FTW website at www.emtwerx.com (“Site”) and any mobile applications (each an “App”) through which they may be made available (the “Services”).
This Privacy Policy is designed to explain how we collect, use, store, retain, disclose, disseminate or otherwise make available (collectively, “Process”) your Personal Information (as defined below) when you use the Services.
PLEASE READ THIS POLICY CAREFULLY. By creating an account and clicking on ‘I agree’ or by accessing the Services, you acknowledge that you have read, understand and agree to be legally bound by this Privacy Policy, and other policies incorporated herein by reference.
MODIFICATIONS TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time, in our sole discretion. We may modify this Privacy Policy by providing notice via one or more of the following methods: (a) by email to the email account used to create your account, (b) by updating the ‘last updated’ date listed above, or (c) by your acknowledgement as part of your account login. We strongly recommend that you frequently review the Privacy Policy to ensure that you understand it, and how it applies to your access to and use of the Services. By continuing to use or access the Services you confirm your agreement to the modified Privacy Policy. If you do not agree, your sole remedy is to discontinue use of the Services and close your account.
INFORMATION WE COLLECT
What is Personal Information
Privacy laws in Canada generally define “Personal Information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. This means Personal Information is any information or data relating to you that can be used to identify you, directly or indirectly, or to contact you.
Your Personal Information
When you visit our Site, use our APP and our other Services, sign up or set up an account with us or contact us, we may collect a variety of Personal Information about you. We may also use third party providers to store your information safely and help us review your accounts for fraud or other concerns. Generally, we need the information listed for you to use our Services:
Basic Information: When you open an account with Us
What We Collect
- Name;
- Address;
- Date of birth;
- Phone number;
- Email address;
- Government Issued Identification
- Nationality or citizenship (if your passport has been provided as identification)
How We Use this Information
- to verify your identity (to protect you against identity theft or fraud)
- to provide you with the use of our Services (e.g., to allow us to put you in touch with our merchants, to contact you about issues with our Site, to allow you to create a WerxID, to invoice you)
- to advertise and market products or features to you
- to verify we are speaking to you
- to notify you about changes to our Site or any products or services we offer or provide though it
- to allow you to participate in interactive features, social media, or similar features on our Site
- to comply with legal requirements
- to prevent fraudulent use of our services
Additional Information: When you upload information to your account
What We Collect
- Gender
- Employer Information
- Educational Information
- Professional Information
- Certifications
- Memberships
- correspondences
- information you share on the Network Commons
How We Use this Information
- to verify the information we have added to your WerxID
- to verify the information you provide to our merchants
- to verify the information you have shared in the Network Commons
- to provide you with our Services
- to carry out our obligations and enforce our rights arising from any contracts with you
- to conduct fraud and risk monitoring
- to comply with legal requirements (such as “know your customer”, anti-money laundering, or anti-terrorism laws)
- Payment Information: When you Make Payments to us
- What We Collect
- Payment information (method of payment, bank details, credit/debit card, card number or other payment card information);
Transaction information (regarding transactions made relating to the Services).
How We Use this Information
- to manage and process your payments
- to carry out our obligations and enforce our rights arising from any contracts with you
- to process warranties and returns
- to conduct fraud and risk monitoring
- to comply with legal requirements
- Additional Information About Yourself You Voluntarily Disclose
What We Collect
If you authorize us or third parties to do so, we may also collect information about you from other sources such as third party service providers, our partners or affiliates, public databases, identity verification providers, merchants who use the Services, advertising networks, analytics providers, social media platforms. This additional information will allow us to advertise and market products or features and additional Services to you.
How We Use this Information
- To allow us to better connect you with our merchants
- to advertise and market products or features and additional Services to you
- Non-Personal Information
What Are Cookies?
Cookies are small data files that are stored in your device memory or on your hard drive when you visit a website. Cookies may be used as a mechanism to recognize you, record behavior, and/or customize your experience with the Site and Services. They can also be used to monitor Site activity, mitigate risk, measure the effectiveness of promotions and prevent potential fraud. If you choose to disable cookies, your use of the Site or Services may be limited or otherwise limited or unavailable.
We may use this information, for example, to ensure that the Services functions properly, to determine how many users have visited certain pages or opened messages, or to prevent fraud. We also work with analytics providers which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.
Most internet web browsers are set to accept cookies and local storage by default.
Data Collection
As you navigate through and interact with our Site, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Site and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is statistical data and may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to: estimate our audience size and usage patterns, speed up your searches, recognize you when you return to our Site, store information about your preferences, allowing us to customize our Site according to your individual interests.
Some content or applications on the Site, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
HOW WE RETAIN YOUR PERSONAL INFORMATION
We will retain and store your Personal Information until you close your account with us; however you have the right to update, change or delete your Personal Information, see our HOW TO ACCESS, CHANGE, UPDATE OR DELETE YOUR PERSONAL INFORMATION below regarding how to do so. Deletion or destruction of Personal Information shall be done according to FTW’s data destruction policy.
If you share your Personal Information with a merchant or other third party, that information will be governed under the merchant or third party’s privacy policy. We are not responsible for the privacy practices of any third party, including merchants who use the Services. We recommend reading and understanding how these external entities process and use your Personal Information.
HOW WE SHARE YOUR PERSONAL INFORMATION
There are situations where FTW may share your Personal Information with our third party service providers, merchants, our partners or affiliates and other parties as described in our Terms of Service and this Privacy Policy. We may share a summary of your Personal Information with various merchants who utilize FTW Services and that you shop at. By entering into our Terms of Service and agreeing to this Privacy Policy, you are affirmatively opting into this sharing of your Personal Information.
FTW service providers and affiliates are required to handle Personal Information consistent with this Privacy Policy and according to our instructions. They cannot use your Personal Information shared by us for their own purposes, and must delete or return shared Personal Information once they have completed our request.
We may also disclose Personal Information if we determine that for purposes of national security, law enforcement, or other issues of public importance where disclosure is necessary or appropriate. We may also disclose Personal Information where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our Terms of Service or to protect our operations or users, or in the event of a reorganization, merger, or sale of FTW.
HOW WE PROTECT YOUR PERSONAL INFORMATION
FTW uses reasonable administrative, technical and physical safeguards to protect your Personal Information, taking into account the nature of your Personal Information, Processing of this data and threats posed. We conduct periodic reviews of these safeguards and work to improve our safeguards to keep your information safe.
We use reasonable measures designed to limit access to your Personal Information only to the persons, employees, or affiliates who have a need to access such information.
However, as an online electronic system, we cannot guarantee that there will be no loss, misuse, unauthorized access or acquisition, or alteration of your Personal Information. Notwithstanding FTW’s efforts, no security measure is perfect or impenetrable and no method of transmission over the internet or electronic storage is 100% secure. Therefore, FTW cannot guarantee complete security of the transmission or storage of your Personal Information. We cannot ensure the security or confidentiality of any information that you transmit or receive from us by internet or wireless connection, as we do not control the methods of transmission. If you believe that any of your Personal Information has been compromised, please contact us immediately.
It is important that you maintain the security and control of your account credentials, and not share your password with anyone.
WHERE YOUR INFORMATION IS STORED AND PROCESSED
FTW is based in Canada, and your Personal Information may be stored or Processed in Canada or in the United States. Our operations are supported by a network of computers, servers, information technology, and other infrastructure that includes, but is not limited to third party service providers. While we are based in Canada, we and our third party service providers may store and process your Personal Information in locations around the world, including but not limited to the United States and the European Union. You consent to Processing and transfer of information in and to the United States, and to other countries, where you may not have the same rights.
In connection with providing the Services, it may be necessary for us to transfer your Personal Information to third parties that are outside the European Economic Area (“EEA”). If your Personal Information is subject to such transfer, we shall take reasonable measures, including appropriate physical, technical, and administrative practices to protect your information, and will have appropriate contractual protections in place with any third parties. By using our Services, you consent to your Personal Information being transferred to other countries, even if those countries have different data protection rules than your country.
PRIVACY OF MINOR CHILDREN
We do not knowingly request or collect Personal Information from any person under the age of 18 or the legal age of the province in which you reside, or where the Services may be used (a “Minor”). Use of the Services by a Minor is expressly prohibited by our Terms of Service. If we learn that we have inadvertently collected the Personal Information of a Minor, we shall immediately take steps to delete the information as soon as possible.
HOW TO ACCESS, CHANGE, UPDATE OR DELETE YOUR PERSONAL INFORMATION
To view, change or update your Personal Information, you may log into your account to make such changes.
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service.
There may also be situations where we cannot grant your request, for example if you ask us to delete your Personal Information and FTW is legally obligated to keep a copy of it to comply with applicable law. We may also decline to grant a request where doing so would undermine our legitimate use of the Personal Information for anti-fraud or security purposes. Other reasons we may decline your request if it jeopardizes the privacy of others, is frivolous or would be extremely impractical.
If you are unable to make said changes in your account, request that your information be deleted, to withdraw consent for use of your Personal Information, or for other changes, you may email us at [email protected]. We will explain the impact to you at the time to help you with your decision.
HOW TO CONTACT US
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. If you have questions about this Privacy Policy, comments or feedback, please contact us at [email protected]. If your questions relate to your account or use of the Services, we may ask for certain information to verify your identity.