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:
Contact Information — Personal Information that you provide when signing up for or using the Services, including name, billing and shipping addresses, email addresses, telephone number, usernames or passwords, and date of birth.
Identity Verification Information — To help create and maintain a trusted environment, we may collect identity verification information (such as images of your driver’s license, as permitted by applicable laws) or other authentication information.
Usage Information – We and our service providers may collect certain information by automated means, such as cookies, web beacons, log files, and similar technology (explained more below), as you use the Services. This includes data such as your internet protocol address, device characteristics, browser characteristics, operating system, language preferences, clickstream data (e.g., a list of pages or URLs visited before and after the website visit), search terms entered, and dates and times of visits to the Services. This information allows us to recognize you and personalize your experience if you return to the Services and to improve the Services.
Cookies — a “cookie” is a file that websites send to a visitor’s internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.
Web Beacons — a “web beacon”, also known as an internet tag, pixel tag, or clear GIF, is a clear graphic image that may be embedded in an email to record when a user opens the email or may be loaded by a web browser to record a user’s visit to a particular website.
Log Files — a “log file” is a file that records how users interact with websites or a server.
Geo-location Information — When you use certain features of the Services, we may collect information about your precise or approximate location as determined through data such as your internet protocol address or mobile device’s GPS to offer you an improved user experience.
Interaction Information — When you communicate with PaymentCo or use the Services to communicate with other users of the Services, we collect information about your communication and any information you choose to provide.
Third Party Content — We may collect the content from third parties:
Third Party Services — If you link, connect, or login to your PaymentCo Account with a third party service (e.g., Google, Facebook), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Referrals — If you are invited to PaymentCo, the person who invited you may submit Personal Information about you such as your email address or other contact information.
Other Sources — To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may also receive additional information about from credit reporting services.
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:
at the time we collect the Personal Information following the instructions provided; or
by informing us by e-mail, mail or phone using the contact details set out in the Contact Us section below.
(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:
to service providers who work on our behalf and who have agreed to use the Personal Information solely in furtherance of our operations, including, but not limited to, service providers who deliver marketing communications, promotional materials, or advertisements that may be of interest to you on our behalf; verify your identity or authenticate your identification documents and check information against public databases; conduct background or police checks, fraud prevention, and risk assessment; perform product development, maintenance and debugging; or allow the provision of the Services through third party services and software tools;
where you have provided express and prior consent and where permissible according to applicable law, to social media platforms such as Facebook or Google to generate leads, drive traffic to our website or otherwise promote the Services;
to a government institution that has asserted its lawful authority to obtain the information or where PaymentCo has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to PaymentCo’s legal counsel;
when we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of the Services, or your safety or the safety of others, or (b) to detect, prevent, or 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;
to any of the companies and business entities that form part of the PaymentCo group (i.e. PlaceHolder Inc., PlaceHolder Canada Inc. and PlaceHolder Technologies Canada Inc.in order to serve you better and to provide you with information about our affiliates’ products and services; and
to affiliates, service providers, advisors, and other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, dissolution, bankruptcy, acquisition, or sale of PaymentCo or all or a portion of our assets or other business transfers, but PaymentCo will require the acquiring organization to agree to protect the privacy of Personal Information in a manner that is consistent with this Privacy Policy.
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 http://www.aboutads.info/choices/ and edit or opt-out your Google Display Network ads' preferences at http://www.google.com/ads/preferences/. 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:
to receive communications related to the processing of Personal Information that are concise, transparent, intelligible and easily accessible;
to obtain from us confirmation if Personal Information is being processed by us and be provided with a copy of Personal Information held by us;
to request the removal (which may be accomplished by anonymization) of Personal Information held by us without undue delay;
to request that we restrict the processing of Personal Information (while we verify or investigate your concerns with this Personal Information, for example);
to object to the further processing of Personal Information, including the right to object to marketing;
to request that Personal Information that you have provided to us be moved to you or to a third party in a structured, commonly used and machine-readable format;
to correct inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete;
to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (Automated Decision-Making);
to lodge a complaint with a supervisory authority; and
where our processing of Personal Information is based on consent, to withdraw that consent without detriment at any time.
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 privacy@placeholderpayments.com.
13. EU DATA SUBJECT RIGHTS AND OTHER RELEVANT INFORMATION
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.