top of page

Canadian ATM Brokerage Inc. Privacy Policy

1. Introduction and Scope

 

1.1 Company Information

Canadian ATM Brokerage Inc. ("Canadian ATM Brokerage," "we," "us," or "our") is a corporation incorporated under the laws of Canada, specializing in the brokerage and advisory of ATM businesses and ATM route transactions across Canada. Our primary offices are located at:
 

  1. 4831 Nelson Rd. NW, Calgary, Alberta T2K 2M1, Canada
     

  2. Telus Sky Tower, 685 Centre Street South, Calgary, Alberta T2G 2C7, Canada
     

Privacy Contact: privacy@atmbrokerage.ca

 

1.2 Business Model Disclosure

Canadian ATM Brokerage operates under a dual‑jurisdiction model to meet provincial licensing requirements and deliver the following services:

 

1.2.1 Direct Advisory & Brokerage Services

Applicable in Alberta, British Columbia, Saskatchewan, Manitoba, New Brunswick, Nova Scotia, Prince Edward Island, Newfoundland and Labrador, Northwest Territories, Nunavut, and Yukon:

  1. Strategic advisory and brokerage transaction facilitation for ATM routes;

  2. Retainer fees of CAD 5,000–CAD 55,000 for portfolios comprising 5–500 ATMs; or CAD 55,000+ for portfolios exceeding 500 ATMs, adjusted for complexity;

  3. Success fees of 6%–10% of the transaction consideration (with retainer fees creditable against such success fees);

  4. Operational‑excellence and regulatory‑compliance consulting;

  5. Coordination of professional networks and specialist referrals.

 

1.2.2 International Purchaser Facilitation (New Service)

When a vetted non‑Canadian buyer is engaged:

  1. Supplemental retainer fee of CAD 15,000+;

  2. Success‑fee uplift of +1 percentage point on the base 6%–10% success fee;

  3. Cross‑border due diligence, sanctions screening, translation, and foreign privacy‑law compliance assistance.

 

1.2.3 Lead Generation Services (Ontario and Quebec)

Subject to the Business Brokers Act (Ontario) and applicable Quebec regulations:

  1. Lead identification and buyer–seller introductions at no up‑front cost to sellers;

  2. Referral fee of CAD 1,500 per qualified lead;

  3. Success fees of 1.0% by the seller and 1.0% by the buyer, payable on closing;

  4. Engagement of provincially licensed brokers and professional advisors through partnership arrangements.

Revenue Sources: Retainers; success‑fee income; referral fees; compliance‑consulting fees; and cross‑border surcharge fees.
 

1.3 Regulatory Expertise and Compliance

Our team possesses in‑depth knowledge of the ATM industry’s regulatory framework, including:

  1. FINTRAC Money Services Business (MSB) registration and compliance;

  2. Anti‑Money Laundering (AML) program design and implementation;

  3. Business transition planning within regulated financial sectors.
     

FINTRAC Certification Status: Currently pursuing FINTRAC MSB registration to strengthen our compliance advisory offerings.
 

1.4 Jurisdictional Scope and Legal Framework

This Privacy Policy applies to all operations of Canadian ATM Brokerage in Canada and is governed by:

  1. Alberta Personal Information Protection Act (PIPA);

  2. Personal Information Protection and Electronic Documents Act (PIPEDA);

  3. Canada’s Anti‑Spam Legislation (CASL);

  4. Applicable provincial privacy laws.


1.4.1 Service Limitations

  1. Ontario: We provide solely lead‑generation services and refer to licensed brokers. 

  2. Quebec: We provide solely lead‑generation services via licensed professional partners. 

  3. Other Provinces/Territories: Full direct advisory & brokerage services as permitted by local legislation.
     

1.5 Scope of Application

This Privacy Policy governs the collection, use, disclosure, and retention of personal information in respect of:

  1. Direct advisory and transaction‑facilitation services;

  2. Lead generation services in Ontario and Quebec;

  3. Regulatory‑compliance consulting services;

  4. Operation and maintenance of our website and digital platforms;

  5. Communications with clients, prospects, referral partners, and other stakeholders.
     

Related Documents: Terms of Service; Services Disclaimer; Cookie Policy; Engagement Agreements.
 

2. Information We Collect


2.1 Personal Information Categories

We collect only the personal data necessary to provide our services, including:

  1. Contact Details: Name; business email; business telephone; business mailing address; province of operation;

  2. Business Profile Data: Entity name and structure; ATM count; geographic ATM distribution; years in operation; annual revenue figures;

  3. Regulatory/Compliance Data: FINTRAC MSB registration status; AML program details; processor agreements; EMV compliance status; armoured‑car arrangements; lease terms with merchants;

  4. Transaction Preferences: Desired sale price range; valuation expectations; succession‑planning objectives; growth‑strategy considerations; preferred transaction structure and timing;

  5. Communications Preferences: Consent for marketing materials; preferred methods and timing; consent for information sharing with specialists or partner firms.

 

2.2 Technical Information

Automatically collected information may include:

  1. Website Analytics: IP address; browser and device type; operating system; pages viewed; session duration; referrer URLs;

  2. Call Recording Data: Audio recordings (with explicit, documented consent); transcripts; metadata (date, time, duration, participants);

  3. Meeting Scheduling Data: Timing preferences; calendar‑integration metadata; attendee details;

  4. Cookie Data: Session, preference, analytics, and marketing cookies as set out in our Cookie Policy.

 

2.3 Information We Do Not Collect

Canadian ATM Brokerage does not collect:

  • Banking or financial account numbers;

  • Social Insurance Numbers or other government‑issued identifiers;

  • Credit card data (all payment processing via Stripe under its own protocols);

  • Personal health information or other sensitive personal data beyond business‑related information;

  • Complete financial statements or personally identifiable data unrelated to ATM operations.
     

3. How We Collect Information

 

3.1 Direct Collection Methods

Personal information is collected directly through:

  1. Web forms (inquiry, transaction, subscription, and content‑download forms);

  2. Email and written communications;

  3. Telephonic and in‑person consultations;

  4. Transaction due‑diligence documentation submissions.

 

3.2 Indirect Collection Methods

We may collect information via:

  1. Web analytics (e.g., Google Analytics);

  2. Referrals from licensed brokers in Ontario and Quebec;

  3. Trade‑association directories and public business registries.

 

3.3 Third‑Party Sources

With appropriate client consent, data may be obtained from:

  1. Licensed business brokers;

  2. Compliance consultants and legal advisors;

  3. Industry associations;

  4. Publicly accessible sources.
     

4. Purposes of Collection and Use

We use personal information to:

  1. Provide advisory, brokerage, and compliance services;

  2. Facilitate transaction due diligence and closings;

  3. Coordinate referrals to legal, accounting, and technical specialists;

  4. Communicate market updates, regulatory developments, and company notices;

  5. Enhance service delivery through analytics and client feedback;

  6. Comply with legal, regulatory, and audit requirements.
     

5. Information Sharing and Disclosure


5.1 Professional Referrals

With prior written consent, we share necessary information with professional advisors (lawyers, accountants, valuers, compliance specialists) to fulfil transaction‑related mandates.
 

5.2 Lead Generation Partnerships (Ontario and Quebec)

Data is shared only with provincially licensed brokers upon explicit written approval by the prospect.
 

5.3 Technology Service Providers

We engage third‑party service providers to support our operations. With appropriate contractual and privacy safeguards, these providers may process personal information on our behalf:

  1. Call Recording and Transcription Services

    • Audio recordings of consultation calls (with explicit consent);

    • Call transcripts generated through secure platforms;

    • Call metadata (date, time, duration, participants);

    • Meeting notes and follow‑up action items.

  2. Meeting Scheduling and Calendar Management (Calendly)

    • Meeting scheduling preferences and availability;

    • Calendar integration and appointment confirmation data;

    • Meeting participant information and contact details;

    • Automated reminder and follow‑up communications.

  3. Website and Analytics Platforms

    • Website usage data and behavioral analytics;

    • Anonymized user interaction information;

    • Technical performance and optimization metrics;

    • Marketing campaign effectiveness measurement.

  4. Customer Relationship Management (CRM) Platforms

    • Client and prospect data storage and management;

    • Email marketing and communication services;

    • Document management and sharing platforms;

    • Secure data access controls.

  5. Payment Processing (Stripe)

    • Payment transaction information for retainer and success fees;

    • Billing and invoice data;

    • Financial transaction records for accounting and audit purposes.
       

5.4 Cross‑Border Transfers

For international purchaser facilitation, we implement:

  1. NDA with Canadian‑equivalent privacy safeguards;

  2. Exclusion of FINTRAC‑protected filings (PCMLTFA section 55);

  3. Client notification and informed consent;

  4. Contractual safeguards ensuring adequate data protection.
     

5.5 Legal and Regulatory Obligations

We may disclose personal information when required by law, including under subpoena, court order, or regulatory inquiry.
 

5.6 Business Transitions

In a sale, merger, or acquisition, client data may be transferred to the acquiring party, subject to continued adherence to this policy.
 

6. Consent Mechanisms and Management Consent Mechanisms and Management

6.1 Express Consent

We obtain express consent for:

  1. Marketing and educational communications;

  2. Call recording;

  3. Sharing data with third‑party specialists;

  4. Cross‑border data transfers.


6.2 Withdrawal of Consent

Consent may be withdrawn at any time by contacting privacy@atmbrokerage.ca. Withdrawal does not affect the propriety of prior processing.


6.3 Implied Consent

We rely on implied consent for routine client communications and service‑related follow‑ups where no new personal data is collected.
 

7. Data Retention and Disposal


7.1 Retention Periods

  1. Active client records: retained for up to 2 years after last interaction;

  2. Completed transaction files: retained for up to 7 years to satisfy audit and tax requirements;

  3. Call recordings: retained for up to 3 years;

  4. Web analytics and marketing data: retained for up to 26 months.


7.2 Secure Disposal

We employ secure deletion or anonymization practices in accordance with industry standards when data retention periods expire.
 

8. Security Safeguards

We maintain technical, administrative, and physical safeguards, including:

  1. Access controls and multi‑factor authentication;

  2. Encryption of data in transit and at rest;

  3. Regular vulnerability assessments and incident‑response planning;

  4. Secure facility access controls and clean‑desk protocols;

  5. Vendor due‑diligence and contractual privacy obligations.
     

9. Individual Rights

9.1 Access and Correction

Clients have the right to access and correct their personal information by contacting privacy@atmbrokerage.ca. We will respond within 30 days.

 

9.2 Data Portability

Upon request, clients may receive their personal data in a structured, machine‑readable format for portability.

 

9.3 Complaints and Oversight

Clients may escalate complaints to our Privacy Officer or file with:

  1. Alberta Office of the Information and Privacy Commissioner;

  2. Office of the Privacy Commissioner of Canada;

  3. Other applicable provincial privacy authorities.
     

10. Cross‑Border Data Considerations

Personal data is processed outside Canada only with client consent and under contractual arrangements providing equivalent privacy protection.
 

11. Service‑Specific Disclosures

11.1 Direct Advisory Services

All retainer and success‑fee structures are disclosed in writing prior to engagement.


11.2 Lead Generation Services

Clients must explicitly approve any data shared with licensed brokers. Referral and success‑fee terms are provided up front.


11.3 Call Recording

Recordings are used solely for service accuracy; they are not used for AI training.
 

12. Marketing and Communications

12.1 Electronic Messaging

We comply with CASL, requiring express consent and clear unsubscribe mechanisms in all commercial messages.


12.2 Educational Outreach

Clients may opt in to receive newsletters, market insights, and regulatory bulletins at any time.


12.3 Social Media and Digital Platform Engagement

  1. Platform Interaction and Data Collection

    • Social media engagements (likes, shares, comments) are subject to each platform’s privacy policy;

    • We do not collect personal information through social channels without explicit consent;

    • We may analyze engagement metrics (e.g., post reach, impressions) in aggregated, anonymized form to improve our content strategy.

  2. Content Strategy and Professional Networking

    • We publish educational and regulatory updates relevant to the Canadian ATM industry;

    • We use professional networking platforms (e.g., LinkedIn) to share industry insights and opportunities;

    • We ensure all social media communications respect user privacy and comply with platform terms and Canadian privacy laws.
       

13. Policy Updates Policy Updates

We review this policy annually or whenever required by law or business changes. Material amendments will be announced at least 30 days in advance.
 

14. Contact Information

Privacy Officer: privacy@atmbrokerage.ca
General Inquiries: info@atmbrokerage.ca
Business Hours: Monday–Friday, 9:00 AM–5:00 PM MST

Regulatory Contacts:

  • Alberta OIPC: Suite 2460, 801 6 Ave SW, Calgary, AB T2P 3W2 | (403) 297‑2728

  • OPC Canada: 30 Victoria St., Gatineau, QC K1A 1H3 | 1‑800‑282‑1376
     

15. Legal Document Cross‑References

  1. Terms of Service

  2. Services Disclaimer 

  3. Cookie Policy

  4. Engagement Agreements

16. Acknowledgment and Acceptance

By engaging Canadian ATM Brokerage, you acknowledge that you have read, understood, and agree to this Privacy Policy. Continued use of our services constitutes ongoing consent unless withdrawn in writing.
 

17. Effective Date and Version


Version: 2.1 – Cross‑Border Disclosures & Fee Surcharge
Effective Date: August 5th, 2025
Next Review: July 9, 2026 or earlier as appropriate

© 2025 Canadian ATM Brokerage Inc. All rights reserved.

bottom of page