Privacy Policy - Canada

Finseta Payment Corp. dba Finseta and our affiliates, subsidiaries, and partners (collectively, “us” or, “we”, or “our”) take data privacy very seriously and recognize the importance of protecting and respecting the personal information of all parties engaging with our services (collectively, “you”, or “your”, or “them”), y This Privacy Policy (the “Policy”) outlines how we collect, use, disclose, and protect your personal information in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) when using our website http://www.finseta.com (the “Website”)

Please read this Policy carefully. If you do not agree with our policies and practices, please do not use our Website or associated services. By accessing or using our Website, you indicate that you understand, accept, and consent to our practices described in this Policy.

1. What personal information we collect and how we collect it

1.1 Information we may collect from you

In order to provide our Website’s services, including but not limited to international payments and currency management solutions (the “Services”) we may access and collect various types of your personal information. Our commitment is to collect only the personal information necessary to provide our Services efficiently, enhance your experience with us, and meet our operational and legal requirements, including but not limited to:

1.1.1 Initial personal information

To use our Website and Services, you must provide your name, address, phone number, and email address – and we may ask you to provide identity document number(s) and copies of identification documents, for example, your driving licence, passport, and/or a utility bill.

1.1.2 Verification of personal information:

We may ask you to send us additional information if:

  • we cannot verify the information that you provide;
  • a query is raised by background checks (see section 1.1.6.2 below);if you send or receive certain high-value transactions or high overall payment volumes through our Website; or
  • as is otherwise required in order for us to comply with our obligations under any applicable laws, including money laundering regulations.

 

The additional information may include a copy of your driving licence, passport, a recent utility bill, and/or other information verifying your identity, address, or your information overall.

We may also ask for evidence of the source of funds or wealth, for example, bank statement, investment statement, business transaction summary, proof of property sale or probate documents.

1.1.3 When we communicate

When you communicate with us for customer service or other purposes, including by phone, email, or other methods, we retain that information and our responses to you.

We record calls on our telephone lines for quality control purposes, as evidence of transactions and to fulfill regulatory requirements.

1.1.4 Transactional-based personal information

When you use our Services to purchase currency or send currency to someone else, we ask you to provide information related to that transaction. This information includes, but is not limited to, the amount, currency and type of the transaction, source of funds, exchange rate, recipient name and bank details (account number, sort code, IBAN, SWIFT, ABA or routing number), recipient address for some jurisdictions, and optionally, the recipient’s email address and phone number.

1.1.5 Personal information we collect when you use our website

When you arrive at or leave our Website, whether connected by a fixed line or wirelessly, we receive the web address of the Website that you came from or are going to.

While you are using our Website we collect information on the Services you search for or view, page response times and length of visits to specific pages, how you interacted with each page (including scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We collect information about the device you are using, such as the type of device, operating system and platform, the type and version of browser, browser plug-in types and versions, the times you access our Website/app,  the time zone setting, mobile network information and unique device identifier, which may include your device’s IMEI number and/or MAC address or the mobile phone number used by the device. We do not capture GPS information about you.

1.1.6 Personal information  that we receive from third parties

1.1.6.1 Identity Verification Using Electronic Verification Providers

To protect ourselves and our customers against fraud, we verify the personal information you provide with Electronic Identity Verification Services. In the course of verification, we receive personal information about you from such services.

Any electronic identity check with a credit agency may leave a record on your credit file. By agreeing to the terms of this Policy, you agree that we may carry out such searches in the knowledge that it may leave a record on your credit history. If you are a joint account holder, in certain circumstances credit agencies may link your record with your spouse, partner or other financial associates.

1.1.6.2 Background Checks

We conduct a background check on all our customers (and for our business customers, also on the business’s directors, shareholders, and partners). During this process, we will obtain personal information about you and/or your business, its directors, shareholders, and partners, from a third-party identity verification provider.

1.1.6.3  Other third-party sources

We may also collect personal information about you from other third-party sources, including other companies (subject to their privacy policies and applicable law).

We are working closely with third parties, including, but not limited to third-party business partners, affiliates, customers who participate in our refer-a-client program, service providers, advertising networks, analytics providers, and search information providers. We may receive personal information about you from them. This may be combined with the personal information you provide to us.

We will use the personal information we receive from third-party sources for marketing purposes only if you have provided your consent to do so, either to the third party that collected the personal information or directly to us.

1.1.7 Feedback and communication information

We may request or receive feedback, questions, comments, or suggestions to enhance our Services and communication with you. Your participation in providing this information is entirely voluntary.

2. How we use your information?

By submitting your personal information to us,  you agree that we may use your personal information for the following purposes:

2.1 Fulfilling your requests

We will use your personal information to:

  • present our Website and its contents to you;
  • provide you with the information, products, and Services that you request from us, including providing money transfer services and quotes; and,
  • complete any transaction you are undertaking with us.
 

2.2 Compliance and risk management

As an authorized financial institution, we are obliged to carry out background checks on individuals, companies, and connected parties, and to monitor ongoing transactions. This is to prevent fraud and money laundering, including to help protect your accounts from fraudulent activity.

We carry out checks to ensure we do not deal with countries, entities, or individuals that are subject to sanctions, to comply with counter-terrorist financing and anti-money laundering regulations, and to identify high-risk individuals where we need to add additional controls. We also conduct investigations into actual or suspected violations of our Terms of Use.

2.3 Communication and customer service

We communicate with our users on a regular basis via email and phone to provide requested Services and help you manage your account. These activities include but are not limited to:

  • responding to requests for customer service;
  • confirming information concerning your identity, business, or account activity;
  • resolving customer complaints;
  • carrying out collection activities; and
  • conducting customer surveys.

We use your email address to:

  • confirm the opening of your Finseta account;
  • send you notice of money transfers that you send or receive through us;
  • send you information about important changes to our products and Services, including notice of any times that our Services may not be available; and,
  • send notices and other disclosures required by law.

You cannot opt out of these communications, as we are obligated by law to do so; however, such communications will be primarily service-oriented rather than promotional.

2.4 Marketing

We may also use your email address to send you other types of communications that you can control, including newsletters and special promotions. These communications are to:

  • provide you with information about Services we offer that are similar to those that you have already inquired about or purchased;
  • provide news about currency market movements, marketing and advertising messages, updates on the services we offer, and promotional offers based on your activities when using our Services;
  • make suggestions and recommendations to you about Services that may interest you, which may be based on your activity on our Website(s);
  • keep you informed about currency market events and news; and
  • tell you about new products and features we are developing that you may find useful.

You can choose whether to receive some, all, or none of these communications.

2.5 Service improvements and account management

We will use your personal information to deliver and improve our Services and manage your account, including:

  • verifying your identity, including during account creation;
  • performing credit and solvency checks, validating the accuracy of your personal information, and verifying it with third parties;
  • resolving disputes, collecting fees, and troubleshooting problems;
  • allowing us to manage risk and to detect, prevent, and/or remediate fraud or other illegal or prohibited activities;
  • detecting, preventing, or remediating violations of our policies, Terms and Conditions, or other user agreements;
  • providing you with customer support services including notifying you of changes to our Services, including any outages, and sending you emails relating to your account and transactions on your account;
  • improving our existing, and developing new, products, services, websites, and capabilities; and,
  • as part of our efforts to keep our site safe and secure, including managing and protecting our information technology infrastructure.
 

2.6 Third-party information

We will combine third-party information with personal information you give to us and that we collect about you. We will use all of this information:

  • to help us better understand your financial circumstances and behaviour so that we may make decisions about how we manage your account;

to process applications for products and services available through us including making decisions about whether to agree to approve any applications.

3. Cookies

3.1 Information we may collect through cookies

As you navigate through and interact with our Website, 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 Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website;
  • Information about your computer and internet connection, including your IP address, operating system, and browser type;
  • Information collected through third-party tracking pixels, such as Google Analytics, Facebook, LinkedIn, and Microsoft Ads; and,
  • Information collected through Website heat mapping software and pay-per-click ad click-fraud blocking software.
 

We may collect information about your consent for the use of cookies on our Website through cookie consent logs, which may include information such as your IP address and browser information.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking).

The information we collect automatically is statistical data and may include personal Information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns;
  • Store information about your preferences, allowing us to customize our Website according to your individual interests;
  • Speed up your searches;
  • Recognize you when you return to our Website.
 

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
  • Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
 

We take the privacy and security of your personal information seriously and we are committed to being transparent about the use of cookies and other automatic data collection technologies on our Website

3.2 Third-party use of cookies

Some content or applications on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our Website. 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.

You can opt-out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and/or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

4. Disclosure of Personal Information

We maintain a strict policy regarding the disclosure of your personal information. We may disclose personal information that we collect or you provide as described below:

4.1 To support our business and provide services to you

Just like most financial service providers, we work with third-party service providers who support our business operations, such as fraud prevention, customer service, and technology services. We may need to disclose user data to them from time to time so that the services can be performed. Our contracts dictate that these third-party business partners only use your personal information in connection with the services they perform for us and not for their own benefit.

By accepting this Policy and maintaining an account with us, you expressly consent to the transfer of your data to those third parties for the purposes listed.

4.2 Banks

When you ask us to process a currency or payment transaction, we will provide your personal information to the third-party business partners who are contracted to us to complete this transaction, for example passing bank details to a correspondent bank(s) or payment provider(s) involved in the transaction.

4.3 Anti-fraud, anti-money laundering, sanctions and risk management

To carry out the checks described above, we will provide your personal information to our third-party business partners who carry out these checks.

4.4 Reporting to regulators

As a regulated financial institution, we are required to report transactions to relevant financial regulators. We will provide your personal information to the regulators to meet these legal obligations.

4.5 Where required by law

We may disclose necessary personal information to the police and other law enforcement agencies, security forces, competent governmental, intergovernmental, or supranational bodies, competent agencies, departments, regulatory authorities, self-regulatory authorities or organizations, and other third parties, including Finseta Group companies, where we are legally compelled and/or permitted to do so.

4.6 Other purposes

We may also disclose necessary personal information for any other purpose disclosed by us when you provide the personal information, or for any other purpose with your consent.

5. Transferring data overseas

We may transfer personal information that we collect or that you provide as described in this Policy to our subsidiaries or affiliates, contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your 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 Canadian privacy legislation.

You are welcome to contact us to obtain further information about our policies regarding service providers outside of Canada. See Section 11 for contact details.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

6. Data Retention Policy

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Under some circumstances, we may anonymize your personal information so that it can no longer be associated with or identify you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

7. Security of Personal Information

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure, including but not limited to:

  • Only our authorized employees and our third-party business partners processing data on our behalf have access to your personal information. All our employees who have access to your personal information are required to comply with this Policy. All third-party business partners are requested by Finseta to ensure that any of their employees who have access to your personal information are bound by terms as strict as this Policy.. Contracts with third-party business partners acting as data processors for Finseta involving personal data require an adequate level of security and require that personal data is processed only as instructed by Finseta.
  • all personal information disclosed, shared, stored, or used and any transactions performed by you through our Website are encrypted.
  • we hold your data in secure data centers with high levels of physical and technical security, including using firewall systems, data encryption and anti-virus protection; and,
  • We use security surveillance systems to detect and prevent illegitimate access to and activities on our systems.
 

Unfortunately, the transmission of information via the Internet and other communication channels is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or through any means. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website or in our communication systems.

8. Access and Corrections

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.

If you want to review, verify, correct, or withdraw consent to the use of your personal information please contact our Privacy Officer, whose contact details are outlined in Section 11 of this Policy.

We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access the personal information that we hold about you or to make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

9. Withdrawing your consent

Where you have provided your consent to the collecting, use, and disclosure of your personal information, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, please contact our Privacy Officer, whose contact details are outlined in Section 10 of this Policy. Please note that if you withdraw your consent we may not be able to provide you with a particular product or Service. We will explain the impact to you at the time to help you with your decision.

10. Changes to this Privacy Policy

We may amend this Policy at any time. Any changes we may make will be posted on our Website, so please check back frequently. We will notify you in advance of any material changes to this Policy and obtain your consent to any new ways that we collect, use, disclose, and store your personal information.

Please check the Policy periodically for updates, as your continued use of our Website(s) after we make changes to this Policy will constitute your acceptance of, and agreement to, any changes. If you disagree with the terms of this Policy, you may close your account at any time.11. Privacy officer

We welcome your questions, comments, and requests regarding this Policy and our privacy practices. Please contact our Privacy Officer at:

Privacy Officer

FINSETA PAYMENT CORP.

1 Elmfield Avenue, Warrenpoint, Newry, County Down,

Northern Ireland, BT34 3HQ

compliance@finseta.com

We are committed to addressing any concerns you may have and will respond to your inquiry within a reasonable time.

11. Complaints

If you are not satisfied with our response to your privacy-related inquiry, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario, as applicable.

Office of the Privacy Commissioner of Canada

30 Victoria Street

Gatineau, Quebec K1A 1H3

Toll-free: 1-800-282-1376

Website: http://www.priv.gc.caI

 

Information and Privacy Commissioner of Ontario

2 Bloor Street East, Suite 1400

Toronto, Ontario M4W 1A8

Toll-free: 1-800-387-0073

Website: http://www.ipc.on.ca

By using our Services, you acknowledge and agree to the terms of this Policy.

We appreciate your trust in us and will continue to work diligently to protect your personal information and provide you with the best possible service.