GPC Financial Corporation Privacy Policy

Introduction

GPC Financial Corporation (GPCFC) is required to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), which governs the use, collection and disclosure of personal information in Canada. GPCFC is committed to maintaining the accuracy, confidentiality, and security of personal information.

Scope and Application of this Policy

Systems and processes used by GPCFC are largely owned, managed, and maintained by its parent company, Global Payments Direct, Inc. (Global Payments) or its affiliates. Global Payments provides payment products and services on behalf of GPCFC for commercial and non-commercial enterprises. Global Payments, GPCFC, and/or their affiliates have relationships with card issuers and merchants, providing products and services, which include payment card processing, point-of-sale terminal management and support, merchant accounting and funds transfer.

Types of Information We Collect

Personal information is any information about an identifiable individual and does not include information about corporations, partnerships or other non- individuals. Unless the context clearly indicates otherwise, the term “individual” refers to merchants who use GPCFC products and services, as well as any visitors to our web site. Depending on the nature of the services we provide to you, and subject to your consent where required, we may collect certain personal information from you, including:

• Contact information (name, address, telephone numbers, e-mail)
• Identification information, such as Social Insurance Number (SIN);
• Merchant contact Information (business name, address, contact information);
• Financial information including credit information and information related to business activity;

Cookies

GPCFC website may use cookies or similar technologies to improve the functionality of our website and provide visitors with a customized online experience. If you would like to browse the GPCFC website, you may do so without accepting cookies. However, you should understand that if you choose not to accept cookies, some areas of the GPCFC website may not function properly or optimally. If you prefer not to accept cookies, you may adjust your browser settings.

Use of personal information

At GPCFC, we collect, use and disclose personal information to provide you with the services you have requested, to respond to your inquiries, and to offer you additional products and services we believe you might be interested in. GPCFC may use your personal information for the following purposes:

• To determine your financial situation by collecting credit and related financial information from our affiliates, strategic partners, credit agencies, other financial institutions and from references provided by you;
• To facilitate the provision of our services by sharing your information with our third party service providers, credit and debit card issuers, credit and debit card associations, credit agencies and similar parties connected to credit or debit card services;
• To investigate potentially fraudulent or questionable activities regarding your merchant account(s) or the use of our services;
• For reporting purposes under credit or debit card association rules or regulations and to credit and debit card issuers, financial institutions, consumer reporting agencies or other credit or debit card related entities;
• To offer you related products and services that might benefit you;
• In the course of an actual or potential sale, reorganization, consolidation, merger or amalgamation of our business; and
• To comply with applicable laws and/or regulations and as otherwise required or permitted by applicable laws and/or regulations.

Disclosure to third parties

We sometimes contract with third parties who help us perform services related to the purposes noted above. Our service providers may, at times, be responsible for processing and handling some of the information we receive from you. We provide only the information necessary to perform the services, and providers are contractually prohibited from processing personal information for purposes other than to carry out the service they have been contracted to provide. Furthermore, as part of our agreements, our service providers are contractually obliged to protect your information in a manner that is consistent with GPCFC’s privacy policies and practices.

We may also be required to disclose Personal Information in response to requests by legal, government, or regulatory agencies with proper jurisdiction.

How we safeguard your information

We use industry standard technologies and maintain current security standards in an effort to ensure that your Personal Information is protected against unauthorized access, disclosure, inappropriate alteration or misuse.

Your rights

You have the right to be informed of the existence, use and disclosure of your personal information and to challenge the accuracy and completeness of the information and have it amended as appropriate. To obtain access to your records or to request a correction to a record you must make a written request. We may request payment of a small fee, in accordance with applicable law. Please describe the records you are requesting, being as specific as possible so that we can ensure our response meets your needs. We will respond to your request within 30 days or we will notify you of the need for additional information or the reasons why your access is denied.

To help us keep your personal information up-to-date, we encourage you to change, update, or amend inaccuracies and make corrections as often as necessary.

You also have the right to withdraw your consent for GPCFC to process your personal information; however, this may limit our ability to provide certain services. GPCFC will collect explicit consent from you when required by law prior to using or disclosing your Personal Information for new purposes.

To make a change or update to your Personal Information, you may do one of the following:

1. Submit a request in writing to: 3381 Steeles Avenue East, Suite 200, Toronto, Ontario M2H 3S7
2. Call the relevant Customer Care Centre at 1-800-263-2970 for GPCFC merchant-related matters, where one of our operators will be available to receive your request for a change in your personal contact information; or
3. Send a facsimile to us 416-847-4240 to request a change in your personal contact information.

Information retention and storage

GPCFC retains your personal information for business purposes only, for as long as reasonably necessary to provide you with our products and services. In addition, we may retain your personal information as long as necessary to comply with a legal obligation, resolve any disputes and enforce our rights and agreements.

Your personal information may be stored on our servers located outside the country where you reside, including in the United States, and may be subject to the laws of that country. GPCFC may also retain service providers to perform certain services and that in the event that a service provider is located in the United States or another jurisdiction, personal information may be processed and stored in that jurisdiction, and that country’s law enforcement or regulatory agencies may be able to obtain disclosure of Personal Information through the laws of those jurisdictions.

International transfers

When your personal information is transferred to another country outside the country in which you reside, we take appropriate steps to ensure such transfers are in accordance with applicable law, are carefully managed to protect your privacy rights and interests, and are subject to written agreements designed to ensure a substantially equivalent level of protection of your privacy rights.

If you have any questions or concerns about the GPCFC’s Privacy Policy or the information in this statement, please contact:

GPC Financial Corporation
Attn: Privacy Office
P.O. Box 4010, Station B Etobicoke, ON M9W 7H8
[email protected]
If you would like more information on PIPEDA, please refer to the website of the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.