Privacy and Cookie Policy
1.General Information
This Privacy and Cookie Policy applies to Personal Information (as defined below) that Advanced Payment Solutions Canada INC. (“APS”, “We”, “Us”) controls, collects, uses, or processes, stores, or discloses for the purposes stated herein only.
We control, collect, use, process, store or disclose Personal Information about You through APS Website, APS Application (as defined below) and/or by any other means indicated herein.
All Personal Information will be controlled, collected, used, processed, stored, or disclosed in certain circumstances pursuant to the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”).
2. Terms and Definitions
For the purposes of this Privacy and Cookie Policy:
“APS Application” means a software application developed specifically for use on small, wireless computing devices, such as smartphones and tablets, rather than desktop or laptop computers;
“APS Services” means foreign exchange dealing, issuing or redeeming money orders, money transferring, dealing in virtual currencies, payment service provider services;
“APS Website” means an internet website owned, operated and/or hosted by APS under the following domain name: www.aps.money;
“Cookie” means a small text file which is placed onto any device (e.g., computer, smartphone or other electronic device), when a user uses APS Website;
“Personal Information” means information about an Identifiable Individual;
“Identifiable Individual” is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
3. Personal Information Protection Principles
APS adheres to the following personal information protection principles:
(1) Identifying Purposes: APS shall identify the purposes for which Personal Information is collected at or before the time the information is collected;
(2) Consent: the knowledge and consent of the Identifiable Individual are required for the collection, use, or disclosure of personal information, except where inappropriate. Personal Information is only processed with the consent of the Identifiable Individual and ONLY for a permissible purpose such as fraud prevention, identity verification, or similar;
(3) Limiting Collection: the collection of Personal Information shall be limited to that which is necessary for the purposes identified by APS. Personal Information may only be collected for specific, transparent and objective purposes and processing activities must fit the purpose for which the Personal Information was collected. Information shall be collected by fair and lawful means;
(4) Limiting Use, Disclosure, and Retention: Personal Information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the Identifiable Individual or as required by law. Personal Information shall be processed and retained only as long as necessary for the fulfilment of those purposes;
(5) Accuracy: Personal Information shall be as accurate, complete, relevant, adequate and up- to-date as is necessary for the purposes for which it is to be used. Personal Information may not include more than required for the purpose of the processing. Personal Information must be controlled for error to prevent the processing of false and misleading data/information;
(6) Safeguards: Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information. Personal Information must be secured from unlawful use, loss, unintended deletion and harm;
(7) Openness: APS shall make readily available to Identifiable Individuals specific information about its policies and practices relating to the management of Personal Information;
(8) Individual Access: upon request, an Identifiable Individual shall be informed of the existence, use, and disclosure of his or her Personal Information and shall be given access to that information. An identifiable Individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate;
(9) Challenging Compliance: an Identifiable Individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the APS’s compliance; and
(10) Collecting, processing, using and disclosing of Personal Information shall be lawful, fair, and transparent, and collecting, processing, using and disclosing activities shall have lawful grounds.
4. Identifiable Person’s Rights Concerning Personal Information
An Identifiable Individual has the following rights in regard to Personal Information:
(1) Right to know whether Identifiable Person’s Personal Information is being processed;
(2) Right to know how Identifiable Person’s Personal Information is processed;
(3) Right to request rectification or erasure of Identifiable Individual’s Personal Information
that is inaccurate or incomplete;
(4) Right to erasure, meaning requesting for Identifiable Individual’s Personal Information to
be erased from APS records if there are no legitimate grounds for retaining it;
(5) Right to object to processing, meaning in certain cases Identifiable Individual’s right to object to processing of Identifiable Individual’s Personal Information, for example in the case of direct marketing;
(6) Right to restrict processing of Identifiable Individual’s Personal Information, e.g., if Personal Information is inaccurate or the processing is unlawful;
(7) Right to access the Personal Information collected from/about the Identifiable Individual, including the right to request and obtain a copy of the Personal Information collected;
(8) Right to lodge a complaint, meaning if an Identifiable Individual is not satisfied with the
way APS handles his/her/their Personal Information the right to file a complaint with a
supervisory authority; and
(9) Right to withdraw any given consent of processing of an Identifiable Individual’s Personal
Information.
5. Personal Information Collected
APS collects and processes Personal Information through several channels, including but not limited to:
(1) Online subscription forms;
(2) Conference or event registration;
(3) Telephone and emails;
(4) APS Website;
(5) APS Application; and/or
(6) Use of the APS Website.
Personal Information APS typically collects and processes may include but are not limited to:
(1) Name;
(2) Email address;
(3) Phone number;
(4) Job title;
(5) Organisation or company of employment;
(6) Physical address;
(7) IP Address;
(8) Device ID;
(9) Cryptocurrency wallet address(es);
(10) Identity documents including drivers license, passport, and proof of address;
(11) Corporate entity information including certificates of incorporation; and/or
(12) Payment instrument information including bank account numbers, bank statements, credit
card numbers, payment voucher numbers.
6. Purposes of Collecting, Processing, Storing and Using of Personal Information
APS collects, processes, stores, and uses Personal Information for the following purposes:
(1) to provide and maintain the APS Website;
(2) to notify You about changes to the APS Website;
(3) to provide any APS Services;
(4) to allow You to participate in interactive features of our service when You choose to do so;
(5) to provide customer care and support;
(6) to provide analysis or valuable information so that we can improve the APS Website;
(7) to monitor the usage of the APS Website;
(8) to detect, prevent and address technical issues;
(9) to establish and maintain a responsible commercial relationship with You;
(10) to process Your order, manage Your account;
(11) to understand Your needs and Your eligibility for any products and services we provide;
(12) to provide information to You about developments and new products, including changes and enhancements to the APS Website;
(13) to develop, enhance, and market products and services, and provide products and services to You;
(14) to provide You with news and other matters of general interest to You as our customer;
(15) as we believe reasonably necessary, advisable or appropriate to comply with our legal or regulatory obligations and to respond to legal, regulatory, arbitration or government process or requests for information issued by government authorities or other third parties or to protect Your, our, or others’ rights;
(16) to fulfill the requirements stipulated under the applicable anti-money laundering and counter-terrorist financing legislation.
With Your consent, APS processes Your Personal Information to send newsletters and campaigns and for other specific purposes You has given consent to.
7. Retention Period
Personal Information of an Identifiable Individual shall be stored until the purpose for which they were collected and processed has been fulfilled.
Personal Information shall be retained for a minimum of 7 (seven) years after the time of transaction or cessation of a business relationship.
You may withdraw Your consent at any time however where APS has obligations to retain Personal Information to comply with applicable anti-money laundering and counter-terrorist financing legislation requests for redaction may not be honored.
Any requests for further information in relation to the continued processing of specific data and requests for destruction of data should be made to [email protected].
8. Securing of Personal Information
APS has taken technical and organisational measures to mitigate risks that Personal Information will be subject to deletion, publication, alteration, misuse, or to fall into the hands of an unlawful party as part of its Data Protection Policy. A multi-layered security approach is in place, including physical security, access controls, IT security and use of safety protocols.
Any privacy breach where personal information has unintentionally been deleted, altered or made accessible to an unlawful party, APS will proceed according to its Data Protection Policy. Such Data Protection Policy includes APS employees’ awareness of the procedures they must follow to identify and report any suspected or actual privacy breach.
9. Transfer of Personal Information
Personal Information collected and processed by APS is never sold to third-party vendors under any circumstance. If compelled by a subpoena, production order, or similar regulatory order APS will provide information requested directly to law enforcement or the regulatory agency in question. APS complies with all valid requests for information from law enforcement and regulatory agencies.
10. Collecting and Processing of Personal Information Received from Citizens and/or Residents of the European Union Member States
For the purposes of Article 25(2) of Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, being fully compliant with PIPEDA, APS is considered as providing an adequate level of protection for Personal Information of an Identifiable Individual, who is a citizen or a resident of the European Union, transferred from the European Union member states to APS.
11. Cookies and Other Tracking Technologies
APS uses Cookies and/or similar tracking technologies to analyse user behaviour, administer APS Website and to collect information about users. This is done to personalise and enhance the APS Website and APS Application user experience. Cookies store information to help make the APS Website and APS Application function. Only APS can access the Cookies created by APS Website and APS Application.
The following types of Cookies may be used when you visit the APS Website:
Advertising Cookies
Advertising Cookies are placed on Your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to You. These cookies allow advertisers and ad servers to gather information about Your visits to the APS Website and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These Cookies are linked to a computer and do not gather any Personal Information about You.
Analytics Cookies
Analytics Cookies monitor how users reached the APD Website, and how they interact with and move around once on the APS Website. These Cookies let Us know what features on the APS Website are working the best and what features on the Site can be improved.
We also use Cookies that are retransmitted by an analytics or statistics provider to collect aggregated information on the number of users and how they visit the APS Website. These are also considered technical Cookies when they operate as described.
Analytics Cookies may collect information through log data, such as:
(1) internet protocol (IP) address;
(2) type of browser and device;
(3) operating system;
(4) name of the Internet Service Provider (ISP);
(5) country information;
(6) date and time of visit;
(7) web page of origin (referral) and exit;
(8) possibly the number of clicks.
We do not use this information to identify You, but rather to understand usage trends on the APS Website.
Technical Cookies
Technical cookies, which can also sometimes be called HTML Cookies, are used for navigation and to facilitate Your access to and use of the APS Website. They are necessary for the transmission of communications on the network or to supply services requested by You. The use of technical Cookies allows the safe and efficient use of the APS Website.
Our Cookies
Our Cookies are “first-party Cookies” and can be either permanent or temporary. These are necessary Cookies, without which the APS Website is not able to work properly or to provide certain features and functionalities. Some of these may be manually disabled in Your browser but may affect the functionality of the APS Website.
Personalization Cookies
Personalization Cookies are used to recognize repeat visitors to the APS Website. We use these Cookies to record Your browsing history, the pages You have visited, and Your settings and preferences each time You visit the APS Website.
Security Cookies
Security Cookies help identify and prevent security risks. We use these Cookies to authenticate users, protect user data from unauthorized parties and as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect the APS Website and APS Services generally.
Site Management Cookies
Site management Cookies are used to maintain Your identity or session on the APS Website so that You are not logged off unexpectedly, and any information You enter is retained from page to page. These Cookies cannot be turned off individually, but You can disable all Cookies in Your browser.
Third-Party Cookies
Third-party Cookies may be placed on Your computer when You visit the APS Website by companies that run certain services We offer. These Cookies allow the third parties to gather and track certain information about You. The majority of third-party Cookies consist of tracking Cookies used to identify online behavior, understand interests and then customize advertising for You. These Cookies can be manually disabled in Your browser.
Session Cookies
We use session Cookies to keep track of how You browse on Your visits to the APS Website. Temporary session Cookies are deleted automatically at the end of the browsing session – these are mostly used to keep track of what You do from page to page, such as with keeping track of what is in Your cart.
Persistent Cookies, on the other hand, remain active longer than just one particular session. These help Us recognize You. We also use them to store Your login and password info, if You choose, and to store Your user settings.
Control of Cookies
Most browsers are set to accept Cookies by default. However, You can remove or reject Cookies in Your browser’s settings. Please be aware that such action could affect the availability and functionality of the APS Website.
For more information on how to control Cookies, check Your browser or device’s settings for how You can control or reject Cookies.
Blocking all Cookies will have a negative impact upon the usability of many websites. If You block Cookies, You will not be able to use all the features on the APS Website.
In addition to Cookies, We may use web beacons, pixel tags, and other tracking technologies on the APS Website to help customize the APS Website and improve Your experience. A “web beacon” or “pixel tag” is a tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails and acquire other statistical data. They collect only a limited set of data, such as a Cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, You can limit their use by controlling the Cookies that interact with them.
12. Changes to this Privacy and Cookie Policy
APS reserves the right to revise this Privacy and Cookie Policy and make changes to it at any time. APS will inform You via notification published on the APS Website and in APS Application or via other means of contact when this considered necessary.
13. How to Contact APS
You can contact APS by post, email, or phone, if You have any questions about this Privacy and Cookie Policy or the information we hold about You, to exercise a right under PIPEDA or to make a complaint.
Our contact details are shown below:
ADVANCED PAYMENT SOLUTIONS CANADA INC.
Postal address: 490-4 BOW VALLEY SQUARE 3, 255 5 AVE SW CALGARY, AB, CANADA T2P3G6
Email address: [email protected]