Privacy Policy

Last updated on August 1, 2022.

1. Application of this Privacy Policy

This Privacy Policy describes the ways in which PlaceHolder Payments Canada Inc. and PlaceHolder Payments Inc. (“PaymentCo” “we”, “us”, or “our”) collects, uses, and discloses your personal information (“Personal Information”) through the Services. “Personal Information” includes any information that can be used on its own or with other information to identify a single person or to identify an individual in context.

This Privacy Policy sets out how we handle Personal Information that we gather when you are using the Services. It does not cover the practices of individuals, companies and entities we do not own, control or manage.

If you see an undefined term in this Privacy Policy (such as “Services”), it has the same definition as in our Terms of Service (“Terms”).

By using the Services or submitting Personal Information through the Services, you acknowledge that you have read about how we process your information as set out in this Privacy Policy, now and as amended, by us. Please do not use the Services and do not submit any information through them if you have not read this Privacy Policy or do not agree with its terms.

2. Information We Collect

PaymentCo only collects Personal Information when you voluntarily provide it to us directly or through our website. PaymentCo does not collect any “sensitive personal information” or Special Categories of Personal Information (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric information) about you.

From time to time, we may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

3. How We Use Information and Basis for Processing

We may use the Personal Information we collect for a number of purposes. Our basis for processing Personal Information depends on your jurisdiction. We have set out our basis for processing below. From time to time, we may also request your consent, in which case we will process on the basis of your consent.

Purpose of Processing

Type of Personal Information

Basis of Processing

To deliver and manage customer support and respond to inquiries.

Contact Information

Usage InformationInteraction Information

Legitimate interest

To provide you with information about the Services, or required notices.

Contact Information

Legitimate interest

To deliver marketing communications, promotional materials, or advertisements that may be of interest to you, and administer participation in special events, programs, offers, surveys, and other market research.

Contact Information

Legitimate interest

To improve the Services and/or to develop new products or services.

Contact Information

Usage InformationGeo-location InformationInteraction Information

Third Party Content

Consent and legitimate interest

To customize your experience when using the Services, such as by providing interactive or personalized elements and content on the Services.

Contact Information

Usage InformationGeo-location Information

Interaction InformationThird Party Content

Performance of contract, consent and legitimate interest

To aggregate and de-identify certain Personal Information and use and share the resulting data for business purposes.

Contact Information

Usage InformationInteraction InformationThird Party Content

Consent and Legitimate interest

To detect, prevent, and respond to fraud, intellectual property infringement, violations of our terms of use or other legal agreements, violations of law, or other misuse of the Services.

Contact InformationIdentity Verification Information

Usage InformationGeo-location InformationThird Party Content

Performance of contract, consent and legitimate interest

We also may combine or aggregate any of the Personal Information we collect through the Services for any of these purposes. We may send you emails, text messages, and push notifications to your mobile device, if you have them enabled, to verify your account and for informational and operational purposes, such as account management, providing instructions, alerts, reminders, customer service, system maintenance, and other Services-related purposes.

Where our use of Personal Information requires your consent, you can provide such consent:

(a) Marketing

We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising. 

We may use your identity, contact, technical, marketing and communications, aggregate and profile Personal Information to form a view on what we think you may want or need, or what may be of interest to you.

Where Canada’s Antispam Legislation (“CASL”) applies to our communications with you, we are committed to complying with CASL and, in particular, the provisions setting out the requirements for sending commercial electronic messages.

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share Personal information with any third party for marketing purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time (see Contact Us section below). Where you opt out of receiving these marketing messages, we may continue to use Personal Information in order to provide you with services you have requested from us.

(b) Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services may become inaccessible or not function properly.

(c) Change of Purpose

We will only use Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (see the Contact Us section below).

If we need to use Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

4. How We Share Information

We may disclose the Personal Information we collect from you through the Services:

We may also share or sell aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

Please note that PaymentCo has social media channels that utilize first and third-party vendor remarketing tracking cookies, including the Google Ads tracking cookie, Facebook, and LinkedIn remarketing cookies. This means we will show ads to you across the Internet, specifically on the Google Content Network (GCN), Facebook, and Linkedln. This data may also be shared with trusted third party vendors that utilize this data to create promotion campaigns for other related companies. As always, we respect your privacy and are not collecting any identifiable information through the use of Google's or any other third party remarketing system. The first- and third-party vendors, including Google, whose services we use, will place cookies on web browsers in order to serve ads based on past visits to our website. This allows us to make major announcements and continue to market our services to those who have shown interest in our service. The PaymentCo Service also uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.

You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioural Advertising at and edit or opt-out your Google Display Network ads' preferences at Please note that the PaymentCo Service currently does not respond to “Do Not Track” signals.

If you would prefer for us NOT to share your information as described above, simply inform us (see the Contact Us section below).

5. Third Party Links

The Services may contain third party links. You acknowledge that we are not responsible for the collection and use of Personal Information by such third parties that are not under our control. We encourage you to review the privacy policies of each website you visit.

6. Data Retention and Deletion

Except as otherwise permitted or required by applicable law or regulation, we retain Personal Information only for as long as is necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting or reporting requirements.

In some circumstances, we may aggregate and de-identify Personal Information so that it may no longer be associated with you. We reserve the right to use such aggregated and de-identified data for any legitimate interest.

7. Data Transfers and Processing

We, or a service provider acting on our behalf, may process, store, and transfer Personal Information in and to a foreign country with different privacy laws that may not be as comprehensive as the laws of the country you are based in. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to access Personal Information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable privacy legislation. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal information out of your home jurisdiction.

If you are located in the EEA, please note that we have implemented safeguards, which may include the EU/UK Standard Contractual Clauses, to ensure Personal Information is protected when transferred, in accordance with applicable data transfer restrictions.

8. How We Protect Information

The security of Personal Information is very important to us. We use administrative, technical, and physical measures to secure Personal Information against unauthorized access, use, disclosure, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your PaymentCo Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your PaymentCo Account, please contact us following the instructions in the Contact Us section below.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the PaymentCo website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect Personal Information, we cannot guarantee the security of Personal Information transmitted to our website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website.

9. Your Choices and your Rights

If you no longer wish to receive marketing communications from us, or if you wish to inquire about or make corrections to of the Personal Information we have collected about you, please submit a request us at to the contact information provided below.

You may also opt out of receiving marketing emails by using the unsubscribe information available in our promotional emails. Please note that you may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Services-related emails.

If you are an EU data subject, the GDPR may apply to the Personal Information we collect from you. You may have some or all of the following rights under certain circumstances, depending on the privacy laws applicable to you:

Your rights to Personal Information may be limited in some circumstances by local legal requirements. Note however that if you exercise your rights, in some cases, we may not be able to provide to you some of the features and functionalities of the Services.

10. Children’s Information

The Services is not directed to, nor do we knowingly collect Personal Information from, any one under the age of majority without parental/guardian consent. If you have reason to believe that we may have collected a minor’s Personal Information without parental/guardian consent, please contact us at the contact information listed below.

11. Changes to this Privacy Policy

If we update this Privacy Policy, we will notify you by posting a new Privacy Policy on this page. If we make any revisions that materially change the ways in which we use or share the Personal Information previously collected from you through the Services, we will give you the opportunity to consent to such changes before applying them to that Personal Information to the extent required by law.

12. Contact Us

PaymentCo has a data protection officer and privacy officer who is responsible for matters relating to privacy and data protection and who can be contacted at the information below.

If you have any questions about this Privacy Policy or our use of Personal Information collected through the Services, please contact us at


PaymentCo processes Personal Information both as a processor and as a controller, as defined under the GDPR. With respect to the Personal Information that PaymentCo processes on your behalf, you represent and warrant that you have established an appropriate legal basis or bases to allow PaymentCo to process such Personal Information. The following terms supplement this Privacy Policy with respect to our processing of European Economic Area (i.e., European Union Member States, Iceland, Lichtenstein and Norway), Swiss and the UK Personal Information. To the extent applicable, in the event of any conflict or inconsistency between the other parts of this Privacy Policy and the terms of this Section, this Section will govern and prevail with regards to the processing of EEA, Swiss and UK Personal Information.