About this Privacy Policy
NewHorizon Tech Inc., operating as WegoPay (“WegoPay,” “we,” “us,” or “our”), is committed to protecting personal information in accordance with applicable Canadian privacy laws.
This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with the WegoPay website; merchant and partner inquiries; merchant and partner onboarding; WegoPay payment services; the WegoPay Merchant Center and Partner Center; and related support, compliance, security, and business operations.
This Policy applies to website visitors, merchants, merchant and partner representatives, authorized platform users, prospective merchants and partners, and other individuals whose personal information we handle in connection with our services.
Information We Collect
The information we collect depends on how an individual or organization interacts with WegoPay.
Website and technical information
When someone visits our website, our hosting, network, and security systems may automatically process limited technical information, such as:
- IP address
- browser and device type
- operating system
- requested pages and access times
- referring page, where available
- security, diagnostic, and error logs
- information required to maintain website availability, security, and performance
Our public website currently does not use advertising trackers, marketing cookies, Google Analytics, Meta Pixel, or online chat tools.
Inquiries and communications
When someone contacts WegoPay, we may collect:
- name
- company or organization name
- job title or role
- email address and telephone number
- information included in the inquiry
- related correspondence and support records
Please do not send identification documents, banking information, passwords, or other sensitive information through ordinary email unless WegoPay has specifically requested the information and provided an appropriate submission method.
Merchant information
In connection with merchant onboarding, administration, payment services, settlement, compliance, or support, we may collect:
- legal and operating names
- business registration and incorporation information
- business, registered, and operating addresses
- contact details
- business activities, products, services, websites, sales channels, and expected transaction activity
- applicable licences, permits, and supporting business documents
- information about directors and authorized representatives
- information about individuals who directly or indirectly own or control at least 25% of an organization, including names, addresses, and ownership or control information
- identity verification information for authorized representatives and, where required, other relevant individuals
- documents or information establishing signing authority, ownership, control, or organizational structure
- settlement bank-account information
- store, terminal, device, and payment configuration information
- compliance, risk-review, investigation, and account-administration records
We do not ordinarily require every director or beneficial owner to provide identification documents. Additional information may be requested where required by law, a payment partner, risk assessment, ownership complexity, inconsistency, or enhanced due diligence.
Partner information
For referral, sales, technology, or other business partners, we may collect:
- individual or business identity and registration information
- contact details
- identity or business-verification documents where required
- contract, application, and relationship-management information
- merchant referral and application information
- bank-account information required to make payments to the partner
- applicable tax and settlement information
- platform-user and activity information
Platform-user information
For users of the Merchant Center or Partner Center, we may collect:
- name and business contact information
- organization, role, and permission information
- account identifiers
- authentication and security information
- login, access, audit, and activity records
- support communications
- information required to administer or secure the account
Users are responsible for protecting their credentials and should not share passwords or authentication codes with WegoPay personnel or other persons.
Transaction and settlement information
WegoPay may process transaction and operational information such as:
- merchant order number
- WegoPay or payment-provider transaction reference
- payment channel
- amount and currency
- transaction date and time
- transaction and refund status
- store, device, or acceptance channel
- refund, settlement, reconciliation, and reporting records
- fraud, security, compliance, and transaction-monitoring information
WegoPay generally does not receive or retain a payer’s payment-account login credentials, payment password, or complete payment-account credentials. The payer authorizes payment through the applicable payment provider.
Depending on the payment provider and transaction flow, WegoPay may receive limited transaction references, tokens, or other information required to process, reconcile, refund, secure, or investigate a transaction. Such information does not necessarily identify the payer to WegoPay.
Information from other sources
Where permitted by law, we may obtain information from:
- merchants, partners, and their authorized representatives
- payment networks and payment providers
- banks and financial institutions
- identity, business-verification, fraud-prevention, sanctions-screening, or compliance service providers
- public corporate registries and government records
- professional advisers
- other lawful sources relevant to providing or protecting our services
How We Use Information
We may use personal information to:
- respond to inquiries and communicate with prospective or existing merchants and partners
- assess, onboard, activate, and administer merchants and partners
- verify identity, business information, signing authority, ownership, control, and eligibility
- provide and support payment acceptance and related services
- process, route, reconcile, refund, and settle transactions
- operate and secure the Merchant Center and Partner Center
- manage accounts, stores, users, roles, and permissions
- provide reports, support, and service communications
- prevent, detect, and investigate fraud, misuse, security incidents, prohibited activity, and suspicious transactions
- conduct merchant verification, AML/CTF controls, sanctions screening, transaction monitoring, and risk reviews
- comply with legal, regulatory, tax, accounting, audit, contractual, payment-network, and reporting requirements
- establish, exercise, or defend legal rights
- improve the security, reliability, and operation of our services
- create aggregated or de-identified information where permitted by law
We limit collection, use, and disclosure to purposes that a reasonable person would consider appropriate in the circumstances.
Consent and Other Permitted Processing
We obtain consent where required by applicable law. The form of consent may depend on the sensitivity of the information and the circumstances in which it is collected.
In some circumstances, Canadian law permits or requires the collection, use, or disclosure of personal information without consent, including for certain legal, regulatory, fraud-prevention, investigation, security, or reporting purposes.
An individual may withdraw consent where processing is based on consent, subject to reasonable notice and legal, regulatory, contractual, security, and operational restrictions. Withdrawing consent may prevent WegoPay from providing or continuing certain services.
When We Share Information
We do not sell personal information.
We may disclose personal information, where permitted or required, to:
- WeChat Pay, Alipay, and other activated payment networks, providers, processors, or acquiring partners
- banks, settlement institutions, and financial institutions
- cloud hosting, data-storage, network, communications, cybersecurity, and technology service providers
- identity and business-verification providers
- fraud-prevention, sanctions-screening, compliance, and risk-management service providers
- auditors, insurers, legal counsel, accountants, and other professional advisers
- contractors and service providers that support our operations
- a purchaser, investor, financing source, or successor in connection with a proposed or completed corporate transaction, subject to appropriate safeguards
- FINTRAC, the Bank of Canada, law-enforcement agencies, courts, regulators, government authorities, or other persons where permitted or required by law
- other parties with consent or at the direction of the relevant individual or organization
Service providers are authorized to use information only for the services they provide or as otherwise permitted by law.
WegoPay may be prohibited from notifying an individual about certain reports, disclosures, monitoring activities, investigations, or protective measures.
Processing Outside Canada or Outside a Province
Personal information may be processed, accessed, or stored in Canada, in another Canadian province, or in another jurisdiction where WegoPay’s service providers, payment providers, financial institutions, or other authorized recipients operate.
Information processed outside an individual’s province or outside Canada may be subject to the laws of the jurisdiction where it is processed, including lawful access by courts, regulators, law-enforcement agencies, or government authorities.
WegoPay remains responsible for personal information transferred to service providers for processing and uses contractual, organizational, and security measures appropriate to the sensitivity of the information and the services involved.
Retention and Disposal
We retain personal information only for as long as reasonably necessary to:
- provide and administer our services
- maintain business, transaction, settlement, security, and support records
- satisfy legal, regulatory, AML/CTF, sanctions, tax, accounting, audit, and reporting requirements
- manage disputes, investigations, complaints, or legal claims
- enforce agreements and protect WegoPay, merchants, partners, and the payment ecosystem
Retention periods vary according to the type of information and the applicable requirement.
Certain records may be required to be retained for at least five years under applicable FINTRAC requirements. Applicable tax and accounting records may generally be retained for at least six years. Some information may be retained longer where required by law, legal process, an investigation, a dispute, or a payment-network or contractual requirement.
When information is no longer required, we take reasonable steps to securely delete, destroy, or anonymize it.
Information Security
WegoPay uses administrative, technical, and physical safeguards appropriate to the sensitivity of the information, which may include:
- role-based access controls
- authentication and account-security measures
- encryption in transit and at rest, where appropriate
- network and system-security controls
- logging, monitoring, and audit records
- vulnerability management and security testing
- transaction monitoring and fraud controls
- business-continuity and incident-response procedures
- service-provider and access management
- employee confidentiality and security requirements
No system or method of transmission is completely secure. WegoPay cannot guarantee absolute security, but we work to protect information and respond appropriately to security incidents.
Website Technologies
Our public website currently does not use advertising trackers, marketing cookies, Google Analytics, Meta Pixel, or online chat tools.
The website and its infrastructure may use strictly necessary technologies or process technical logs required to:
- deliver requested pages
- maintain security
- prevent abuse
- balance traffic
- diagnose errors
- maintain availability and performance
If WegoPay later introduces analytics, online chat, advertising technologies, or non-essential cookies, we will update this Policy and provide any notices, choices, or consent mechanisms required by applicable law.
Access, Correction, and Privacy Requests
Subject to applicable law and permitted exceptions, an individual may request:
- confirmation of whether WegoPay holds personal information about them
- access to personal information held by WegoPay
- correction of inaccurate or incomplete information
- information about how their personal information has been used or disclosed
- withdrawal of consent where processing is based on consent
- review of a privacy concern or complaint
WegoPay may need to verify the requester’s identity before responding.
Access, correction, deletion, or consent-withdrawal requests may be limited where information must be retained or protected for legal, regulatory, contractual, security, investigation, fraud-prevention, reporting, or third-party privacy reasons.
We will respond in accordance with applicable law.
Privacy of Minors
WegoPay’s services are designed for businesses and authorized business users and are not directed to children or minors.
We do not knowingly seek to collect personal information directly from minors through our public website. If we learn that personal information was collected from a minor in circumstances where it should not have been collected, we will take reasonable steps to address the situation.
Privacy and Security Incidents
WegoPay maintains procedures for assessing and responding to privacy and security incidents.
Where required by applicable law, we will notify affected individuals and the appropriate privacy commissioner or other authority of a breach of security safeguards that creates a real risk of significant harm. We will also retain breach records as required by law.
Changes to this Policy
We may update this Privacy Policy to reflect changes in our services, technology, legal requirements, or privacy practices.
The updated Policy will be posted on our website with a revised effective date. Where required by law, we will provide additional notice of material changes.
Contact the Privacy Officer
Questions, complaints, access or correction requests, and other privacy inquiries may be directed to:
- Privacy Officer
- NewHorizon Tech Inc., operating as WegoPay
- privacy@wegopayglobal.com