Updated: December 15, 2017
At EmployeeAssist Inc., doing on business as PayTickr (“PayTickr”), we are committed to providing our
customers and users with exceptional service. As providing this service involves the collection, use and
disclosure of some personal information about our customers and users, protecting their personal information is
one of our highest priorities.
Our use of the personal information we collect from our customers and users is subject to the Alberta Personal
Information Protection Act (“PIPA”) and/or the federal Canadian Personal Information Protection and Electronic
Documents Act (“PIPEDA”). PIPA and PIPEDA (as applicable) set out the ground rules for how Alberta
businesses and not-for- profit organizations may collect, use and disclose personal information.
In accordance with PIPA and PIPEDA (as applicable), we will inform our customers and users of why and how
we collect, use and disclose their personal information, obtain their consent where required, and only handle
their personal information in a manner that a reasonable person would consider appropriate in the
we will follow in protecting the personal information of our customers and users. Our privacy commitment
includes ensuring the accuracy, confidentiality, and security of that personal information and allowing our
customers and users to request access to, and correction of, their personal information.
Scope of this Policy
that you choose to link to your account or otherwise provide access to any account or personal profile you
establish with PayTickr, including TelPay Incorporated. In those instances, the privacy policies of such service
providers and other parties may apply.
Personal Information – means information about an identifiable individual, which may include such information
as name, age, gender, home address, phone number, e-mail address, Social Insurance Number, username,
password and credit card information. Personal information does not include business contact information
Business contact information – means information that would enable an individual to be contacted at a place
of business and includes name, position name or title, business telephone number, business address, business
email or business fax number. Contact information is not covered by this policy or by PIPA or PIPEDA (as
Privacy Officer – means the individual designated responsibility for ensuring that PayTickr complies with this
policy and with PIPA and PIPEDA (as applicable).
Policy 1 – Collecting Personal Information
- 1.1 Unless the purposes for collecting personal information are obvious and the customer or user voluntarily
provides his or her personal information for those purposes, we will communicate the purposes for
which personal information is being collected, either orally or in writing, before or at the time of
- 1.2 We will only collect personal information of customers and users that is necessary to fulfill the following
- To verify identity;
- To verify that the customer or user meets our minimum age requirements;
- To verify credit information;
- To identify customer and user preferences;
- To understand the needs of our customers and users with respect to our products and services and
enhance their experience using our products and services;
- To open and manage a user account and/or personal profile (where applicable);
- To deliver requested products and services;
- To deliver notices, updates, alerts and other information concerning our products and services that
may be of interest to our customers and users;
- To ensure a high standard of service to our customers and users;
- To collect and process payments;
- To meet regulatory requirements; and
- To enable related entities and third party service providers to deliver requested products, services
and/or information and to accomplish the purposes described in Policy 1.
- 1.3 We may also collect information related to your use of our services, where applicable, such as:
- Device-specific information (e.g. hardware model, operating system information, unique device
identifiers and mobile network information, including phone number) which we may associate with
your PayTickr account;
- Log information (e.g. details of how you use our service, internet protocol address, system and
device event information such as crashes, system activity, hardware settings, browser type, browser
language and the date and time of use of our service, and cookies that may uniquely identify your
browser or your PayTickr account)
- 1.4 About Cookies - We may collect and store information related to your use of our services by sending
one or more cookies or anonymous identifiers to your device.
Policy 2 – Consent
- 2.1 We will obtain the consent of our customers and users to collect, use or disclose personal information
(except where, as noted below, we are authorized to do so without consent).
- 2.2 Consent can be provided orally, in writing, electronically and/or through an authorized representative or
it can be implied where the purpose for collecting using or disclosing the personal information would be
considered obvious and the customer or user voluntarily provides personal information for that purpose.
When you establish a user account or purchase products or services from us, you consent to the
collection of your personal information for the purposes described in Policy 1.
- 2.3 Consent may also be implied where a customer or user is given notice and a reasonable opportunity to
opt-out of his or her personal information being used for direct marketing of our services or products and
the customer or user does not opt-out.
- 2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or
product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers
and users can withhold or withdraw their consent for PayTickr to use their personal information in
certain ways. A customer’s or user’s decision to withhold or withdraw their consent to certain uses of
personal information may restrict our ability to provide a particular service or product. If so, we will
explain the situation to assist the customer or user in making the decision.
- 2.5 We may collect, use or disclose personal information without the customer’s or user’s knowledge or
consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual's life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law; or
- For other purposes authorized under PIPA or PIPEDA (as applicable).
Policy 3 – Using and Disclosing Personal Information
- 3.1 We will only use or disclose customer or user personal information where necessary to fulfill the
purposes identified at the time of collection or for a purpose reasonably related to those purposes such
- To conduct customer and user surveys in order to enhance the provision of our services;
- To contact our customers and users directly about products and services that may be of interest to
- To enable related entities and third party service providers to deliver requested products, services
- 3.2 With respect to payroll services provided by PayTickr, we may disclose customer or user personal
information to the relevant employers and government agencies in conjunction with the delivery and use
of such payroll services by the relevant customers and users.
- 3.3 We will not use or disclose customer or user personal information for any additional purpose unless we
obtain consent to do so.
- 3.4 We will not sell, lease or rent customer or user lists or personal information to other parties.
Policy 4 – Retaining Personal Information
- 4.1 If we use customer or user personal information to make a decision that directly affects the customer or
user, we will retain that personal information for at least one year so that the customer or user has a
reasonable opportunity to request access to it.
- 4.2 Subject to policy 4.1, we will retain customer and user personal information only as long as necessary to
fulfill the identified purposes or a legal or business purpose. This may include retaining information as
directed or requested by a customer with respect to user personal information of such customer’s
Policy 5 – Ensuring Accuracy of Personal Information
- 5.1 We will make reasonable efforts to ensure that customer and user personal information is accurate and
complete where it may be used to make a decision about the customer or user or disclosed to another
- 5.2 Customers and users may request correction to their personal information in order to ensure its
accuracy and completeness. A request to correct personal information must be made in writing and
provide sufficient detail to identify the personal information and the correction being sought. A request to
correct personal information should be forwarded to the Privacy Officer identified below.
- 5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the
information as required and send the corrected information to any organization to which we disclosed
the personal information in the previous year. If the correction is not made, we will note the customer’s
or user’s correction request in the file.
Policy 6 – Securing Personal Information
- 6.1 We are committed to ensuring the security of customer and user personal information in order to protect
it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar
- 6.2 The following security measures will be followed to ensure that customer and user personal information
is appropriately protected:
- Physically securing offices where personal information is held by us;
- The use of usernames and passwords (where applicable);
- The use firewalls for stored personal information;
- Restricting employee access to personal information as appropriate (i.e., only those that need to
know will have access and such access will require a password); and
- Contractually requiring any service providers to provide comparable security measures.
- 6.3 We will use appropriate security measures when destroying customer’s and user’s personal information
such as shredding documents and permanently deleting electronically stored information.
- 6.4 We will continually review and update our security policies and controls as technology changes to
ensure ongoing personal information security.
Policy 7 – Providing Customers and Users Access to Personal Information
- 7.1 Customers and users have a right to access their personal information, subject to limited exceptions
outlined in the relevant sections of PIPA and PIPEDA (as applicable).
- 7.2 A request to access personal information must be made in writing and provide sufficient detail to identify
the personal information being sought. A request to access personal information should be forwarded
to the Privacy Officer identified below.
- 7.3 Upon request, we will also tell customers and users how we use their personal information and to whom
it has been disclosed, if applicable.
- 7.4 We will make the requested information available within 30 business days, or provide written notice of
an extension where additional time is required to fulfill the request.
- 7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we
will inform the customer or user of the cost and request further direction from the customer or user on
whether or not we should proceed with the request.
- 7.6 If a request is refused in full or in part, we will notify the customer or user in writing, providing the
reasons for refusal and the recourse available to the customer or user.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer
- 8.1 The Privacy Officer is responsible for ensuring PayTickr’s compliance with this policy and the Personal
Information Protection Act.
- 8.2 Customers and users should direct any complaints, concerns or questions regarding PayTickr’s
compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the
client, customer, member may also write to the Office of the Information and Privacy Commissioner for
Alberta or the Office of the Privacy Commissioner of Canada (as applicable).
Contact information for PayTickr’s Privacy Officer:
48 Bermondsey Rise NW
Calgary, AB T3K 1T9
- 8.3 We may designate another individual other than the Privacy Officer as the person to contact for any
Policy 9 – Changes