Privacy Policy
SnapPay Inc.
LAST UPDATED: July 23, 2026
This Privacy Policy (the “Policy”) describes how SnapPay Inc. (“SnapPay”, “we”, “us” or “our”) collects, uses, discloses, stores, protects and disposes of personal information. It applies when individuals use or interact with SnapPay’s payment products, point-of-sale devices, websites, onboarding services, merchant portal, email, telephone support or other services.
This Policy should be read together with any additional notice or consent presented at the time personal information is collected.
1. Meaning of Personal Information
“Personal information” means information about an identifiable individual. It does not generally include information that is solely business contact information, such as a person’s professional title, business address, business telephone number or business email address, when used for business purposes.
2. Personal Information We Collect
Educational Payments. When an individual uses a SnapPay product to make an online payment to an educational institution, we may collect information such as the student’s name, date of birth, student identification number and gender. We may also collect the name, telephone number and other identifying information of a person making the payment on the student’s behalf.
Merchant Payments. When an individual uses a SnapPay product to make an online payment to a merchant, we may collect information such as name, telephone number, email address, WeChat ID, payment details and transaction information.
Business Client Onboarding and AML/KYB. When SnapPay onboards or reviews a business client, we may collect personal information relating to beneficial owners, directors, officers and authorized representatives. This information may include legal name, date of birth, residential address, contact information, ownership or control information, occupation or business role, government-issued identification details and information required for identity verification and regulatory screening.
Website and Communications. When an individual visits our website or contacts us, we may collect contact details, correspondence, device and browser information, IP address, cookie data, website usage information and other information voluntarily provided to us.
3. How We Collect Personal Information
We may collect personal information directly from the individual, from a business client or its authorized representative, through onboarding forms and agreements, through payment and service channels, from government-issued documents, through our website and communications, and from identity-verification, fraud-prevention, sanctions-screening and other service providers where permitted by law.
SnapPay limits collection to information that is reasonably necessary for the purposes identified in this Policy and uses fair and lawful means of collection.
4. Purposes for Collection, Use and Disclosure
SnapPay may collect, use and disclose personal information for the following purposes: processing and administering Educational Payments and Merchant Payments; confirming the identity of students, purchasers, beneficial owners and authorized representatives; conducting client onboarding, KYB and AML/CTF due diligence; performing sanctions, politically exposed person, watchlist, adverse-media and fraud screening; complying with FINTRAC and other legal or regulatory obligations; responding to inquiries and support requests; issuing invoices and administering accounts; protecting SnapPay, its clients and its services; detecting, preventing and investigating fraud, security incidents and unlawful activity; administering and improving our website and services; and sending marketing communications where the individual has consented or where otherwise permitted by law.
SnapPay will not use or disclose personal information for a materially new purpose without obtaining additional consent, unless the use or disclosure is permitted or required by law.
5. Consent
For SnapPay’s acquiring program, consent is obtained through the merchant onboarding process and the Merchant Agreement. By completing the onboarding process, entering into the Merchant Agreement and providing or authorizing the provision of personal information for the identified purposes, the business client and relevant individuals provide implied consent to SnapPay’s collection, use and disclosure of that information, as permitted by applicable law.
The implied consent established through the merchant onboarding process and Merchant Agreement applies to personal information relating to beneficial owners, directors, officers and authorized representatives where that information is provided or authorized for business-client onboarding, identity verification, AML/KYB compliance, fraud prevention, sanctions and regulatory screening, and related legal or regulatory requirements.
SnapPay records and retains the applicable Merchant Agreement, onboarding records and other evidence supporting implied consent in accordance with applicable legal and regulatory recordkeeping requirements.
An individual may withdraw consent, where legally permitted, by submitting a written request to SnapPay’s designated Compliance Officer using the contact information in Section 17. SnapPay will explain any resulting service limitations and any legal, regulatory or contractual requirements that prevent or limit the withdrawal.
Consent may not be required where collection, use or disclosure is permitted or required by law, including certain circumstances involving fraud prevention, investigations, legal proceedings, law-enforcement requests or regulatory reporting.
6. Disclosure of Personal Information
SnapPay discloses personal information only as reasonably necessary for the purposes described in this Policy, with consent, or as otherwise permitted or required by law.
Educational institutions and merchants. We may disclose the information needed to facilitate a payment and confirm the identity of the student or purchaser. These recipients are not authorized by SnapPay to use the information for unrelated purposes.
Technology, identity-verification and compliance service providers. We may provide personal information to service providers that support cloud hosting, secure storage, identity and document verification, fraud prevention, sanctions screening, politically exposed person screening, watchlist and adverse-media screening, and the secure operation of our services. These service providers may process identification information, government-issued identification documents and other information reasonably necessary to perform their services on SnapPay’s behalf.
Authorities and legal disclosures. We may disclose personal information to FINTRAC, law-enforcement agencies, courts, regulators or other authorities where disclosure is legally permitted or required, or where necessary to protect SnapPay’s rights, safety or property.
Service providers are given only the information reasonably necessary to perform their functions and are required to protect personal information through appropriate contractual, privacy and security obligations.
7. Storage of Personal Information
SnapPay’s production systems and data are hosted in Canada. Personal information is stored and processed exclusively within Canada.
8. Security Safeguards
SnapPay uses administrative, technical and physical safeguards appropriate to the sensitivity of the information. These safeguards include data classification and need-to-know access; role-based access controls; unique user credentials and multi-factor authentication for remote access; periodic access reviews and prompt access revocation; firewalls and network segmentation; encryption in transit and at rest; controlled key management; secure configurations, patching, anti-malware, vulnerability scanning and penetration testing; centralized logging and monitoring; time-limited vendor access; employee screening and security training; encrypted and redundant backups; restoration testing; and documented incident-response and breach-escalation procedures.
No method of transmission or storage is completely secure. SnapPay continuously reviews and improves its safeguards based on the sensitivity of the information, identified risks and applicable requirements.
9. Limiting Retention and Secure Disposal
SnapPay retains personal information only for as long as necessary to fulfil the identified purposes and satisfy applicable legal, regulatory and legitimate business requirements.
AML/KYB, beneficial-ownership, screening, transaction, investigation and regulatory reporting records are retained for the periods required under applicable FINTRAC recordkeeping requirements, generally for at least five years based on the applicable record and triggering event. Information may be retained longer where another legal, regulatory or documented business requirement applies.
Once the applicable retention period has expired and the information is no longer required, SnapPay securely deletes or destroys it in accordance with its Information Security Policy and approved disposal procedures. Electronic records are securely deleted or wiped; paper records are securely destroyed; and media that cannot be reliably wiped is physically destroyed through an approved process.
Destruction may be suspended where information is subject to a legal hold, investigation, audit, dispute or other legal or regulatory requirement. Third-party providers must return or securely delete SnapPay data when their services end, where appropriate.
10. Accuracy
SnapPay takes reasonable steps to ensure that personal information is accurate, complete and up to date for the purposes for which it is used. Individuals may submit an access or correction request in writing to SnapPay’s designated Compliance Officer. SnapPay verifies the requester’s identity, reviews the request, corrects inaccurate or incomplete information where appropriate, and maintains a record of the request and response.
11. Access and Other Privacy Rights
Subject to applicable law, an individual may request confirmation of whether SnapPay holds personal information about them, access to that information, an explanation of how it has been used and disclosed, and correction of inaccurate or incomplete information. An individual may also withdraw consent where applicable and submit a privacy inquiry or complaint.
Requests must be submitted in writing using the contact information in Section 17. SnapPay may request information reasonably necessary to verify the requester’s identity. SnapPay will respond to an access request within 30 days of receipt. Where permitted by applicable law, SnapPay may extend this period and will provide the individual with notice of the extension, the reason for the extension, the revised response date and any applicable right to complain. SnapPay will explain any lawful refusal or limitation.
12. Marketing Communications
SnapPay may send marketing communications about products and services where the recipient has consented or where otherwise permitted by law. A recipient may withdraw consent to marketing communications at any time by using the unsubscribe mechanism in the message or contacting SnapPay. Withdrawal from marketing communications does not affect service, transactional, security or legally required communications.
13. Website Use and Cookies
SnapPay may use cookies and similar technologies to operate its website, remember preferences, understand browsing activity and improve website performance. We may use analytics service providers to help analyze how visitors use the website.
Our website may contain links to websites that SnapPay does not own or control. SnapPay is not responsible for the privacy practices of those third parties, and individuals should review the privacy policy of each external website.
14. Biometric Information and Automated Decision-Making
SnapPay does not collect or process biometric information in connection with the client-onboarding process described in this Policy and does not use artificial intelligence or solely automated decision-making to make onboarding, identity-verification or AML/KYB decisions. Such decisions are reviewed by authorized personnel.
If SnapPay proposes to introduce biometric processing or automated decision-making in the future, it will complete the required privacy and legal review, update its notices and obtain any consent required by applicable law before implementation.
15. Privacy Inquiries, Complaints and Escalation
Privacy inquiries, access or correction requests, complaints and escalation requests may be submitted in writing to SnapPay’s designated Compliance Officer using the contact information in Section 17.
SnapPay will acknowledge, investigate and respond within the timelines required by applicable privacy laws. If a matter is not resolved, the individual may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.
16. Updates to This Policy
SnapPay may update this Policy from time to time to reflect changes in its practices, services or legal requirements. The “Last Updated” date at the beginning of this Policy indicates when it was most recently revised. SnapPay will provide appropriate notice of material changes through its website or other suitable channels and will retain prior versions for reference.
17. Contact Information
Compliance Officer
SnapPay Inc.
Address: 800-2810 Matheson Blvd E. Mississauga, Ontario L4W 4X7, Canada
Telephone: (905) 279-1717
Email: info@snappay.ca