Privacy Policy

Privacy Policy for ASAPP Financial Technology Inc. (hereinafter referred to as “The Company”). The Privacy Policy below governs your use of The Company website and any information you provide on this site or related to its use.

Overview

To operate The Company website and to reduce the risk of fraud, The Company must ask you to provide us information about yourself. This Privacy Policy describes the information we collect and how we use that information.

The Company takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on The Company website, whether the services are offered by The Company, or by its subsidiaries. If you have questions or concerns regarding this Privacy Policy, you should first contact The Company by telephone prior to using the website.

By accepting the Privacy Policy and Terms and Conditions through use of the website, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the The Company’s Terms and Conditions. This Privacy Policy will take effect on January 16, 2018. This Privacy Policy was last updated on September 28, 2019.

Please note that your personal information will be stored and processed on our computers in Canada. The laws on holding personal data in Canada may be more or less stringent than the laws of your country but The Company will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not use The Company website and / or register for any service(s) as they may be offered on The Company website.

Notification of Changes

This policy may be revised over time as new features are added to The Company website or as we incorporate suggestions from our customers. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. In addition, if we make a material change to this Privacy Policy, and you disagree with the terms of change, you may contact us to have your personal information removed from our records. Please check The Company website at www.asappbanking.com at any time for the most current version of our Privacy Policy.

The Company website may include links to third party websites. These sites are governed by their own privacy statements, and The Company is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party websites should review the privacy statement of these sites before providing them with personally identifiable information.

Information We Collect

Because of the way that World Wide Web communication standards work, when you arrive at or leave The Company website, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our website you visit while you are on The Company website, the type of browser you use and the times you access our website. We use this information to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with The Company.

"Cookies" are small files of data that reside on your computer and allow us to recognize you as a website user if you return to The Company website using the same computer and browser. We may send a "session cookie" to your computer if and when you log in to you’re account (if applicable) by entering your e-mail address and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times.

We may also use longer-lasting cookies to display your e-mail address on our sign-in form, so that you don't have to retype the e-mail address each time when you log in to your account (if applicable). Our cookie files are encoded so that your e-mail address and other information can only be interpreted by The Company.

Customer Service Correspondence

If you send us correspondence, including e-mails and faxes, we retain such information in our records. We will also retain customer service correspondence and other correspondence from The Company to you. We retain these records in order to measure and improve our customer service and to investigate potential fraud and violations of our Terms and Conditions. We may over time, delete these records if permitted by law. If you submit your e-mail address to The Company as part your interaction with the website, including but not limited to use of any of the forms on the site or through our “Contact” service or as part of a registration process (if applicable) on the website, your e-mail address will be retained by The Company for the purpose of communicating with you.

In addition, from time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

Our Use and Disclosure of Information

We collect, store and process your personal information on servers located in Canada. Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your personal information to:

- provide the services and customer support you request;

- resolve disputes, collect fees, and troubleshoot problems;

- prevent potentially prohibited or illegal activities, and enforce our User Agreement;

- customize, measure, and improve our services and the content and layout of our website; and

- tell you about targeted marketing, service updates, and promotional offers based on your communication preferences.

We also use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

Disclosure to Third Parties

The Company will not sell or rent any of your personally identifiable information to third parties. However, we disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. As The Company may outsource some of its functions, including data storage and processing, to related entities or service providers in foreign jurisdictions those related entities or service providers may be required to disclose your personal information pursuant to a subpoena or other legal process which originates in that foreign jurisdiction. We also disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).

As with any other business, it is possible that The Company in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by The Company, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described above. We also share your information with our parent companies, affiliates, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.

Contact with The Company’s Website Users

We communicate with users on a regular basis via e-mail to provide requested services, to resolve customer complaints, to investigate suspicious transactions and to provide informational or promotional information about The Company.

Information Security

The Company is committed to handling your customer information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only to employees who need to know that information in order to fulfill their job responsibilities.

If you register for an account through The Company website (if applicable), the security of your account will rely on your protection of your password. You may not share your password with anyone. If you do share your password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password.

If you have any questions about this Privacy Policy, The Company’s information practices, or your dealings with The Company, you can contact us at 416-915-0345.