Privacy Policy
Last updated: August 3, 2026
Safety Ambassador Event Services Corp. · Operating as GigPay · Ontario, Canada
Legal Entity
Safety Ambassador Event Services Corp.
Operating Brand
GigPay
Version 1.1
Applies To
All GigPay users: contractors, business clients, and visitors
Privacy Officer
Compliance
Your Privacy Matters
This Privacy Policy explains how GigPay collects, uses, stores, shares, and protects your personal information. Please read it carefully. By creating an account or using GigPay, you consent to the practices described in this Policy. If you do not agree, you may not use the platform.
1. Who We Are
GigPay is a workforce marketplace and escrow-based payment platform operated by Safety Ambassador Event Services Corp. (“GigPay”, “we”, “our”, or “us”). The platform connects approved business clients with verified independent contractors for event staffing and security-related engagements, and facilitates escrow-based payment workflows through regulated banking and payment partners.
GigPay is committed to protecting your privacy and handling your personal information responsibly, in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy law. This Policy applies to all personal information collected by GigPay in connection with the platform, including through our website, mobile application, and any other interface through which you access GigPay services.
Legal Entity
Safety Ambassador Event Services Corp.
Operating Brand
GigPay
Privacy Officer
Compliance Email
Mailing Address
Safety Ambassador Event Services Corp., [Insert Corporate Address]
Jurisdiction
Ontario, Canada (launch); Canada-wide (planned)
2. Information We Collect
GigPay collects only the information necessary to operate the platform, verify identity, prevent fraud, process payments, and comply with legal and regulatory obligations. The table below summarizes the categories of information we collect, who it applies to, and whether it is required.
Category
Information Collected
Applies To
Required?
Identity Information
Legal name, date of birth, residential address, email address, phone number
Contractors & Business Clients
Yes
Government ID
Photograph of government-issued photo identification (driver’s licence, passport, provincial ID)
Contractors
Yes
Biometric / Liveness Data
Selfie photograph; liveness verification data collected via Sumsub
Contractors
Yes
Security Licence
Licence number, issuing province, expiry date, and licence status
Contractors (where applicable)
Conditional
Business Information
Business name, registration number, business address, authorized representative details, director and ownership information
Business Clients
Yes
Beneficial Ownership
Identity of individuals owning 25% or more of a business client entity
Business Clients
Yes
Banking Information
Bank account details, account ownership verification records
Contractors & Business Clients
Yes
Financial Records
Escrow funding records, booking amounts, payout history, refund and dispute records
Contractors & Business Clients
Yes
Compliance Screening Data
Sanctions screening results, PEP screening results, adverse media findings, identity verification outcomes, risk ratings
Contractors & Business Clients
Yes
Work Records
Booking records, time and attendance records, hours approved, work completion records
Contractors & Business Clients
Yes
Communications
Messages sent through the platform, support tickets, dispute submissions
Contractors & Business Clients
Conditional
Technical Information
Device identifiers, IP address, browser type, operating system, login activity, session data, cookies
All users
Automatic
Usage Information
Pages visited, features used, booking activity, search queries on platform
All users
Automatic
Biometric and Liveness Data
GigPay uses Sumsub to collect selfie photographs and liveness verification data from contractors during onboarding. This data is used solely for identity verification purposes. It is processed by Sumsub in accordance with their privacy practices. GigPay does not use biometric data for any purpose other than identity verification. You may request information about how this data is handled by contacting privacy@gigpay.ca.
GigPay does not collect or store full payment card numbers. Where card processing is involved, it is handled directly by our regulated payment partners.
GigPay does not knowingly collect personal information from individuals under 19 years of age. If we become aware that information from a minor has been collected, we will take reasonable steps to delete it promptly.
3. How We Use Your Information
GigPay uses personal information only for purposes that are reasonable and necessary to operate the platform, meet our legal obligations, and protect the safety of our users and banking partners. The table below sets out the specific purposes for which we use personal information and the legal basis under PIPEDA.
Purpose
Information Used
Legal Basis (PIPEDA)
Account creation and management
Identity information, contact information
Consent; contractual necessity
Identity verification (KYC/CIP)
Government ID, selfie/liveness data, biometric data
Legal obligation; consent
Security licence verification
Licence information
Legal obligation; contractual necessity
Compliance screening (sanctions, PEP)
Identity information, compliance screening data
Legal obligation
Fraud prevention and risk management
Identity, financial, technical, usage, and compliance data
Legitimate business interest; legal obligation
Escrow and payment processing
Banking information, financial records, booking and work records
Contractual necessity
Contractor payout management
Banking information, work records, payout history
Contractual necessity
Dispute resolution
Work records, communications, financial records
Contractual necessity; legitimate interest
Platform security monitoring
Technical information, usage information, login activity
Legitimate business interest
Communication with users
Contact information, account information
Contractual necessity; consent
Legal and regulatory compliance
All categories as required
Legal obligation
Banking partner compliance support
Identity, financial, compliance, and work records
Legal obligation; contractual necessity
Service improvement and analytics
Usage information, technical information (aggregated or anonymized where possible)
Legitimate business interest
GigPay does not use personal information for automated decision-making that produces legal or similarly significant effects on users without human review. All account restriction, suspension, and termination decisions involve Compliance Officer review.
4. Legal Basis for Collection and Processing
GigPay collects and processes personal information on the following legal bases under PIPEDA:
Legal Basis
When It Applies
Consent
Where you have expressly agreed to the collection or use of your information — including at account creation, onboarding, and where additional consent is sought for specific purposes such as biometric data collection.
Contractual Necessity
Where processing is required to perform our obligations under the Terms of Service, Independent Contractor Agreement, or Business Client Services Agreement — including account management, payment processing, and payout delivery.
Legal Obligation
Where we are required by law to collect or retain information — including under PIPEDA, applicable AML and financial crime legislation, FINTRAC obligations (where applicable), and banking partner compliance requirements.
Legitimate Business Interest
Where processing is reasonably necessary for fraud prevention, platform security, and risk management, provided our interests are not overridden by your privacy rights.
Where GigPay relies on consent as the legal basis for collection, you have the right to withdraw that consent at any time. Withdrawal of consent may affect your ability to access certain platform services. See Section 11 for information on how to exercise your rights.
5. Identity Verification and Compliance Screening
GigPay is required to verify the identity of all platform users before payment activity is permitted, and to screen users against applicable sanctions lists, PEP databases, and adverse media sources. These are legal and contractual obligations — they are not optional.
5.1 Our Verification Partner
GigPay uses Sumsub as its primary third-party identity verification and compliance screening provider. Sumsub processes personal information on our behalf under a written data processing agreement that requires Sumsub to protect your information and use it only for the purposes for which it is shared.
Sumsub’s services used by GigPay include:
Government-issued ID document verification
Selfie and liveness verification (biometric data)
Sanctions list screening (OSFI, OFAC, UN, EU, and other applicable lists)
Politically Exposed Person (PEP) screening
Adverse media screening
Fraud detection signals
5.2 What This Means for You
Your identity information will be shared with Sumsub to complete verification
Sumsub may process your information in jurisdictions outside Canada (see Section 10)
Your selfie and liveness data is biometric in nature and is handled with additional care
Screening results are retained by GigPay as part of your compliance record
You will not be able to access payment-related features until verification is complete
GigPay may require re-verification at any time — for example, when your ID expires or if a compliance concern arises
5.3 Ongoing Screening
Identity verification and compliance screening are not one-time events. GigPay conducts ongoing rescreening to ensure that users do not become subject to sanctions or adverse findings after onboarding. Material changes to your profile may also trigger re-verification.
6. How We Share Your Information
GigPay does not sell personal information. We do not share personal information with third parties for their own marketing purposes. We share information only as described in this section.
Recipient
Why We Share
Safeguards
Sumsub (Verification Partner)
Identity verification, liveness verification, sanctions/PEP/adverse media screening, fraud detection
Data processing agreement; information used only for verification purposes
Pateno Payments
Payment processing, escrow management, payout processing, fraud prevention, regulatory compliance support
Contractual obligation; Pateno maintains its own privacy and security program
DC Bank
Banking partner for escrow, trust account management, settlement, and regulatory reporting obligations
Contractual obligation; regulated financial institution; subject to OSFI oversight
Cloud Infrastructure Providers
Secure hosting and storage of platform data
Data processing agreement; encryption at rest and in transit
Customer Support Providers
Responding to user inquiries and support tickets (limited information only)
Data processing agreement; access restricted to what is necessary
Analytics Providers
Platform performance monitoring and improvement (aggregated or anonymized where possible)
Limited to technical and usage data; no sensitive personal information
Legal and Regulatory Authorities
Where required by law, court order, valid regulatory request, or lawful investigation
Disclosure limited to what is required; GigPay will seek to notify users where legally permitted
Professional Advisors
Legal counsel, auditors, and compliance advisors assisting GigPay with legal or regulatory obligations
Bound by professional confidentiality obligations
Successor Entity
In the event of a merger, acquisition, or sale of GigPay’s business, information may be transferred to a successor
Users will be notified and successor will be bound by this Policy or equivalent protections
We Do Not Sell Your Data
GigPay does not sell, rent, or trade personal information to any third party for commercial or marketing purposes. Information is shared only as necessary to operate the platform, meet legal obligations, and protect the safety of our users and banking partners.
7. Payment Processing and Banking Partners
Payments on the GigPay platform are processed through Pateno Payments and DC Bank, both regulated financial institutions. These partners maintain their own privacy, security, and compliance programs and are subject to oversight by applicable Canadian financial regulators.
To process payments and meet regulatory obligations, we share with our banking partners:
Verified identity information for contractors and business clients
Banking account information
Booking, escrow funding, and payout records
Compliance screening results and risk assessments
Any information required to support fraud prevention or regulatory reporting
GigPay’s banking partners may independently be required to report certain transactions or suspicious activity to FINTRAC or other regulatory authorities under Canadian law. GigPay cooperates with and supports those obligations.
GigPay does not collect or store full payment card numbers. Where card processing is required, it is handled entirely by our regulated payment partners, who apply their own PCI-DSS and security standards.
8. Data Retention
GigPay retains personal information only as long as reasonably necessary for the purposes described in this Policy, including operating the platform, resolving disputes, meeting legal obligations, and supporting banking partner compliance requirements.
Record Type
Minimum Retention
Reason
KYC and identity verification records
5 years minimum
AML compliance obligations; banking partner requirements; fraud prevention
Compliance screening results
5 years minimum
AML compliance; regulatory record-keeping; banking partner requirements
Transaction and financial records
5 years minimum
AML compliance; tax and accounting obligations; dispute resolution
Booking and work records
5 years minimum
Dispute resolution; audit readiness; contractual obligations
Compliance case files
5 years minimum
AML compliance; regulatory record-keeping; potential litigation
Account information (active accounts)
Duration of account
Ongoing service delivery
Account information (closed accounts)
5 years post-closure
Legal obligations; dispute resolution; fraud prevention
Technical and usage data
Up to 2 years
Platform security; analytics; fraud detection
Communications and support records
3 years
Dispute resolution; service quality; legal purposes
Where longer retention is required by applicable law, banking partner obligation, or an active legal hold, we will retain information beyond these periods. We will notify users of extended retention where we are legally permitted to do so.
When information is no longer required, we delete or anonymize it in accordance with our data destruction procedures.
9. Security
GigPay implements reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. Our security measures include:
Technical Controls
Administrative Controls
✓ Encryption at rest and in transit (TLS)
✓ Role-based access controls
✓ Multi-factor authentication
✓ Audit logging for sensitive data access
✓ Secure cloud infrastructure
✓ Vendor security review program
✓ Session management and timeout controls
✓ Documented access control policy
✓ Staff training on data handling
✓ Need-to-know access restrictions
✓ Vendor contractual security requirements
✓ Incident response procedures
✓ Annual compliance program review
✓ Data breach notification procedures
Important Limitation
No information security system can be guaranteed to be completely secure. GigPay cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We encourage you to use a strong password, enable multi-factor authentication, and contact us immediately if you suspect unauthorized access to your account.
In the event of a data breach that poses a real risk of significant harm to individuals, GigPay will notify affected individuals and the Office of the Privacy Commissioner of Canada as required under PIPEDA.
10. International Data Processing
GigPay is a Canadian company and stores data primarily in Canada. However, some of our service providers — including Sumsub — may process personal information in jurisdictions outside Canada, including in the United States and the European Union.
Where personal information is transferred internationally, GigPay takes the following steps to protect it:
We enter into written data processing agreements with all service providers that impose privacy and security obligations consistent with PIPEDA
We assess the privacy laws of destination jurisdictions before transferring information
We limit the information shared to what is necessary for the service being provided
Foreign Law Disclosure
Personal information transferred to service providers in foreign jurisdictions may become subject to the laws of that jurisdiction, including lawful access requests by foreign governments or courts. We cannot guarantee the same level of protection for information processed outside Canada as the laws of other jurisdictions may differ from Canadian privacy law.
11. Your Privacy Rights
Subject to applicable law, you have the following rights with respect to your personal information. GigPay will respond to all valid requests within 30 days, or notify you if more time is required.
Right
Description
How to Exercise
Right of Access
You may request a copy of the personal information GigPay holds about you, and information about how it is being used and with whom it has been shared.
Email privacy@gigpay.ca
Right to Correction
You may request that inaccurate or incomplete personal information be corrected. Note that some records (e.g., compliance records) may not be amended.
Email privacy@gigpay.ca
Right to Withdraw Consent
Where GigPay relies on consent as the legal basis for processing, you may withdraw consent at any time. Withdrawal may affect your ability to use platform services.
Email privacy@gigpay.ca
Right to Know How Used
You may request information about the purposes for which your personal information is being used and the third parties to whom it has been disclosed.
Email privacy@gigpay.ca
Right to Complain
If you believe GigPay has mishandled your personal information, you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca.
Limitations on Rights
Some privacy rights are subject to limitations under applicable law. For example, GigPay may be required to retain compliance, transaction, and identity verification records for a minimum of five years regardless of a request for deletion. We will inform you of any limitations that apply to your request and explain our reasons.
12. Cookies and Analytics
GigPay uses cookies, session tracking technologies, and analytics tools to operate and improve the platform. The types of cookies we use include:
Cookie Type
Purpose
Can You Opt Out?
Essential / Functional
Required for the platform to operate, including login sessions, security, and escrow workflow functionality
No — disabling these will prevent platform use
Security Monitoring
Used to detect fraud, account takeover, and unauthorized access
No — required for platform security
Analytics
Used to understand how the platform is used and improve performance (aggregated data where possible)
Yes — via browser cookie settings; some functionality may be limited
13. Children’s Privacy
GigPay is not intended for use by individuals under 19 years of age. We do not knowingly collect personal information from minors. All contractors must confirm they are at least 19 years old as part of the onboarding process.
If GigPay becomes aware that personal information has been collected from an individual under 19 without appropriate consent, we will take prompt steps to delete that information and terminate the associated account. If you believe a minor has created an account on GigPay, please contact us at privacy@gigpay.ca.
14. Changes to This Policy
GigPay may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, banking partner requirements, or regulatory developments. When we make material changes, we will provide reasonable notice to active users through the platform or by email before the changes take effect.
The “Last Updated” date at the top of this Policy reflects the most recent revision. Continued use of GigPay after a Policy update constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you must stop using the platform and contact us to close your account.
15. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or the handling of your personal information, please contact GigPay’s Privacy Officer:
GigPay Privacy Officer
Privacy inquiries: privacy@gigpay.ca
Compliance inquiries: compliance@gigpay.ca
Mailing address: Safety Ambassador Event Services Corp., [Insert Corporate Address]
GigPay will respond to all privacy requests within 30 days. If your concern is not resolved to your satisfaction, you may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or 1-800-282-1376.
16. Consent
By creating an account, submitting personal information, completing identity verification, or using the GigPay platform in any capacity, you confirm that you have read and understood this Privacy Policy and consent to the collection, use, disclosure, and retention of your personal information as described herein.
Where you are providing personal information on behalf of a business client, you confirm that you are authorized to provide that information and to bind the business to the terms of this Policy.
You may withdraw consent at any time by contacting privacy@gigpay.ca, subject to the limitations described in Section 11. Certain information may be retained following withdrawal of consent where required by law or legitimate business purpose.
Approved By
James McBean — Co-Founder, Interim Compliance Officer
Date
________________________________
Approved By
Christine Byrd — Co-Founder
Date
________________________________
Version
1.1
Effective Date
[Insert Date]
Last Updated