“Personal Data” means any information that identifies or is reasonably capable of identifying an individual, directly, or indirectly, such as a name or identification number, an online identifier or other identifiable characteristics and other information that is being associated with an identified or reasonably identifiable individual.
Luxon may also collect, create, process, store, protect, disclose, share and transfer your Non-Personal Data as part providing our Services and/or otherwise as part of our business operations. For example, Luxon may use anonymised and aggregated transactional information for commercial purposes such as reviewing or analysing transaction data and patterns.
This Notice is issued by Luxon Pay Ltd (No. BC1360780), with its registered office at Bow Valley Square 3, 490, 205 – 5, Avenue SW, Calgary, Alberta, T2P 2V7, Canada. (“Luxon Pay“, “Luxon” “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our Services, and visitors to our premises (together, “you”). For the purposes of this Notice, Luxon is the Controller.
As a Controller, Luxon is required to use appropriate security safeguards in order to protect Personal Information against loss or theft, as well as unauthorised access, disclosure, copying, use, or modification. This includes any Personal Information in our possession or custody and extends to Personal Information that has been transferred to a third party for Processing and we must ensure any third party process provides a comparable level of protection of Personal Data.
We will only collect Personal Data relevant to the purpose for which it will be used, and which will be limited to what is necessary for that purpose.
Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:
Please note that third parties you interact with may have their own privacy policies, and we are not responsible for their operations or their use of the data they may collect. Information collected by third parties is governed by their privacy practices and we are not responsible for unauthorized or unlawful third-party conduct. We encourage you to learn and understand the privacy practices of any relevant third parties you engage with.
We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, Apps, or Services, including where those data are collected from different devices.
We Process the following categories of Personal Data about you:
We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.
The legal basis for the Processing of your Personal Data is dependent on the context in which we collect it and the purposes for which it is used. Subject to Applicable Law, the purposes for which we Process Personal Data, and the most common legal bases on which we perform such Processing, are as follows:
We disclose Personal Data within Luxon, for legitimate business purposes and the operation of our Sites, Apps, or Services to you, in accordance with Applicable Law. In addition, we disclose Personal Data to:
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under Applicable Law. Third party processors we use regularly, but which may change from time to time, include but are not limited to:
We Process Personal Data for the purposes of automated decision-making and Profiling, which is defined in Section (19).
Automated decision-making and Profiling, are carried out for the following purposes:
You have a legal right to a meaningful explanation of and/or to contest, or reject being subject to automated decision making and Profiling and get human intervention on a decision as detailed further in (14) Your legal rights. However, these rights may not apply where the automated decision made, or Profiling is (i) Is necessary for entering into or performing a contract with you; (ii) Is authorised by law and there are suitable safeguards for your rights and freedoms; or (iii) Is based on your explicit consent. In these situations, you may still be able to obtain human intervention and express your point of view by contacting us using the details in (18) Complaints and contact details.
Because of the international nature of our business, we transfer Personal Data within Luxon and to third parties as noted in Section (7) above, in connection with the purposes set out in this Notice. For this reason, we may transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of Personal Data. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided in Section (18) below.
Please note that when you transfer any Personal Data directly to a recipient outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with Applicable Law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security or confidentiality of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
In the event of a data breach by us or one of our Processors, we are obligated to:
We take every reasonable step to ensure that:
From time to time we may ask you to confirm the accuracy of your Personal Data.
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:
(1) We will retain Personal Data in a form that permits identification only for as long as:
Plus (2) the duration of:
And (3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under Applicable Law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
You have many rights that you may be able to exercise in relation to your Personal Data. These rights may apply under a number of different regulations, for example, the General Data Protection Regulation (GDPR) which is generally applicable to EEA residents.
Subject to Applicable Law, you may have the following rights regarding the Processing of your Relevant Personal Data:
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (18) below. Please note that:
All use of our Sites, Apps, or Services is subject to our Terms and Conditions. We recommend that you review our Terms and Conditions regularly, in order to review any changes we might make from time to time.
We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, or Services that may be of interest to you. If we provide Sites, Apps, or Services to you, we may send information to you regarding our Sites, Apps, or Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under Applicable Law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, or Services you have requested.
If You wish to make a complaint about the Services or to exercise one of your legal rights outlined in Section 14, you can email us at email@example.com with brief details of your complaint or request and the phone number and email address associated with your eWallet or request our complaint form and send to our service email address on the form.
We will provide you a full response to your complaint or request by email within 15 Business Days after the date we receive your complaint. In exceptional circumstances where we are unable to respond in full to your complaint or request, we will inform you of this giving our reasons for the delay and the timeframe within which you will receive a full reply, which in any event shall be within 35 Business Days of the date we received your complaint or request.
Contact details for Luxon are as follows:
Luxon Pay Ltd Bow Valley Square 3, 490, 205 – 5, Avenue SW, Calgary, Alberta, T2P 2V7, Canada Email: firstname.lastname@example.org
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Luxon and Luxon Pay are trading names of Luxon Pay Ltd, a company registered in Calgary, AB, Canada (No. 2024517852), with its registered office at Bow Valley Square 3, 490, 205 – 5 Avenue SW, Calgary, Alberta, T2P 2V7, Canada. Luxon Pay Ltd is authorised by FINTRAC as a Money Service Business (MSB No. M22974394). Terms and Conditions apply.