About SnapB2B

Snap Accounts Payable Company (“SnapB2B”, “we”, “our”, or “us”) is committed to protecting the privacy and security of personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in connection with the SnapB2B platform and related services (the “Platform”).

SnapB2B provides software that helps businesses manage accounts payable processes, vendor onboarding, and payment workflows. In many cases, SnapB2B acts as a technology service provider to business customers and financial institution partners, processing information on their behalf to enable payment and financial workflow services.

This Privacy Policy is intended to comply with applicable privacy laws, including the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), the Canadian Anti-Spam Legislation (CASL), the European General Data Protection Regulation (GDPR) where applicable, and relevant United States privacy laws, including the California Consumer Privacy Act (CCPA/CPRA) and other applicable state privacy laws.

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

1. Scope of this Policy

This Privacy Policy applies to personal information collected through the SnapB2B website, Platform, communications with SnapB2B, and services provided to customers and vendors using the Platform.

In some cases, SnapB2B processes personal information on behalf of its business customers or financial institution partners, who may act as the primary data controller or decision-maker regarding the use of such information.

2. Personal Information We Collect

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 similar technologies. You can block these cookies, but in such a case we may not be able to provide all website or Platform functionality.

2.1 SnapB2B may collect the following categories of personal information:

• Customer Information. When an organization subscribes to the SnapB2B Platform, we may collect corporate information such as business name, address, and related account information, as well as personal information about customer employees, including names, email addresses, login credentials, job titles, business contact details, communications with SnapB2B, and invoice or transaction-related data. This information may be input manually or synchronized through a customer ERP or related system.
• Vendor or Supplier Information. Our customers may provide information relating to their vendors or suppliers, including corporate name, contact information, payment instructions, remittance details, invoice information, transaction history, and employee contact information, to facilitate use of the Platform and payment workflows. Vendors may also provide information directly to SnapB2B. We use vendor information in accordance with this Privacy Policy and, where applicable, on behalf of our customers.
• Financial Information. To enable accounts payable processing and payment workflows, SnapB2B may process financial information including bank account information, payment routing details, invoice and transaction information, payment instructions, and related financial workflow data. SnapB2B generally processes this information on behalf of its business customers and financial institution partners in order to facilitate payment processing and reconciliation services.
• Technical Information. When you visit our website or use our Platform, we may collect technical information using cookies and similar technologies. This may include your IP address, browser type, operating system, device information, screen resolution, location, language settings, referring site, time of access, page views, and other interaction data. We use this information to measure and improve the effectiveness, security, and performance of our website and Platform, and to enhance the user experience.
• Website Analytics. We may use Google Analytics or similar analytics services to understand how users interact with our website, including page views, traffic sources, and time spent on pages. This information is generally aggregated or de-personalized and used for website performance, analytics, and improvement purposes.
• Your Choice with Cookies. You can block the use of cookies by activating the relevant settings in your browser. The “Help” feature on most browsers will explain how to prevent the browser from accepting new cookies, how to receive notice of new cookies, or how to disable cookies altogether. If you choose to block cookies, you may not be able to access all or part of the content or functionality of our website or Platform.
• Privacy Policies of Third Parties. This Privacy Policy addresses only the use and disclosure of information by SnapB2B. Other websites or services that may be accessible through our website or Platform may have their own privacy policies and practices. We encourage you to review the privacy statements of all third parties before providing them with information.

3. How We Use Personal Information

We use personal information to provide products and services to our customers and their vendors, to support payment and financial workflow services, and for internal operational purposes.

3.1 We may collect, use, and process personal information for the following purposes:

• to establish, develop, and preserve our business relationships with customers, vendors, and other individuals with whom we deal;
• to create, establish, and administer customer accounts and respond to customer or vendor inquiries;
• to provide our services through the Platform and support related payment and workflow transactions;
• to establish or verify the identity and credentials of customers, vendors, and other users;
• to authenticate identity and preserve privacy when individuals contact SnapB2B by telephone, electronic means, or otherwise;
• for internal training, support, and quality assurance purposes;
• to manage our business and ensure the efficiency, reliability, and security of our systems;
• to detect, prevent, or investigate fraud, security incidents, errors, or unauthorized activities;
• to comply with legal, regulatory, contractual, and financial compliance obligations;
• to protect customers, vendors, and SnapB2B from error, misuse, and fraud;
• to understand and assess customer needs with a view to improving our products and services and developing new ones; and
• to provide personalized services and relevant product information to customers and vendors where permitted by law.

We may also use personal information, subject to applicable law and an individual’s right to withdraw consent where required:

• to communicate with customers and vendors about products or services that may be of interest;
• to personalize content or promotions on our website or Platform; and
• to conduct surveys regarding the quality of our products, services, or customer support.

Where possible, rather than using personal information, we may anonymize and/or aggregate information so that it no longer identifies an individual and use it for the purposes described above or any other lawful purpose.

Unless required or authorized by law, SnapB2B will not collect or use personal information for a materially different purpose without taking appropriate steps under applicable law.

We do not knowingly collect personal information from children, and we do not target our website, Platform, or services to children.

4. Consent

Where required by law, SnapB2B will obtain consent for the collection, use, processing, or disclosure of personal information.

In many cases, SnapB2B processes personal information on behalf of business customers or financial institution partners. In those cases, those entities may be responsible for obtaining any necessary consent from their employees, vendors, or users.

The form of consent sought by SnapB2B may vary depending on the sensitivity of the personal information, the reasonable expectations of the individuals involved, and any requirements established by applicable law.

5. Right to Withdraw Consent

Where consent is required, individuals may withdraw their consent to our use of their personal information at any time, subject to legal or contractual restrictions and reasonable notice. For example, individuals may opt out of receiving marketing communications from SnapB2B.

Withdrawal of consent may mean that we are not able to provide all or part of the services offered through our Platform. In certain cases, we may continue to use or retain personal information after consent has been withdrawn where we have a legal basis to do so, including to comply with legal obligations, resolve disputes, enforce agreements, or support fraud prevention and legitimate business purposes.

You may withdraw consent as follows:

• Marketing Emails and Commercial Messages. You can opt out of commercial email communications by clicking the “Unsubscribe” link included in those messages. Even if you opt out of promotional communications, we may still need to contact you regarding your account or other transactional matters.
• Telephone Marketing or Quality Control Communications. If you have provided your phone number, you may request that SnapB2B not use your personal information for telephone marketing or similar outreach by contacting us at privacy@snapb2b.com.

6. Sharing and Disclosure of Personal Information

SnapB2B may share personal information with trusted service providers, financial institution partners, payment or financial infrastructure providers, and others where necessary to operate our services, support payment workflows, or comply with legal requirements. We provide such parties only the information needed for the relevant purpose and require them to protect personal information appropriately.

SnapB2B does not sell personal information.

6.1 Personal information may be disclosed in the following circumstances:

• To Service Providers and Partners. We may engage third-party providers, including affiliates or independent contractors, to perform services on our behalf. These may include providers of cloud hosting, data storage, security monitoring, analytics, customer support, or related operational services. These providers are contractually required to use personal information only for authorized purposes and to apply appropriate confidentiality and security safeguards.
• To Financial Institution Partners and Financial Infrastructure Providers. Where the Platform integrates with financial services, information may be shared with banking partners, financial institution partners, payment networks, and financial infrastructure providers to enable payment processing, settlement, reconciliation, compliance, or related financial workflow functions.
• At the Direction of Our Customers. We may share information with third parties at the request or instruction of our customers, including, for example, sharing information with a customer’s financial institution or service provider in connection with services delivered through the Platform.
• As Permitted or Required by Law. From time to time, SnapB2B may disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation, regulatory request, or other legally valid process. We may also disclose personal information where necessary to protect rights, property, safety, or security, or to prevent fraud or unlawful activity, as permitted by law.
• Corporate Transactions. Personal information may be transferred in connection with a merger, acquisition, financing, reorganization, asset sale, or other corporate transaction, subject to appropriate confidentiality protections.

Only those employees of SnapB2B and trusted third-party contractors who need access for legitimate business reasons will be granted access to personal information, and they will be bound by applicable confidentiality, privacy, and security obligations.

7. Storage and Cross-Border Processing of Personal Information

SnapB2B processes and stores data in the cloud and may process or store personal information in Canada, the United States, or other jurisdictions where SnapB2B or its service providers operate.

• Storage locations may be selected in order to operate efficiently, improve performance, provide redundancy, support resilience, and comply with applicable legal, regulatory, or contractual requirements.
• We take steps to ensure that personal information collected under this Privacy Policy is processed in accordance with applicable law and protected through appropriate contractual, technical, and organizational measures.
• Where information is disclosed or transferred to third parties, SnapB2B seeks to protect that information through contractual obligations requiring confidentiality and security protections that are at least commercially reasonable for the services provided.

As a result of cross-border processing, personal information may be subject to the laws of the jurisdictions in which it is stored or processed, which may differ from those of the individual’s home jurisdiction.

8. Security of Personal Information

SnapB2B maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, loss, disclosure, alteration, or destruction. These safeguards include secure infrastructure, encryption of data in transit where appropriate, access controls, authentication mechanisms, monitoring systems, and internal policies governing the handling of personal information.

Information stored in cloud environments is subject to contractual protections between SnapB2B and the applicable service provider. While no system can guarantee absolute security, SnapB2B takes reasonable measures to protect personal information.

9. Retention

SnapB2B retains personal information only for as long as necessary to fulfill the purpose for which it was collected, provide services through the Platform, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and support legitimate business operations.

• Certain financial, transactional, compliance, or account-related records may be retained for longer periods where required by law, regulation, contractual obligation, or legitimate operational need.
• Personal information that is no longer required for the identified purpose may be deleted, anonymized, or, where appropriate, returned to the customer, subject to applicable law and technical feasibility.
• Actual retention periods may vary depending on the type of information and the context in which it is processed.

10. Access, Correction, and U.S. Privacy Rights

Individuals may have the right to access their personal information held by SnapB2B and to request correction of inaccurate personal information, subject to applicable law.

Residents of certain U.S. states, including California, may also have additional rights regarding their personal information, such as the right to request access, correction, deletion, or information about how personal data is used or shared, subject to applicable exceptions.

If you have an account with us, you may be able to access and update certain personal information through your account. If you need assistance with access or correction requests, please contact us using the contact information below. We may request additional information to verify your identity before processing a request. This verification information will only be used for that purpose.

SnapB2B does not sell personal information.

11. Security Incidents

If SnapB2B becomes aware of a security incident involving personal information, we will take appropriate steps to investigate, contain, and mitigate the issue and to notify affected parties or authorities as required by applicable law.

12. Changes to this Privacy Policy

SnapB2B may update this Privacy Policy from time to time to reflect changes in our practices, services, legal obligations, or applicable laws. The updated version will be posted on our website with the revised effective date.

13. How to Contact Us

If you have questions, concerns, or complaints regarding this Privacy Policy or the personal information that SnapB2B collects, uses, or discloses, please contact us by email at privacy@snapb2b.com or by mail at: Compliance Officer, Snap Accounts Payable Company, 770 St. George Blvd., Moncton, NB E1E 2C6, Canada.