Clik2pay Privacy Policy

Last updated July 1, 2021
© FOGHORN PAYMENTS INC.
20 Bloor Street East
PO Box 75039
Toronto, ON
M4W 3T3

Protecting the privacy, security and confidentiality of personal information is fundamental to the way Clik2pay does business. This Privacy Policy explains the ways we help protect personal information, and respect and support the trusted relationship between our business clients (Clients) and their customers (Consumers). For Clik2pay, “Information” means any personal, transaction and other details that we require to support Clik2pay Services.

By using the Clik2pay Services, including through a computer or mobile device, each Client and Consumer accepts the terms of this Privacy Policy and consents to our collection, use, disclosure and retention of their information as described in this Privacy Policy (including to contact them), and for all other purposes permitted under applicable personal information privacy statutes, anti-spam legislation, and consumer protection laws. Our website and Services are not targeted or directed at children under the age of 13 and do not knowingly collect or store any personal information from children under the age of 13.
We may amend this Privacy Policy from time to time by posting a revised version and updating the “Last updated” date above. The revised version will be effective at the time we post it. Continued use of our Services constitutes acceptance of any amendment of this Privacy Policy.

The Privacy Policy consists of four key principles:

  1. Collecting and using information: Before we ask for any personal information about the Client or the Consumer, we will explain why it is needed and how we intend to use it. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain consent if we wish to use this information for any other purpose.
  2. Releasing information: We may need to provide personal information to our suppliers who assist us in serving Clients. We may also need to release the information if we are required to do so by law and self-regulatory organizations to prevent, detect or suppress financial abuse, fraud and criminal activity.
  3. Protecting information: We will protect information with appropriate safeguards and security measures. We will retain information only for the time it is required and for the purposes we explained.
  4. Respecting privacy concerns: We will investigate and respond to Client and Consumer concerns about any aspect of our handling of their information.

In this Privacy Policy, we explain how we fulfil each of these important principles.

We collect the information we need and only use it for the purposes explained to the Client and Consumer.

Personal information is required to support transaction processing and communications, and to satisfy valid information requests from Interac™, banks, regulators, and other organizations who are legally entitled to make such requests.

When we initiate a transaction, there is a requirement to obtain the following Consumer information from the Client, in order to (a) successfully address and deliver a message to a Consumer if required, and (b) to meet risk management, fraud monitoring and tracing requirements of the payment network (Interac™):

  • Consumer name, and
  • Contact information: ONE OF email address OR cell phone #.

We ask for the Client’s account number, in order to (a) help the Consumer verify their billing details, though only the last four digits of the Client account number are presented to the Consumer, and (b) uniquely identify a Consumer and therefore to detect and avoid duplicate transactions.

When transactions are returned from the sending bank, we receive the Consumer’s name and bank of record, which we maintain associated with the transaction in case tracing of transactions is required, or in case the Client requests such information.

When completing a Clik2pay transaction through the Internet or through a mobile device, we may collect device level information about that Consumer. This information will help to identify higher risk transactions and monitor potential fraud or suspicious transactions.

Having Consumer information helps us determine preferences and consider enhancements or other service offerings, such as instalments, receipts and deferral plans.

When a Consumer is using our website, we may monitor and/or record browsing habits to better understand usage of our on-line assets.

If the Client provides us information about a specific Consumer to resolve a complaint, we may learn additional Consumer information. We will only use this information to address comments and/or reply to questions, and we may store the communication and our reply in case we correspond further.

If a Consumer receives an email claiming to be from Clik2pay that he/she believes to be fraudulent, he/she should not open, respond or click any links or open attachments contained within the email. Consumers may be instructed to notify us immediately by forwarding a copy of the email to us at admin@clik2pay.com and then delete the email.

In order to provide certain services on mobile devices, we may require location information. If the Client or Consumer does not consent to collection of this information, then they cannot use the corresponding Services. Clients and Consumers can stop our collection of location information at any time by changing the preferences on their mobile devices. If the preferences are changed, our Services may no longer function. Clients and Consumers also may stop our collection of location information through the Services by following the standard uninstall process to remove all Clik2pay mobile applications from their devices.

We may send cookies to Client or Consumer computers or mobile devices. Cookies are small data files that are stored on a hard drive or in device memory when a Client or Consumer visits a website or views a message. Cookies support the integrity of our registration process, retain Client and Consumer preferences, and help evaluate and compile aggregated statistics about user activity.

We only release information where it is required to deliver the Clik2pay Services.

We will obtain the Client’s consent to release any information to third parties required to deliver Clik2pay Services. To deliver email and text messages, Clik2pay must provide an email address and mobile number to our service provider Twilio. Twilio’s privacy policy can be read at the following link: https://www.twilio.com/legal/privacy#how-twilio-processes-your-end-users-personal-information

The account number of the Client and transaction data will be shared with Interac™ and the Client’s bank to facilitate the Clik2pay payment transaction.

Client and Consumer information may be disclosed in response to valid demands or requests from governments, regulators, courts and law enforcement authorities.

We do not sell or rent customer lists or personal information to others.

We protect information with appropriate safeguards and security measures.

We have security standards to protect our systems and Client and Consumer information against unauthorized access and use.

Our systems have been designed to ensure that email address, mobile number, first name and Client account number are always private and confidential. Nevertheless, Clik2pay cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use Client or Consumer personal information for improper purposes. If any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

All our suppliers and agents, as part of their contracts with Clik2pay, are bound to maintain confidentiality and may not use information for any unauthorized purpose. Protecting the confidentiality of information is also specified in our employment agreements. Our employees are familiar with this Privacy Policy and procedures to safeguard Client and Consumer information.

When we provide information in response to a legal inquiry or order that we believe to be valid, we disclose only the information that is legally required.

Client and Consumer data is stored on Amazon Web Services (AWS), encrypted in accordance with information security standards, and located in Canada.

We retain information only if it is required for the reasons it was collected. We are required to retain transaction data for a period of 7 years following completion of the transaction. We will destroy, delete, erase or convert it to an anonymous form after that point.

We take any complaints seriously – and are committed to helping resolve complaints.

Usually, the best way to address the complaint is to raise the issue as soon as it comes up with the person the Client or Consumer is dealing with. Even if the Client or Consumer doesn’t notice the issue right away, the Client or Consumer can always get in touch with us at any time to voice their complaint.

Before beginning, be ready to have any supporting documents available and consider what solution may be appropriate.

To tell us about any concerns or complaints or questions regarding this Privacy Policy, please contact us at admin@clik2pay.com. We may request additional details regarding the concerns and may need to engage or consult with other parties in order to investigate and address the issue. We will keep records of the request and any resolution.

If the resolution provided is unsatisfactory, the complaint can be escalated in the following ways:

  1. The Client or Consumer can ask the individual they are dealing with to escalate on their behalf.
  2. Escalate the complaint directly with Clik2pay management, using the following contact information.

Mike Bradley
Founder & CEO
mike@clik2pay.com

If the results of our investigation or any resulting corrective measures remain unsatisfactory, the Client or Consumer may be entitled to make a written submission to the Privacy Commissioner in their jurisdiction or to the Office of the Privacy Commissioner of Canada at the address below:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3
https://www.priv.gc.ca/en