Buckzy – Canada

Effective May 2022

Introduction

Your privacy and keeping Your personal information secure are extremely important to us. At Buckzy Payments Inc., we are committed to protecting and respecting Your privacy and handling Your information in an open and transparent manner.

This Privacy Policy (“Policy“) explains among other things: what we do with Your personal information; what we do to keep it secure; with whom we share Your information; Your rights in relation to the personal information we hold about You; and who You can contact for more information. In this Policy, references to “You” and “Your” are references to users of our website, a customer and a consumer.

We will amend or update this Policy regularly to reflect changes in our practices with respect to the processing of personal information, or changes in applicable law. We encourage You to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.

If You don’t want to read all the details. Here are the highlights that You may really wish to know:

  • We are bound by the Personal Information Protection and Electronic Documents Act 2000 (“PIPEDA” or the “Act”).
  • Where appropriate we share Your personal information within Buckzy Payments Inc., our affiliates, partners and other companies. Upon request or where we are legally obliged, we may share Your information with public agencies.
  • We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers). In providing this information You confirm to us that You have their permission to do so.
  • We use third parties to process Your personal information on our behalf to perform our services for You, and due to the international nature of our business, some of them are based outside of Canada.
  • You have several rights over Your personal information, and the manner in which You can exercise those rights are contained in this Policy.
  • We will send You direct Marketing if You have agreed to receive it. We do this to encourage You to use our services and send You offers or promotions that may interest You. You can ask us to stop sending You marketing information at any time. Either by selecting the unsubscribe button at the bottom of any email communication You may receive from us or by sending us an email at privacy@buckzy.net.
  • We may use Your personal information to display online advertisements and Marketing relating to our services on our website or online media channels only if You have selected to accept all cookies.
  • We will not collect sensitive information about You without Your consent unless an exception in the Act applies. For example, if the collection is required or authorized by law.

Definitions

To help clarify our meaning, we have used certain capitalised terms in this Policy. These terms and their meaning are:

“Cookie” means a small text file which includes a unique identifier that is sent by a web server to the browser on Your computer, or any other internet-enabled device when You visit an on-line site.

“Privacy Laws” means the Personal Information Protection and Electronic Documents Act 2000 (“PIPEDA” or the “Act”), and other applicable legislation relating to privacy or data protection in Canada.

“Marketing” means any action or advertisement or promotion or marketing material like surveys, vouchers, research and events. This list is not exhaustive.

“Services” means Buckzy service and such other services or products that we may introduce from time to time.

Who are we?

Buckzy Payments, Inc. (“Buckzy”, “We”, “Us”, “Our”), a Province of British Columbia corporation is committed to protecting and respecting Your privacy, handling Your information in an open and transparent manner, and keeping Your information secure.

The personal information we collect about You

We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Data Protection Legislation and as set out in this Policy.
The personal information we collect and use may include, among other things:

  • Your name, company name and title;
  • Your contact information such as Your email address, postal address and telephone number or any telephone number used to call us;
  • Your demographic information such as age, education, and interests;
  • evidence of Your identity, (for example passport information, social security number; and driver’s license);
  • unique identifiers such as Your username and password;
  • Your profiles and postings on any other social media applications and services that we provide or that You make available to us;
  • any correspondence or complaint made to us;
  • Your payment details and other financial data (for example, Your bank or payment method provider’s name) and salary details; and
  • Information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers), where You provide us with such information. In providing this information You confirm to us that You have obtained all necessary permissions from them to the reasonable use of their information for the purposes and in the manner described in this Policy or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.

How we collect Your personal information

  • Information You give to us when You use our services. If You use our services You will need to provide certain information including Your name and address and debit card number, as well as the name and other details of the recipients of the money transfers that You instruct us to carry out. This information must be complete and accurate, and if not we may have to take additional steps to complete the transaction.
  • Other information You give to us. This is information about You that You give us by filling in forms on our website (for example, the ‘contact us’ section) or when You communicate with us by phone, e-mail or otherwise. It includes, for example, information You provide when You register on the website for us to contact You, when You inquire about any of our Services, when You sign up to receive notifications, and when You report a problem with our website. The information You give us may include, among other data, Your name and email address.
  • From other members of Buckzy Payments Inc., We may collect information about You from our affiliates in the United States, the U.K., and other subsidiaries or affiliates globally.
  • Social Media. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram, You might give us permission to access information from those accounts or services.
  • Your Communication with us. We also keep a record of any email correspondence You send to us. This assists us in improving the customer experience.
  • Other Sources. We may receive information about You from other sources, including publicly available resources, e.g. newspapers, internet sites, registries, or public records, and combine this data with information we already have about You. This helps us to update, expand and analyse our records and provide services that may be of interest to You.

Information we collect about You.

When You visit our site we may place Cookies onto Your device, or read Cookies already on Your device, subject always to obtaining Your consent, where required, in accordance with applicable law. We use Cookies to record information about Your device, Your browser and, in some cases, Your preferences and browsing habits. We may use Your personal information through Cookies and similar technologies, in accordance with applicable regulations. Like most websites, we use “cookies” and similar technologies to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. There are small text files that websites transfer to Your computer (or phone / tablet). Cookies and similar technologies are widely used to make websites work efficiently and to collect information about Your online preferences; they improve website use and speed – for example by automatically filling Your name and address in text fields.

In addition, with regards to each of Your visits to our site, we will automatically collect certain information (for example, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data). We may combine this automatically- collected log information with other information we collect about You.

Our website includes Social Media Widgets or Features, such as the Facebook Like button and Twitter button which are interactive mini-programs that run on our site to provide specific services from another company (e.g. displaying the news, opinions, music, etc). Personal information, such as Your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.

Personal Information from Third Parties

If we receive personal information about You that we did not request directly from You or from another party, we will decide whether we could have collected the information in accordance with this Policy and Privacy Laws. If so, we will keep the information and handle it in accordance with this Policy and applicable Privacy Laws. if we decide that we could not have collected the personal information in accordance with this Policy and applicable Privacy Laws, we will delete, purge or anonymise the information if it is reasonable and lawful to do so.

How we use Your personal information

Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer or device.

We use Your information for the following specific purposes:

  • to carry out our obligations arising from any contracts entered into between You and us or from applicable law such as anti-money laundering laws, and to provide You with the Services in accordance with our Terms and Conditions and with this Policy;
  • to register You with an account;
  • to fulfil Your Transaction / Request;
  • to send You confirmations or other notifications;
  • to notify You about temporary or permanent changes to our services or other service-related messages;
  • to assist You where online applications are not completed;
  • to prevent fraud, money laundering, terrorist financing and any other illegal activity;
  • to ensure that content from our site is presented in the most effective manner for You and for Your computer;
  • to promote our business;
  • to send You Marketing communications, as applicable, provided that You have given us Your contact details and that You do not decide to opt-out from this type of communications, in accordance with Data Protection Legislation.
  • to administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes;
  • as part of our efforts to keep our site, and our services safe and secure;
  • Analytics, web traffic analysis, to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
  • to make suggestions and recommendations to You and other users of our site about services that may interest You or them;
  • to train, monitor and assess the effectiveness of the manner in which we provide the Services to You;
  • to consider and investigate any concerns or complaints You may have; and
  • to display personal testimonials of satisfied consumers on our website in addition to other endorsements, where You have agreed with a third-party review site that we may do so. If You wish to update or delete Your testimonial, contact us at privacy@buckzy.net.

Buckzy Payments Inc., will not sell, rent or otherwise disclose Your information to third-party marketers or others unaffiliated with Buckzy or other partners for the purpose of advertising, promoting or selling other services to You. However, where and to the extent permitted by law, Buckzy may work with third parties to analyze the information that we gather from You when You visit our website, our LinkedIn page, Facebook page, and our online advertisements, whether or not You use the Buckzy service. For further information see the Who we might share Your personal information with section of this Privacy Policy.

Direct Marketing

We may use the contact details You provided to send You marketing communications by email, telephone, or other communication formats about similar products or services where permitted by applicable law (unless You have opted out).

In other cases, we may ask for Your consent to send You marketing communications about products or services offered by Buckzy, its affiliates, and other partners.

Opting Out of Direct Marketing

You can opt-out of receiving Buckzy marketing communications by modifying Your email subscriptions by clicking on the unsubscribe link or following the opt-out message included in the communication.

Alternatively, simply send an email to privacy@buckzy.net and the email address that You wish to be removed within the email.

Please note that if You request we stop sending You Marketing messages or You unsubscribe, we may continue to send You service and administrative communications such as transfer updates and other important information on Your transaction.

Who we might share Your personal information with

Your personal information is very important to us. However, there are circumstances where it is necessary for us to share Your information for legitimate business purposes (including operating our site, and providing services to You), in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose Your personal information to:

we share Your information with our affiliates:

  • for our internal business, operational, management and service needs;
  • for compliance, regulatory and audit activity and in connection with legal, regulatory and tax claims and investigations;
  • to understand and support our customers, consumers and other individuals who use our services, apps and visit our sites; and
  • to send Marketing communications to You.

which include people with whom we do business or who provides services to us. If we engage a third party processor (Processor) to process Your information, the Processor will be subject to binding contractual obligations to: only use the personal information in accordance with our prior written instructions; and use measures to protect the confidentiality and security of the personal information, together with any additional requirements. We may disclose data to provide our services, to respond to legal requirements, enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, and protect our rights and property. Processors may include:

  • Credit reference agencies or other service providers to verify Your identity or the identity of recipients of the money transferred through our services or for any other purpose related to providing our services;
  • Professional advisers, such as our auditors and lawyers;
  • Companies that capture or analyse information to help us understand how our services and sites are used and perform or to tailor our services and promotions, including for the purpose of allowing us to improve the services we provide;
  • Companies that provide us with marketing assistance, including: the management of email marketing operations, and other services that deploy marketing on the internet or social media platforms; the running of surveys and other feedback activity; as analysis of the effectiveness of any marketing or consumer engagement we do;
  • Banks, payment card processors and other service providers that process bank transfers, credit and debit card payments or otherwise provide financial infrastructure services to enable us to provide our services;
  • Our service providers, including those who provide data hosting services, fraud prevention services; technology services, and technology tools that allow us to monitor, test and improve our services and sites;
  • Companies that we have instructed to provide services to or for us for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
  • Other business entities should we plan to merge with, or be acquired by, or be invested in by that business entity, or if we undergo a corporate reorganisation; and
  • Any successor in business to us.

Where we have a good reason to suspect fraud, money laundering, terrorist financing or any other illegal activity we can, upon request or where legally obliged, share Your personal information with crime prevention agencies and other third parties for the purpose of detecting, preventing, or reporting crime, or for actual or suspected breach of any applicable law or regulation. These third parties may include business partners and companies that provide services to us, law enforcement bodies, regulatory and supervisory authorities, providers of fraud prevention and detection services. Please note, we may suspend activity on Your account or any transaction, refuse access to Your account or cancel any transaction You may want to make, if we think there is a risk of any illegal activity.

We release accounts or other personal information when we consider it appropriate to comply with the law, to enforce our Terms and Conditions and any other agreement to protect the rights, property, or safety of Buckzy, our employees, consumers, our business partners, and the public. In these circumstances, we will only provide them with the information they require to perform their function.

We may share personal information in a secure way to allow research companies and feedback providers to contact You directly on our behalf to get Your opinions on or refuse to take part in the research or surveys.

Links to Other Sites

Our sites may contain links to other websites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once You link to another website from our site You are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before You submit any data to these websites.

International transfer of Your personal information

Due to the international nature of our business, we may need to transfer Your personal information to other Buckzy entities, to other third parties as noted in the “Who we might share Your information with” section of this policy, and recipients, in connection with the purposes set out in this Policy. For this reason, we may transfer Your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which You are located. Buckzy will take reasonable steps to ensure that personal information is protected and any such transfers comply with applicable law.
Where recipients are located outside of Canada we ensure that the information will be protected by safeguards comparable to Canada’s privacy Laws; or by methods including using contractual clauses, or by ensuring the recipient is subject to laws of another jurisdiction that provides comparable protection to the Privacy Laws.
We also ensure that our data protection and information security controls applying to Your personal information in Canada continue to apply in the hands of our affiliates or contracted service providers located overseas.

How we keep Your personal information secure

We have implemented appropriate administrative, technical and organisational security measures designed to protect Your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect Your personal information, we cannot guarantee or warrant the security of Your data transmitted to our site; and any transmission is at Your own risk. Please note that You are responsible for maintaining the security of Your credentials used to access any Buckzy service or account, and You must report suspected unauthorized activity to us. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.
We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.

Protecting Your own information

It is important to keep Your password secure to prevent fraudulent use of Your account. Do not disclose Your password to anyone else and especially anyone who requests it from You by telephone or email. Buckzy will never ask You to provide Your password or personal information via email. Please be aware of the following:

  • Change Your password regularly and avoid using the same password on other websites to prevent hackers from access to Your account;
  • Avoid simple passwords that can easily be guessed;
  • Be aware that public WiFi networks are risky and hackers may capture Your online transactions and personal information. Only connect to a network You can trust;
  • If You use a shared computer, make sure You log out immediately after You have finished using the website; and
  • Beware of ‘phishing’ where criminals may attempt to steal Your information by sending You bogus emails.

How long will we keep Your personal information

We take every reasonable step to ensure that Your personal information is only retained for as long as it is required for the purposes set out in this Policy. Therefore, we will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

The period for which we will retain information about You will vary depending on the type of information and the purposes for which we will use it. Generally, unless applicable law or our legal and regulatory obligations require a longer retention period, we will keep our records for at least five years after You have terminated Your relationship with us.

Your Rights

Subject to applicable law, You may have a number of rights regarding our processing of Your relevant personal information, including:

  • the right not to provide Your personal information to us (however, please note that we may be unable to provide You with the full benefit of our site, or our services, if You do not provide us with Your personal information);
  • the right to request access to Your personal information, together with information regarding the nature, Processing and disclosure of that personal information;
  • the right to request for the correction of any inaccuracies in Your personal information;
  • the right to request for the erasure of Your personal information. This is also known as the right to be forgotten. We will keep a note of Your name if You ask for Your personal information to be erased;
  • the right to prevent processing for direct marketing purposes as stated in the Direct Marketing section of this Policy;
  • the right that we restrict our use of Your personal information;
  • where we use Your personal information on the basis of Your consent, You have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of Your personal information in reliance upon any other available legal basis); and
  • the right to lodge complaints with the Office of the Privacy Commissioner of Canada regarding the use of Your personal information by us or on our behalf.

We may require proof of Your identity before we can give effect to these rights. You should also be aware that some of these rights are qualified and not absolute; therefore exemptions or limitations may apply. For example, we can refuse to provide information if fulfilling Your request would reveal the personal information about another person, or if You request that we delete information which we are required to retain by law, have compelling legitimate interests to keep, or need access to fulfil our legal obligations.

You can contact us at privacy@buckzy.net if You want to enforce any of these rights. We will comply with our legal obligations as regards Your rights as a data subject.

Any request for access to Your personal information must be in writing and we will endeavour to respond within a reasonable period and in any event within one month (three months for complex or numerous requests), in compliance with Data Protection Legislation. We reserve the right to charge a reasonable fee (reflecting the costs of providing the information) or to refuse to respond where requests are manifestly unfounded or excessive: in this case, we will explain the situation to You and we will inform You about Your rights.

Contact us

Questions, comments and requests regarding Your personal information and our Policy are welcome and should be sent to the attention of the Privacy Officer at privacy@buckzy.net or by mail to the following address:
40 University Avenue, Suite # 201
Toronto, ON Canada
M5J 1T1

If You believe that there has been a breach of the ACT or elements of this Policy, or if You have any concerns regarding the handling of Your personal information, You may also use the above contact details to make a complaint to us relating to Your privacy.

How to Make a Privacy Complaint

If after the applicable response time is complete and You are not satisfied with our response to Your complaints, You can also refer Your complaint to the Office of the Privacy Commissioner of Canada by: