Privacy Policy
Effective: May 5, 2026
1. Purpose
POSconnect Inc., operating as SportsPay (“SportsPay,” “we,” “our”), respects the privacy of individuals whose personal information we collect, use, and disclose in the course of our business. This Privacy Policy describes the personal information we handle, how and why we handle it, and the rights individuals have in relation to that information.
This Policy is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. Where provincial legislation imposes additional requirements, SportsPay complies with those requirements.
This Policy is published on the SportsPay website.
2. Scope
This Policy applies to all personal information collected, used, and disclosed by SportsPay in the course of providing payment facilitator and acquiring services to merchants (including sports organizations, associations, and small businesses) and the cardholders whose payments flow through those merchants.
This Policy applies to all directors, officers, employees, contractors, and agents of SportsPay, and to all third-party service providers who handle personal information on our behalf.
3. Privacy Officer
SportsPay has designated a Privacy Officer who is accountable for compliance with this Policy and with applicable privacy legislation.
Individuals with questions about this Policy, requests in respect of their personal information, or privacy-related complaints may contact the Privacy Officer at:
Privacy Officer, SportsPay, 648 Ossington Avenue, Toronto, Ontario, M6G 3T7
Email: compliance@sportspay.com
Telephone: 1-888-380-5413
4. Personal Information We Handle
“Personal information” means information about an identifiable individual. The categories of personal information SportsPay handles vary by the individual’s relationship with us. The following table summarizes the principal categories:
Category | Examples |
Identification & Contact | Name, business address, personal address (where applicable), email address, telephone number, date of birth (where required for KYC). |
Government Identifiers | Government-issued ID numbers used for KYC and sanctions screening, as required under the PCMLTFA and FINTRAC guidance. |
Financial & Transactional | Bank account information for settlement and payouts, transaction history, payment card data (handled in accordance with PCI DSS), reconciliation records. |
Beneficial Ownership | Information about directors, officers, and beneficial owners of merchant and end-user client entities, as required for KYC and due diligence. |
Compliance & Risk | Sanctions screening results, due diligence findings, complaint records, transaction monitoring outputs. |
Website Use | IP address, browser type, device information, cookies, and similar technical data collected when individuals interact with the SportsPay website. |
Communications | Records of correspondence, complaint submissions, and other communications between SportsPay and the individual or entity. |
5. Why We Handle Personal Information
SportsPay collects, uses, and discloses personal information for the purposes identified at or before the time of collection, including:
- To provide and administer payment facilitation and acquiring services to merchants;
- To onboard merchants, including underwriting, due diligence, and Know-Your-Customer (KYC) procedures;
- To comply with applicable laws and regulations, including the PCMLTFA (FINTRAC), the RPAA (Bank of Canada), card network operating rules, and applicable sanctions regimes;
- To screen individuals and entities against sanctions and other watchlists;
- To monitor transactions for fraud, money laundering, terrorist financing, and other compliance risks;
- To process complaints and disputes;
- To communicate with merchants and other contacts about their accounts and our services;
- To improve, secure, and maintain the SportsPay website, systems, and services;
- To protect SportsPay’s rights, property, and operations, and the rights and safety of others;
- For other purposes disclosed at or before the time of collection.
6. Consent
SportsPay collects, uses, and discloses personal information with the knowledge and consent of the individual, except where otherwise permitted or required by law. The form of consent sought may vary depending on the sensitivity of the personal information and the reasonable expectations of the individual.
Express consent is generally obtained for sensitive personal information. Implied consent may be appropriate where the purpose is obvious and the individual voluntarily provides the information for that purpose.
An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect SportsPay’s ability to continue providing services. Individuals wishing to withdraw consent should contact the Privacy Officer.
7. Disclosure to Third Parties
SportsPay discloses personal information to third parties only as necessary for the purposes described in this Policy, including to:
- Service providers who process personal information on SportsPay’s behalf (e.g., banking partners, technology vendors, screening providers), under contractual obligations of confidentiality and security;
- Partner financial institutions that hold safeguarded end-user funds;
- Acquiring banks and card networks for the processing of card transactions;
- Regulators and government authorities, including FINTRAC, the Bank of Canada, the FCAC, the Office of the Privacy Commissioner of Canada, and law enforcement, as required by law;
- Professional advisors (e.g., legal counsel, auditors) under obligations of confidentiality;
- Successor organizations in the event of a corporate transaction, subject to appropriate confidentiality and consent requirements;
- Other third parties with the individual’s consent or as otherwise permitted by law.
8. Cross-Border Transfers
Some of SportsPay’s service providers and partners are located outside of Canada, including in the United States. As a result, personal information may be transferred to, stored in, or accessed from jurisdictions outside Canada, including in connection with payment processing services.
When personal information is transferred outside Canada, it is subject to the laws of the foreign jurisdiction, including lawful access by foreign courts, governments, and regulators. SportsPay remains accountable for personal information transferred to a service provider for processing, and uses contractual and other means to ensure a comparable level of protection while the information is being processed by the service provider.
9. Safeguards
SportsPay protects personal information by physical, organizational, and technological safeguards appropriate to the sensitivity of the information. These safeguards include:
- Restricted access to personal information on a need-to-know basis;
- Encryption of personal information at rest and in transit, where appropriate;
- Logging and monitoring of access to systems handling personal information;
- Confidentiality obligations imposed on personnel and service providers;
- Compliance with the Payment Card Industry Data Security Standard (PCI DSS) for cardholder data;
- Regular review and update of safeguards in response to evolving threats and technologies.
10. Retention
SportsPay retains personal information only for as long as necessary to fulfill the purposes for which it was collected, to meet legal and regulatory retention requirements, and to address any disputes or claims that may arise.
Records subject to PCMLTFA recordkeeping requirements are retained for a minimum of five years from the date the record is created or the relationship ends, whichever is later. Other categories of personal information are retained in accordance with SportsPay’s records management framework.
When personal information is no longer required, it is securely destroyed, erased, or anonymized in accordance with SportsPay’s data disposal procedures.
11. Accuracy and Access
SportsPay makes reasonable efforts to ensure that personal information is accurate, complete, and up to date for the purposes for which it is used.
Subject to applicable legal limitations, individuals have the right to:
- Request access to the personal information SportsPay holds about them;
- Request correction of inaccurate or incomplete personal information;
- Be informed of how their personal information has been used and to whom it has been disclosed.
Requests should be submitted in writing to the Privacy Officer at the contact information in Section 3. SportsPay will respond to access requests within thirty (30) days of receipt, or as otherwise permitted under PIPEDA. SportsPay may decline access where required or permitted by law (for example, where access would reveal personal information about another individual or where the information is subject to solicitor-client privilege) and will explain the reason for any refusal.
12. Privacy Breach Response
SportsPay maintains procedures for the identification, containment, assessment, reporting, and remediation of privacy breaches. Where a privacy breach creates a real risk of significant harm to an individual, SportsPay will:
- Report the breach to the Office of the Privacy Commissioner of Canada as soon as feasible;
- Notify affected individuals as soon as feasible;
- Notify other organizations or government institutions that may be in a position to reduce or mitigate harm;
- Maintain a record of all privacy breaches as required under PIPEDA.
13. Cookies and Website Use
The SportsPay website uses cookies and similar technologies to operate the website, remember user preferences, and collect technical information about website use. Most browsers allow users to refuse cookies; doing so may affect website functionality.
Server logs record technical information including IP address, browser type, pages visited, and timestamps. This information is used for security, troubleshooting, and analytics.
14. Children
SportsPay’s services are not directed to children. SportsPay does not knowingly collect personal information from children. Where SportsPay becomes aware that personal information of a child has been collected without appropriate consent, SportsPay will take steps to delete the information.
15. Complaints and Recourse
Individuals who believe SportsPay has not handled their personal information in accordance with this Policy or with applicable privacy legislation may submit a complaint to the Privacy Officer at the contact information in Section 3. The Privacy Officer will investigate the complaint and respond within a reasonable time.
If the individual is not satisfied with SportsPay’s response, the individual may file a complaint with the Office of the Privacy Commissioner of Canada:
Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec, K1A 1H3
Telephone: 1-800-282-1376
Website: priv.gc.ca
16. Changes to this Policy
SportsPay reviews this Policy at least annually and updates it from time to time to reflect changes in our business, applicable laws, and best practices. The most recent effective date is shown at the top of this Policy. Material changes will be communicated through the SportsPay website and, where appropriate, directly to affected individuals.