FintechWerx International Software Services Inc., doing business as FintechWerx (“FTW”, “we”, or “us”) values your privacy. This policy (the “Privacy Policy”) applies to any use of the services available through the FTW website at [https://dev2.fintechwerx.com](https://dev2.fintechwerx.com) (the “Site”) and any mobile applications (each an “App”) through which they may be made available (the “Services”).

This Privacy Policy is designed to explain how we collect, use, store, retain, disclose, disseminate, or otherwise make available (collectively, “Process”) your Personal Information (as defined below) when you use the Services.

PLEASE READ THIS POLICY CAREFULLY. By creating an account and clicking on ‘I agree’ or by accessing the Services, you acknowledge that you have read, understand, and agree to be legally bound by this Privacy Policy, and other policies incorporated herein by reference.

 

MODIFICATIONS TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, in our sole discretion. We may modify this Privacy Policy by providing notice via one or more of the following methods:

• By email to the email account used to create your account

• By updating the ‘last updated’ date listed above

• By your acknowledgement as part of your account login

We strongly recommend that you frequently review the Privacy Policy to ensure that you understand it and how it applies to your access to and use of the Services. By continuing to use or access the Services, you confirm your agreement to the modified Privacy Policy. If you do not agree, your sole remedy is to discontinue use of the Services and close your account.

INFORMATION WE COLLECT

What is Personal Information?

Privacy laws in Canada generally define “Personal Information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. This means Personal Information is any information or data relating to you that can be used to identify you, directly or indirectly, or to contact you.

1. Your Basic Information (When you open an account with us)

• What We Collect:

  • Name

  • Address

  • Date of birth

  • Phone number

  • Email address

  • Government-Issued Identification

  • Nationality or citizenship (if your passport has been provided as identification)

     

• How We Use This Information:

   

  • To verify your identity (to protect you against identity theft or fraud)

     

  • To provide you with the use of our Services (e.g., to allow us to put you in touch with our merchants, to contact you about issues with our Site, to allow you to create a WerxID, to invoice you)

     

  • To advertise and market products or features to you

     

  • To verify we are speaking to you

     

  • To notify you about changes to our Site or any products or services we offer or provide through it

     

  • To allow you to participate in interactive features, social media, or similar features on our Site

  • To comply with legal requirements

  • To prevent fraudulent use of our services

2. Additional Information (When you upload information to your account)

• What We Collect:

  • Gender

  • Employer Information

  • Educational Information

  • Professional Information

  • Certifications

  • Memberships

  • Correspondences

  • Information you share on the Network Commons

     

• How We Use This Information:

   

  • To verify the information we have added to your WerxID

     

  • To verify the information you provide to our merchants

     

  • To verify the information you have shared in the Network Commons

     

  • To provide you with our Services

     

  • To carry out our obligations and enforce our rights arising from any contracts with you

     

  • To conduct fraud and risk monitoring

     

  • To comply with legal requirements (such as “know your customer”, anti-money laundering, or anti-terrorism laws)

     

3. Payment Information (When you make payments to us)

• What We Collect:

   

  • Payment information (method of payment, bank details, credit/debit card, card number, or other payment card information)

     

  • Transaction information (regarding transactions made relating to the Services)

     

• How We Use This Information:

   

  • To manage and process your payments

     

  • To carry out our obligations and enforce our rights arising from any contracts with you

     

  • To process warranties and returns

     

  • To conduct fraud and risk monitoring

     

  • To comply with legal requirements

4. Additional Information About Yourself You Voluntarily Disclose

If you authorize us or third parties to do so, we may also collect information about you from other sources such as third-party service providers, our partners or affiliates, public databases, identity verification providers, merchants who use the Services, advertising networks, analytics providers, and social media platforms. This additional information allows us to advertise and market products, features, and additional Services to you.

• How We Use This Information:

  • To allow us to better connect you with our merchants

  • To advertise and market products, features, and additional Services to you

5. Non-Personal Information & Cookies

What Are Cookies?

Cookies are small data files that are stored in your device memory or on your hard drive when you visit a website. Cookies may be used as a mechanism to recognize you, record behavior, and/or customize your experience with the Site and Services. They can also be used to monitor Site activity, mitigate risk, measure the effectiveness of promotions, and prevent potential fraud. If you choose to disable cookies, your use of the Site or Services may be limited or unavailable.

We may use this information to ensure that the Services function properly, to determine how many users have visited certain pages or opened messages, or to prevent fraud. We also work with analytics providers which use cookies and similar technologies to collect and analyze information about the use of the Services and report on activities and trends.

Most internet web browsers are set to accept cookies and local storage by default.

Data Collection

As you navigate through and interact with our Site, 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 Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.

   

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

   

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising, please visit the Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Site and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

Some content or applications on the Site, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. We do not control these third parties’ tracking technologies or how they are used.

HOW WE RETAIN YOUR PERSONAL INFORMATION

We will retain and store your Personal Information until you close your account with us; however, you have the right to update, change, or delete your Personal Information (see the HOW TO ACCESS, CHANGE, UPDATE OR DELETE YOUR PERSONAL INFORMATION section below). Deletion or destruction of Personal Information shall be done according to FTW’s data destruction policy.

If you share your Personal Information with a merchant or other third party, that information will be governed under the merchant or third party’s privacy policy. We are not responsible for the privacy practices of any third party, including merchants who use the Services.

HOW WE SHARE YOUR PERSONAL INFORMATION

There are situations where FTW may share your Personal Information with our third-party service providers, merchants, partners, affiliates, and other parties as described in our Terms of Service and this Privacy Policy. We may share a summary of your Personal Information with various merchants who utilize FTW Services and that you shop at. By entering into our Terms of Service and agreeing to this Privacy Policy, you are affirmatively opting into this sharing of your Personal Information.

FTW service providers and affiliates are required to handle Personal Information consistent with this Privacy Policy and according to our instructions. They cannot use your Personal Information shared by us for their own purposes, and must delete or return it once they have completed our request.

We may also disclose Personal Information for national security, law enforcement, or other issues of public importance where disclosure is necessary or appropriate, to enforce our Terms of Service, to protect our operations or users, or in the event of a reorganization, merger, or sale of FTW.

HOW WE PROTECT YOUR PERSONAL INFORMATION

FTW uses reasonable administrative, technical, and physical safeguards to protect your Personal Information, taking into account the nature of your data, the processing of this data, and threats posed. We conduct periodic reviews of these safeguards and work to improve them to keep your information safe.

However, as an online electronic system, we cannot guarantee that there will be no loss, misuse, unauthorized access, acquisition, or alteration of your Personal Information. No security measure is perfect or impenetrable. If you believe that any of your Personal Information has been compromised, please contact us immediately.

WHERE YOUR INFORMATION IS STORED AND PROCESSED

FTW is based in Canada, and your Personal Information may be stored or processed in Canada or in the United States. Our operations are supported by a network of computers, servers, IT, and third-party service providers around the world, including the European Union.

In connection with providing the Services, it may be necessary for us to transfer your Personal Information to third parties outside the European Economic Area (“EEA”). If your Personal Information is subject to such transfer, we shall take reasonable protective measures and have appropriate contractual protections in place. By using our Services, you consent to your Personal Information being transferred to other countries.

PRIVACY OF MINOR CHILDREN

We do not knowingly request or collect Personal Information from any person under the age of 18 or the legal age of the province in which you reside (a “Minor”). Use of the Services by a Minor is expressly prohibited by our Terms of Service. If we learn that we have inadvertently collected the Personal Information of a Minor, we shall immediately take steps to delete the information as soon as possible.

HOW TO ACCESS, CHANGE, UPDATE OR DELETE YOUR PERSONAL INFORMATION

To view, change, or update your Personal Information, you may log into your account to make such changes.

Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service.

There may also be situations where we cannot grant your request (e.g., if we are legally obligated to keep a record, if it would undermine anti-fraud/security purposes, or if it jeopardizes the privacy of others).

If you are unable to make said changes in your account, wish to request that your information be deleted, want to withdraw consent, or need other changes, you may email us at support@emtwerx.com.

HOW TO CONTACT US

We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices.

• General Privacy Questions: support@fintechwerx.com

• Account/Services Support: support@emtwerx.com