Privacy Policy
Welcome to Shakepay!
When we mention the “Platform”, we are referring to:
(1) our mobile application for iOS and Android (the “Application”);
(2) the website at https://shakepay.com (the “Website”); and
(3) all of our business activities, including our “Services” as described below.
We hope you enjoy your use of the Platform!
At Shakepay, we take your privacy and the security of your personal information very seriously. This Privacy Policy (the “Policy”) explains who we are, the personal information we collect from and about you, and how we use and protect it when you interact with the Platform. Please take a moment to read it carefully.
As a Shakepay customer, you can trust that we handle your personal information with care and in compliance with our legal obligations. This Policy lays out exactly how we do that.
Overview
Here is a quick overview of what personal information we collect, why we need it, and whom we might share it with.
Why?
What?
With whom we share?
Open and maintain your account on the Platform
Full name
Email
Address
Occupation
Phone number
Shaketag
Companies that provide the infrastructure for the Platform
Verify your identity for you to be able to use the Services on the Platform
Full name
Date of birth
Address
ID document (passport or driver license)
Video of your face and voice
May include employment history
Companies that perform identity verification for the Platform
Process e-transfers, direct deposit, wire funds in and out of the Platform
Full name on your bank account
Email associated with your bank account
Name of your bank
May include your bank account number
Banking/financial partners
Platform use to understand your needs, how to improve our services and trace fraudulent activities
IP address
Device ID
Browser information
Analytics identifiers
Companies that provide data analytics such as Google Analytics
Terms You Need to Know
“Data Protection Laws” refers to the laws that are designed to protect your personal information and privacy in the place where you live. These include (1) “PIPEDA” (the Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities and users in Canada outside Quebec; (2) the Act Respecting the Protection of Personal Information in the Private Sector as amended by Law 25 (the “Quebec Private Sector Act”), which applies to our activities and users in Quebec; (3) any other applicable data protection law. Shakepay is committed to adhering to all the Data Protection laws.
Under PIPEDA, Shakepay “collects, uses, and discloses” your personal information. Under the Quebec Private Sector Act, Shakepay “collects, holds, uses or communicates to third persons” your personal information. Those phrases (or their variations) may be used interchangeably in this Policy.
“Financial Regulatory Laws” include the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), the Money-Services Businesses Act (Chapter E.12.000001), and various provincial securities laws and provincial securities regulatory authority exemptive relief. The Financial Regulatory Laws impose special obligations on Shakepay to which we are committed to adhering, and which may have an effect on our treatment of your personal information.
“Personal information” – this is information we collect from you or about you and which is defined in PIPEDA as “information about an identifiable individual.” Under the Quebec Private Sector Act, it is defined as “any information which relates to a natural person and allows that person to be identified either directly or indirectly.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. We take a broad view of what constitutes personal information and what qualifies as being about an identifiable individual / natural person.
“Services” includes but is not limited to our proprietary and fully automated platform accessible through the Website, Application and other means to buy, sell, deposit, transfer, earn, hold, or withdraw Bitcoin and other virtual currencies, to hold, transfer or withdraw funds and to use the Shakepay Card issued by a bank. You can find more details about the Services in our Terms of Use.
Who Handles Your Personal Information
The Platform is owned and operated by Shake Labs Inc., a Canadian federal corporation based in Montreal, Quebec with an office at the address listed below. Where this Policy refers to “Shakepay”, it may refer to Shake Labs Inc. and / or its affiliates (notably Shakepay Inc. and Shakepay Financial Inc.), and subsidiaries, and their respective shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy also refers to Shakepay and / or its Representatives.
Shakepay is a member of the Canadian Investment Regulatory Organization (CIRO) and is registered as an Investment Dealer with the Autorité des Marchés Financiers (AMF) and the securities regulatory authorities in all Canadian provinces and territories. Shakepay is also a Money Services Business (MSB) registered with FINTRAC and Revenu Québec.
Under PIPEDA, Shakepay is an “organization”; under the Quebec Private Sector Act, Shakepay is an “enterprise”.
If you want to ask us anything about what’s in this Policy, or anything else privacy- or data-related, or exercise any of your available privacy rights, you can contact our Chief Privacy Officer at:
Shakepay Chief Privacy Officer privacy@shakepay.com
or:
Shakepay Chief Privacy Officer 500 Place d'Armes, Suite 1800 Montreal, QC H2Y 2W2
Why We Use Your Personal Information
As a regulated investment dealer and Money Services Business, we are required by Financial Regulatory Laws to collect, process, store, and disclose certain Personal Information about our customers. Collecting this information allows us to provide you with exceptional Services, address customer service issues, improve Shakepay’s offerings, and communicate with you for business purposes. Rest assured, we do not sell or rent your personal information.
Under PIPEDA and the Quebec Private Sector Act, the legal basis for our collection and use of your Personal Information is your informed consent, and by submitting this Personal Information you acknowledge having granted this consent to Shakepay. In the event you withdraw your consent to use such Personal Information, you may no longer be able to access or use some, or all, of the Platform.
Shakepay also automatically collects certain information using “Third-Party Analytics Programs” such as Google Analytics to help us understand how our customers and other individuals use the Platform, but none of this information identifies you personally, except via an alphanumeric string. For example, each time you visit or use the Platform or log in to the Platform, we automatically collect (as applicable):
your IP address
the browser and computer or device type and ID
analytics identifiers (access times, the web page from which you came, the web page(s) or content you access, external links you click on, other engagement information, and other general related information).
We use information collected in this manner only to better understand your needs and the needs of the Platform customers in the aggregate. Shakepay also makes use of information gathered for statistical purposes to keep track of the number of visits to the Platform, the specific pages on the Platform, and customers with a view to introducing improvements to the Platform. Your IP address and other relevant information we collect using the Third-Party Analytics Programs may be used in order to trace any fraudulent or criminal activity, or any activity in violation of the Shakepay Terms of Use.
Who We Share Your Personal Information With
We share some of your Personal Information with certain types of third-party service providers, who are identified above. Some of these third-party providers may be located outside your home jurisdiction, including in the United States.
When we disclose Personal Information to a third-party service provider, we will only do so pursuant to a written agreement that protects the confidentiality of your information, except in urgent situations where this may not be possible.
The service providers that we use for the Platform that may have access to your Personal Information, and their subprocessors, may change over time as we continuously improve our Services. If you have concerns or would like to know more about the specific service providers involved at a certain time, please contact our Chief Privacy Officer with the details of your request, using the contact information provided above.
Shakepay may share your Personal Information with law enforcement, government agencies or other public authorities in the following circumstances:
Legal Obligations: When required by applicable laws (especially the Financial Regulatory Laws) in response to lawful requests, including those related to national security, law enforcement and governmental bodies.
Preventing Harm or Illegal Activities: When we believe it is necessary to investigate, prevent, or take action regarding illegal activities, including but not limited to fraud, terrorist financing or situations involving potential threats to the safety of any person. This also includes any violation of the Terms of Use that apply to you.
Protecting the Platform: When we believe it is necessary to investigate, prevent, or take action regarding situations that involve misuse of the Platform infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks or attempts to compromise the security of the Platform infrastructure or the Platform generally).
Our disclosures will be limited to the purpose of assisting our customers with making use of our Services, addressing an error that has occurred, or preventing/investigating the occurrence of what is or may be a criminal offence. An example of the foregoing would be responding to an inquiry from a bank about a wire transfer a customer was attempting to make to Shakepay, and the bank requires more information or confirmation from Shakepay about the transaction.
Shakepay uses certain third-party email services providers to communicate with you about the Platform, and to send you promotional communications (the “Email Service Providers”). Personal Information (your email address) is transferred to the Email Service Providers in order for the emails to be sent out properly. Your Personal Information is only used to send out emails; the Email Service Providers do not use this Personal Information for any other purpose, and will not transfer or sell your Personal Information to any other third party.
You may unsubscribe from receiving promotional emails from us at any time by following the link at the bottom of any email sent to you. Other emails that are related to Platform functions will not have an opt-out option as they are necessary for the use of the Platform. You can also unsubscribe from any of our marketing communications by contacting us at help@shakepay.com.
We Use Tracking Technology (“Cookies”)
Shakepay uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) in the Platform, and by interacting with the Platform you agree to their use.
Cookies are small text files placed on your computer or device when you visit a website or use an online service, in order to track use of the site or service and to improve the user experience by storing certain data on your computer or device.
We use cookies and related technologies for the following functions:
to enable your logging-in to the Platform;
to provide general internal and user analytics in the Platform and to conduct research to improve the content of the Platform using the analytics programs as described above in this Policy;
to track and differentiate users; such cookies and other related technologies are used by third-party services integrated into the Platform; and
to assist in identifying possible fraudulent activities.
Your browser or device can be set to refuse cookies or delete them after they have been stored. You can refer to your browser’s or device’s help section for instructions, but here are instructions for the most commonly-used browsers and operating systems:
Please note that deleting or blocking certain cookies may reduce your user experience by requiring you to re-enter certain information, including information required to use certain services available on the Platform. Furthermore, deleting certain cookies may prevent certain functions, or the entirety of the Platform, from working at all.
How We Protect Your Personal information
Shakepay ensures that your Personal Information is held securely and implements access controls to reduce access to Personal Information on a "need-to-know" basis within the company. We have implemented very strict technical and organisational procedures for ensuring that, by default, only Personal Information which are necessary for each specific purpose are collected, used and disclosed by us. These procedures prevent your Personal Information from being lost; or used or accessed in any unauthorised way.
We also have procedures in place to deal with any suspected or actual data security breach. We will notify you and any applicable supervisory authority of a suspected or actual data security breach where the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.
Shakepay uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage and related technology required to operate the Platform, and these third parties have been selected for their high standards of security, both electronic and physical.
All information, including Personal Information, is transferred with encryption Transport Layer Security (“TLS”), the most robust security standard for Internet data transfer and transactions. You can use your browser to check Shakepay’s valid TLS security certificate on the Platform.
Finally, Shakepay is proud to be SOC 2 certified. SOC 2 is an independent auditing procedure that ensures the privacy and data of our customers is protected based on the five “trust service principles” of security, availability, processing integrity, confidentiality and privacy.
Your Bank Account Information and certain Verification Information (specifically images of your face) are considered sensitive personal information under the Data Protection Laws, and they will be treated with the heightened security and privacy the Data Protection Laws require.
Your Rights Regarding Your Personal Information
You have the following rights regarding your Personal Information held by Shakepay. Please note that the availability of these rights may vary depending on the Data Protection Laws applicable in your location.
Withdraw Your Consent: You can change your mind at any time and stop Shakepay from using your Personal Information;
Delete Your Data: Ask us to erase your Personal Information from our records;
View Your Data: Access your Personal Information and any relevant information around its collection, use, and disclosure;
Get a Copy of Your Info: Request an easy-to-read copy of your data to share with another organization if you’d like.
Update Your Info: Let us know if your Personal Information is wrong or outdated, and we’ll fix it.
Opt-Out of Marketing: You can stop receiving promotional emails or messages from us anytime.
Know Who Gets Your Info: Find out if we share your data (we don’t sell or rent it) and see the relevant sections in this Policy for details. Contact our Chief Privacy Officer if you have more questions.
Limit How We Use Your Info: If your Personal Information is incorrect or if we’re handling it improperly, you can ask us to restrict its use.
Say No to Targeted Ads: Refuse any marketing or advertising targeted at you by Shakepay.
If you wish to exercise any of these rights, please contact our Chief Privacy Officer at the contact information above.
If you request erasure of your Personal Information, we will comply to the extent feasible; however, Shakepay reserves the right to retain some Personal Information for a reasonable time to fulfill legal obligations or comply with legal processes, particularly those required under Financial Regulatory Laws, as provided in the Data Retention section below.
Please note that deletion of your Personal Information may limit or prevent you from using all or a portion of the Platform.
Data Retention
Your Personal Information will generally be retained only as long as necessary for the purpose for which it was collected. For example, we will retain your Platform account information only for as long as your account remains active.
However, because Shakepay is regulated under the Financial Regulatory Laws, we are required to keep certain Personal Information for up to seven years to comply with these legal obligations. Rest assured, we will continue to safeguard your Personal Information to our very high standards and according to this Policy throughout the retention period.
Automated Decision-Making
Shakepay uses certain automated decision-making process in our provisions of the Platform as it relates to your Personal Information, notably using images of your face to verify your identity.
Children’s Privacy Statement
The Platform is not intended for children under the age of 18. We do not knowingly collect any Personal Information from a child under 18. If we become aware that we have inadvertently received Personal Information from a person under the age of 18 through the Platform, we will delete such information from our records.
Changes to this Privacy Policy
The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy. You can always find the most updated version at this URL, and we will always post a notice on our Platform if we make big changes. If you have an account to use the Platform, we will also email you to tell you the Policy has been updated, and what the important changes are.
Complaints
If you are located in Canada outside Quebec and you are not satisfied with the response received or the actions taken by our Chief Privacy Officer, you have the right to file a complaint to the Office of the Privacy Commissioner of Canada at:
Office of the Privacy Commissioner of Canada 30 Victoria Street Gatineau, Quebec K1A 1H3 Toll-free: 1-800-282-1376 Phone: (819) 994-5444 Fax: (819) 994-5424
You can also find instructions on how to proceed with a complaint on their website. In Quebec, you can submit a complaint to the Commission d’accès à l’information du Québec, with further information available on their website.
Last update: January 8, 2025
Last updated