Last updated January 2022

Privacy Policy

We are Snap Accounts Payable Corporation (“SnapAP”, or “we”, “our”, “us”), and we are committed to transparency with respect to our practices in handling personal information. To that end, this Privacy Policy describes how we collect, use and disclose information of our customers (“Customers”) that use our SnapAP Software-as-a-Service Accounts Payable platform (the “Platform”), and the information we collect, use and disclose on behalf of our Customers – for example, relating to our customer’s vendors and suppliers, including those that access our Platform (“Vendors”). As the Platform is accessible to Customers and Vendors in various countries, this Privacy Policy is intended to satisfy the requirements of rules established by applicable law, including the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Canadian Anti-Spam Legislation (“CASL”), as well as the European General Data Protection Regulation (“GDPR”), and relevant US laws, including the California Consumer Privacy Act

When used in this Privacy Policy “personal information” means any information about an identifiable individual. This may include, for example, an individual’s name, contact information, email address, IP address, billing records, and financial account information. Personal information that is aggregated or anonymized and cannot be associated with an identifiable individual is not considered to be personal information.

 1. Application and Scope

This Privacy Policy applies to the personal information we collect, use and disclose through the SnapAP website and Platform.

1.1 This Privacy Policy governs personal information collected through SnapAP’s website, https://SnapAP.ca, (the “Website”) and through use of the Platform, whether by our Customers who subscribe to our services and use the Platform, their Vendors who use the Platform, or any visitors to our website that agree to leave such information. It also explains how we use cookies and similar technologies.

1.2 By using the Platform, or interacting with us in any manner, you are protected by the rights and safeguards contained in this Privacy Policy and you explicitly agree to its terms.

2. Collection of Personal Information

We collect and use personal information shared directly with us by Customers, Vendors and website visitors. We also automatically collect technical information through our website and Platform, using cookies and other similar technologies. You can block these cookies but in such a case we may not be able to provide you with all our website/Platform functionalities. 

2.1 SnapAP collects the following personal information:

  • Customer Information. When an organization is a SnapAP Customer and subscribes to the SnapAP Platform, we collect certain corporate information (such as Customer business name, address, bank account and tax information), as well as personal information about Customer employees (name, email, Platform login information, account name). This information can be inputted manually, or via Customer ERP synchronization with the Platform. 
  • Information about Vendors. Our Customers provide certain information relating to their Vendors (corporate name, contact information, bank account information, transaction history, employee contact information) to facilitate Customer’s use of the Platform, and also to enable Vendors to use the Platform. For example, a Customer may add or modify information about a given Vendor. Vendors may also provide information to SnapAP directly. We will only use the information about Vendors in accordance with this Privacy Policy. 
  • Technical information. When you visit our website or use our Platform, we may collect, using electronic means such as cookies, technical information. This information may include information about your visit to our website, including the IP address of your computer and which browser you used to view our website, the time you accessed or used our website, your operating system, resolution of the screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, the information you entered, advertisements you have seen, etc. This data is used to measure and improve the effectiveness of our website or enhance the experience for our customers. For instance, it may be used to ensure that the services advertised on our website are available in your area and that we are showing you customized content and promotions on our website which are of interest to you. We treat this information as personal information when it is associated with your account or contact information. For instance, we may collect and use the following type of information when you visit and/or interact with us on our websites:
  • Website Analytics. We may use Google Analytics, or other analytics services, which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. 
  • Your Choice with Cookies. You can block the use of cookies by activating the settings in your browser. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to withhold consent, or subsequently block cookies, you may not be able to access all or part of the content of our website. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.
  • Privacy Policies of Third Parties. This Privacy Policy only addresses the use and disclosure of information by SnapAP. Other websites that may be accessible through our website or Platform have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

3. Use of Personal Information

We use personal information to provide products and services to our Customers and their Vendors, and for our internal purposes.

3.1 We collect personal for the following purposes:

  • to establish, develop and preserve our business relationship respectively with our Customers, their Vendors, and other individuals with whom we deal with;
  • to create, establish and administer Customers’ accounts and to respond to Customer or Vendor inquiries;
  • to provide our services via the Platform, and ensure that all related transactions are supported and implemented;
  • to establish or verify the credentials/identity of Customers and/or Vendors;
  • to authenticate the identity and preserve the privacy of Customers and their Vendors contacting SnapAP by telephone, electronic means or otherwise;
  • for internal training and quality assurance purposes;
  • as necessary, to establish or verify the credentials of persons that use, or intend to use, one or more of the services offered by SnapAP;
  • to manage its businesses and ensure the efficiency, reliability and security of its systems;
  • to meet legal and regulatory requirements and allow SnapAP to meet contractual requirements relating to the services provided to Customers and Vendors;
  • to ensure our records are accurate and to protect Customers, Vendors and SnapAP from error and fraud;
  • to understand and assess the interests, wants and changing needs of Customers with a view to improving our products and services and developing new ones; and
  • to provide personalized services as well as product recommendations to Customers and Vendors.

We also use your personal information (subject to an individual’s right to withdraw consent):

  • to communicate with Customers and Vendors for the purposes of providing advertising and marketing messages pertaining to additional products or services that may be of interest;
  • to personalize our advertisements to ensure that such advertisements are of relevance for our Customers and their Vendors;
  • to conduct surveys on the quality of our products, services or customer service.

3.2 When possible, rather than using personal information, we will anonymize and/or aggregate personal information so that it no longer identifies an individual, and use it for the purposes mentioned above or any legal purpose.

3.3 Unless required or authorized by law, SnapAP will not collect or use personal information for any other or new purpose without obtaining further consent. 

3.4 We do not knowingly collect information from children, and we do not target our website, our Platform or any SnapAP services to collect information about children.

4. Consent

Through use of our Platform or by visiting our website, you agree to be bound by this Privacy Policy.

4.1 SnapAP obtains consent of individuals for the collection, use, processing or disclosure of personal information at or before the time of collection: orally or through written documents, including agreements, forms, as well as printed or electronic communications. The form of consent sought by SnapAP will vary according to the sensitivity of the personal information, the reasonable expectations of the individuals and any requirements or standards established by law.

4.2 In general, by subscribing to the SnapAP Platform and/or submitting information to us in connection with using SnapAP products and services (whether as a Customer or a Vendor), you are providing your consent to the collection, use, processing and disclosure of personal information as set out in this Privacy Policy, and, as applicable, in any agreement you may enter into with us. Moreover, by visiting, interacting with and/or using our website, you agree to benefit from, and be bound by, the terms and conditions of this Privacy Policy.

5. Right to Withdraw Consent

Any individual can withdraw their consent to our use of their personal information at any time. For example, at any time, an individual can opt-out from receiving any of our marketing emails. However, withdrawal of consent to use or disclose personal information may mean that we are not able to provide you with all of our services. We may nonetheless retain your information if we have a legal basis to do so.

5.1 If you withdraw your consent to the use, processing or sharing of your personal information for the purposes set out in this Privacy Policy, we may not be able to provide you with all (or any) of the services offered via our Platform. In certain cases, we may continue to use the personal information after you have withdrawn consent if we have a legal basis to do so, or if your withdrawal of consent was limited to certain processing activities or to certain elements. For example, we may keep information if we need to do so to comply with a legal obligation, to resolve disputes and to enforce our agreements.

5.2 Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice; however, without such consent, SnapAP may limit the services it is able to provide users and customers via our Platform. You may also withdraw your consent as follows:

  • New products and services, commercial electronic messages, marketing emails. You can always limit the communications that SnapAP sends to you. To opt-out of commercial emails, simply click the link labeled “Unsubscribe” at the bottom of any commercial electronic messages we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account, or other transactional communications.
  • Telephone marketing and quality control communications. If you shared with us your phone number, we may contact you by telephone. You may decide that you prefer SnapAP not to use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse to contact you by telephone for marketing purposes or by email for quality control purposes. If this is the case, you may advise us by contacting us at [email protected]

6. Sharing of Personal Information

We may share personal information with service providers who are assisting us with our operations, or that we partner with in order to provide our services (such as financial institutions). We only share with such third parties the limited information they require, and they are prohibited from using personal information for any other purpose than servicing SnapAP. We may also share personal information when required to do so under applicable law. 

6.1 Personal information may be made available by SnapAP to third parties to fulfill the purposes for which it has been collected or as set forth in this Privacy Policy. SnapAP will NOT share, sell, rent or trade your personal information to any third party. However, we may share personal information when authorized by law or as follows:

  • To third-party service providers and partners. We may hire service providers, which may be affiliates or third parties, to perform services on our behalf. This may include, without limitation, a person or an organization retained by SnapAP to perform work on its behalf. 

We may also share information with third parties at the request of our Customers (for example, sharing information with a Customer or Vendor’s financial institution). We provide such third parties with only that information which is necessary in order for them to provide the services required, or that we have been instructed to provide by our Customer. All such third parties are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others. SnapAP will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by SnapAP itself.

  • As permitted or required by law. From time to time, SnapAP may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.

6.2 Only those employees of SnapAP or trusted third party contractors, who need access for business reasons, or whose duties reasonably so require, will be granted access to personal information about Customers and their Vendors and will be bound by the terms of this Privacy Policy and any data security policies of SnapAP.

7. Storage of Personal Information 

SnapAP processes and stores data in the cloud.

  • The storage locations are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. Storage locations may also be chosen in accordance with regulations and required compliance. We take steps to ensure that the information we collect under this Privacy Policy is processed according to the provisions of this statement and the requirements of applicable law where the data is located.
  • SnapAP will strive to protect personal information disclosed or transferred to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by SnapAP itself.

8. Security of Personal Information

8.1 We use reasonable security measures to protect personal information against unauthorized access, use, loss and disclosure. SnapAP has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information. Information stored in the Cloud is subject to contractual protections between SnapAP and the service provider.  When we transmit any data (such as messages, attachments, etc.) over the Internet, we protect it through the use of encryption.

9. Retention

We only retain personal information for the time period necessary to fulfill the purpose for which it was collected and in accordance with applicable law.

  • SnapAP retains personal information for as long as is necessary to provide the services and fulfill the transactions requested by Customers and/or Vendors, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required by law. Personal information that is no longer required to fulfil the identified purpose will be returned to our customer or destroyed.
  • Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. The criteria we use to determine the retention periods include:

10. Access and Correction

Individuals have the right to access their personal information held by SnapAP and to have it corrected.

10.1 SnapAP respects individuals’ right to access and correct their personal information. If you have an account with us, you can log in at any time to access and update the personal information you have provided to us. If you need assistance with the access or correction of personal information, please contact us using the contact information detailed below. Note that we may request additional personal information from you to verify your identity before any corrections are made or access is provided. This additional information will only be used to verify your identity and will not be used for any other purpose.

11. How to Contact Us

11.1 If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that SnapAP collects, uses or discloses, please contact us by email at: [email protected] or by mail at: Compliance Officer, Snap Accounts Payable Corporation, 735 Main Street, Moncton, NB, E1C 1E5 Canada.