SALSA CANADA PRIVACY POLICY 

Effective Date: November 20, 2025 

Salsa Payroll Canada Inc. (“Company,” “Payroll Provider,” “our,” “we”, “us”) respects its users’ privacy and is committed to protecting its users’ privacy through compliance with this Privacy Policy (the “Privacy Policy”). This Privacy Policy is part of our Terms of Use, available here (“Terms of Use”). 

In this Privacy Policy we describe the types of information we may collect from our users or that our users may provide when they use our website, salsa.dev (the “Website”), through our payroll platform (the “Platform”) or any other products, and/or services provided by us (collectively, the “Services”) and our practices for collecting, using, processing, and disclosing that information. Access and use of the Services may be as a (i) Website visitor; (ii) a business customer of one of more of our Services (a “Payroll Provider Customer”), (iii) a client of a Payroll Provider Customer (an “Employer-User”), or (iv) an employee of an Employer-User (an “Employee-User”) (collectively, “Users”). Please read this Privacy Policy carefully to understand our practices regarding your information and how we will treat it. By using the Services, Users agree to the collection, use and disclosure of information, including Personal Information (defined below) in accordance with this Privacy Policy. 

This Privacy Policy may not apply to information that we process on behalf of a Payroll Provider Customer where the Payroll Provider Customer is governed by a separate service agreement with Payroll Provider. If you have concerns regarding your personal information that is processed by a Payroll Provider Customer, please direct your concerns to the applicable Payroll Provider Customer.  

  1. Collection of Personal Information 

In this Privacy Policy, “Personal Information” means any information that relates to a natural person and allows that person to be identified, either directly or indirectly, including but not limited to sensitive personal information that entails a reasonable expectation of privacy. For example, Personal Information may include: (a) information about either an Employer-User or an Employee-User, such as email address, name, and banking information; and (b) information about a Payroll Provider Customer subscribed to the Platform and any information about the Employer-Users or Employee-Users uploaded to the Platform.  

When Users use our Services, we may collect or receive Personal Information to provide them our Services and operate our business. The types of Personal Information that we may collect include: 

  1. Information Provided to Us Directly 

We collect information from Users when they use our Services or contact us with inquiries. The Personal Information shall include: 

  • Contact Information – We collect Personal Information from Users when they use our Services. This includes Personal Information such as first and last name, date of birth, salutation, email address, billing and mailing address, professional title and company name, and phone number. 
  • Profile/Onboarding Data – We collect Personal Information from Users when they onboard to our Services. This includes demographic data such as city, country of residence,  marital status, familial or other relationship to third parties whose personal information you provide to us (including dependents), postal code, age, profile photo, username and password that you may establish through the Service, government-issued identification number data, preferences and any other information that you add to your account profile. 
  • Banking Information and Financial Data – We also collect Personal Information, including banking information and your stated income/wages, tax withholding rate and other related payroll information where applicable, from Users who use our Services. 
  • Marketing Data – We collect information such as your preferences for receiving our marketing communications and your engagement with them. 
  • Purchase or Order Details – We collect Personal Information related to purchases from Payroll Provider Customers. 
  • Other Identifiers – We also collect Personal Information including employer information, age, social insurance number, nationality and other government identifiers that will help identify the applicable tax withholding rate, from our Employee-Users and Employer-Users. 
  1. Information Received as Part of Communications  

When Users use our Services, communicate to use directly through the Platform, social media, or contact us by phone or email, we will automatically collect, and store certain Personal Information provided, and the activities engaged in by the applicable user. 

  1. Information Collected Automatically 

We will receive and store certain Personal Information about Users and their device(s) automatically when Users access or use the Platform. This information may include: 

  • Technical Information – We collect technical information associated with activity on the Platform, which may include information related to operating systems, information about your device, internet browsers and internet protocol (“IP”) address and other information that is accessing the Platform. Additionally, we may collect unique identifiers, including identifiers used for advertising purposes, language settings, mobile device carrier, radio/network information and general location information such as city or geographic area. We use such information for diagnostic and statistical purposes and to administer our Services. 
  • Platform Usage Information – We collect information through our third party services and business partners to better understand Users’ usage of the Platform and trends, which may include how individuals access the Platform, online activity and pages accessed, and how much time Users spend on the Platform. This information is used to analyze and improve the Platform and Services and provide a better experience for Users. 
  1. Location Information 

When Users use the Platform and/or Services, we may collect general location information (such as IP address). This information may be used to provide recommendations to Users, and to enhance Users’ experience and improve the Platform and Services.  

  1. Information Collected through Third Parties

We may collect Personal Information about Users from Payroll Provider’s business partners, financial service providers, identity verification services, and/or public sources to provide Users with the Services as part of our fraud detection, monitoring, and prevention measures. 

Further, we may collect Personal Information from Users from other sources and in response to marketing, promotional, or other communications, through social media or online interactions, connected to an actual or prospective business relationship with us, and/or by giving us contact details at events. 

We also may combine Personal Information that we receive from you with information we obtain from other sources, such as: 

  • Public Sources – Such as government agencies, public records, and other publicly available sources. 
  • Private Sources – Such as social media platforms and other third party data licensors. 
  • Marketing Partners – Such as Payroll Provider’s joint marketing partners or co-sponsors of Payroll Provider events. 
  • Service Providers – Such as third party service providers that provide services on Payroll Provider’s behalf or help us operate the Services or other aspects of our business. 
  • Business Transaction Partners – We may receive information about you in connection with an actual or prospective business transaction. For example, we may receive Personal Information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction.  

Note About Employee-Users: 

Please note that if you are an Employee-User, Payroll Provider may collect information directly from the Employee-User of the Payroll Provider Customer through which Employee-Users receive access to the Platform. An Employee-User’s agreement with the relevant Employer-User will explain how the Employer-User shares Personal Information with Payroll Provider, so we encourage Employee-Users to ask direct questions regarding their Personal Information with the applicable Employer-User.

  1. Use of Personal Information 

We may use Personal Information that we collect or receive about Users for various purposes. 

  1. To Provide Users with Our Platform and/or Services 

We use Personal Information to provide Users with our Platform and/or Services. If the applicable information is to be provided to, or the Services are to be performed by, a third party, then we will disclose the applicable Personal Information to the third party. Personal Information collected by us may be available or provided to a third party that is contractually obligated to protect Personal Information as disclosed in this Privacy Policy. 

  1. To Maintain, Support, Improve and Personalize the Services  

We use Personal Information from Users for our everyday business operations such as supporting, auditing, administering the Services, and analytics. Personal Information collected from Users may also be used to improve the content and/or functionality of the Services. For example, it may be used to help us improve our Platform’s functionality for payroll services. 

  1. To Communicate with Users

Subject to applicable law, we use Personal Information to communicate with and respond to Users where necessary. We may contact Users: 

  • To provide notices about their account with Payroll Provider, including expiration and renewal notices, as applicable; 
  • Subject to applicable law, regarding promotions or other communications that may be of interest; 
  • To notify about changes to the Services or the Platform; and
  • To provide notices about updates to payroll, payment timing, and other legal documentation and forms required to provide the Services.  

We comply with Canada’s anti-spam legislation (CASL) and we will not send you electronic communications in contravention of this law.  We will request that you expressly consent to receiving electronic communications from us. 

We will ensure that our electronic communications with you include an opt-out feature and instructions on how to un-subscribe if you no longer wish to receive future e-mail or text messages from us. You can unsubscribe using the link included in the e-mail/text message or by sending an e-mail to legal@salsa.dev. If you do not expressly consent to receiving electronic communications, we will only communicate with you for the limited purposes permitted under CASL.  

  1. To Maintain Legal and Regulatory Compliance

Our Services are subject to certain laws and regulations which may require us to process Users’ Personal Information. For example, we process Personal Information to fulfill our business obligations, or as necessary to manage risk as required under applicable law.

  1. To Enforce Compliance with Our Terms of Use and Policies

When Users access or use our Services, each are bound by our Terms of Use and this Privacy Policy. To ensure compliance, we process Users’ Personal Information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We also process Personal Information to investigate, prevent or mitigate violations of our internal terms, agreements or policies; and enforce our agreements with third parties and business partners. 

  1. To Protect Users, Others, and Our Business

We use Users’ Personal Information to protect Users, others, and our business, including, without limitation, using information for fraud prevention, for enforcement of our Terms of Use, to comply with the law, and to protect against security risks.

  1. For Our Business Purposes

We may use Personal Information for any other purpose disclosed to Users at the time we collect or receive the Personal Information, or otherwise with consent.

Personal Information provided to us or that we collect from third parties may be published or posted on non-public areas of the Platform to be accessed or viewed by the applicable Payroll Provider Customer or third parties that assist us in providing the Services, such as the relevant taxing authorities and/or vendors that assist with compliance matters (collectively, “User Content”). User Content is not posted in a public-facing medium; however, Users acknowledge that User Content is transmitted by Payroll Provider at the risk of Users. Therefore, we cannot and do not guarantee that User Content will not be viewed by unauthorized persons. Payroll Provider is not obligated to police, review or verify User Content in any way.  Payroll Provider is not responsible for and expressly disclaims any and all liabilities arising from any User Content. 

Finally, we may create aggregated, de-identified or anonymized data from your Personal Information and other individuals whose personal information we collect. We may use aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services, promote our business and to train our artificial intelligence or machine learning models. 

  1. Use of Cookies, Other Tracking Technologies and Do Not Track Settings
  1. Cookies and Other Tracking Technologies

We may use cookies, web beacons, pixels and similar technologies to collect information and personalize Users’ experience with the Services. We do not correlate tracking information to individuals, however some information collected, such as IP addresses, will be unique. 

We may use local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific web applications. 

Additionally, we may use web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened or that certain content was viewed or click. 

We may also use cookies to automatically collect information about you. Cookies are small web files that a site or its provider transvers to a device’s hard drive through a web browser that enables Payroll Provider to recognize the individual and remember certain information. We may use chat and other artificial intelligence technologies that employ cookies and/or software code to operate the chat features through the Services. These third party technologies may access and use information about webpages you have visited, your IP address, your general geographic information and other Personal Information you share through online chats or within inputs to facilitate the provision of the Services. 

We use first-party and third-party cookies for the following purposes: 

  • To make the Platform and/or our Services function properly; 
  • To improve the Platform and/or our Services or business; 
  • To recognize Users’ when they return to the Platform or the Services and to remember information that has been previously provided; 
  • To collect information about Users’ activities over time and across third-party website or other online services in order to deliver advertising tailored to specific interests; and 
  • To provide a service browsing experience for Users using our Services.  

Users may disable the use of cookies by modifying their bowser settings but note that doing so may alter features of the Platform or Services. 

 

  1. Third Party Use of Cookies and Other Tracking Technologies 

Some content accessible through our Services is served by third parties, including advertisers, ad networks and servers, content providers, and service providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect your Personal Information about Users when using the Services for the purposes of marketing. The information they collect may be associated with Personal Information or they may collect information about Users’ online activities over time and across many online services. 

We do not control these third parties’ tracking technologies or how they may be used. If Users have any questions about an advertisement or other targeted content, they should contact the responsible provider directly. 

  1. Do Not Track Settings

Payroll Provider does not track Users over time and across third party websites to provide targeted advertising, and therefore does not respond to Do Not Track (DNT) signals. However, some third party websites track browsing activities when Users use their websites so that they can tailor content to Users’ preferences. If Users are visiting such sites, a web browser may provide a setting so that third parties (particularly advertisers) know you do not want to be tracked.

  1. Children Under the Age of Majority   

Our Services are not intended for children under the age of majority, and Users are not allowed to use our Services or provide information to or on our Services if they are under the age of majority in the applicable jurisdiction. We do not knowingly collect Personal Information from children under the age of majority. If we learn we have received Personal Information from or about a child without verification of parental consent, we will delete that information immediately. If we might have any information from or about a child under the age of majority, please contact us immediately at legal@salsa.dev.

  1. Sharing of Personal Information with Third Parties

We may disclose aggregated information about Users, and information that does not identify any individual, without restriction.

Further we may share Personal Information of Users with the following entities:  

  • To our subsidiaries and affiliates or business partners; 
  • To contractors, service providers, and other third parties we use to support our business; 
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Payroll Provider’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Payroll Provider about all users is among the assets transferred; 
  • To fulfill the purpose for which the Personal Information was provided. For example, if an Employer-User give us an email address or mailing address so that we can send compliance documentation (such as payroll compliance and/or tax compliance), we will use that email address and/or mailing address to send the Employer-User such documentation; 
  • To banks, government agencies and taxing authorities, and state and local tax agencies as is required to provide the Services; 
  • To third party contractors in order to analyze the website performance and user behavior and/or to improve the Services; and 
  • To comply with any court order, to comply with applicable law, to prevent fraud, or respond to legal processes, or a request for cooperation by any government or regulatory entity.

Finally, we will also disclose Personal Information with consent or direction, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Payroll Provider, our customers, or others.

  1. Data Retention

We retain Personal Information we collect where we have an ongoing legitimate business need to do so (for example, to provide Users with the Services or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing legitimate business need to process Personal Information, we will either delete or anonymize the Personal Information or, if this is not possible (for example, because the Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from any further processing until deletion is possible. 

  1. Choices About How We Use and Disclose Users’ Personal Information

We strive to provide Users with choices regarding the Personal Information provided to us. We have created mechanisms to provide the following control over Personal Information:

  • Tracking Technologies and Advertising. Users may set their browser to refuse all or some browser cookies, or to alert them when cookies are being sent. To learn how Users can manage Flash cookie settings, visit the Flash player settings page on Adobe's website. If Users disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  1.       Accessing and Correcting Personal Information  

If you are a Payroll Provider Customer, you may review and change your Personal Information by accessing your account information. If you are an Employer-User or Employee-User, please contact the Payroll Provider Customer or Employer-User through which you have access to the Services to find out more information on how to access and/or correct your Personal Information. Users may send us an email at legal@salsa.dev to request access to, correct, or delete any Personal Information that has been directly provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Users also have the right to data portability, which includes the right to request that computerized Personal Information be communicated in written, intelligible transcript request that collected Personal Information be communicated to Users in a structured, commonly used format. 

This section lists the privacy-related rights that we extend to Users.  The right to know and right to deletion are not absolute and are subject to certain exceptions. For example, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, the applicable account with us or the security of our systems.

  • Right to Know – Users have the right to know the Personal Information we collect, use, and disclose about themselves.
  • Right to Deletion – Users have the right to request that we delete any Personal Information we have collected or maintain about them. We may save Personal Information when permitted by applicable law including, without limitation, when the Personal Information is needed for a legal purpose.
  • Right to Correction – Users may modify their Personal Information by contacting our Privacy Officer privacy@salsa.dev.
  • Right to Learn on Request – Users have the right to learn about their Personal Information on request and informed when we make a decision solely based on automated personal decision making.  

Users may also request that we provide them with a copy of their Personal Information in a commonly used electronic format so that it can be managed and moved.

Please note that we may ask Users to verify their identity before responding to such requests.

  1. Transferring Personal Information

Our Services are accessible within Canada. If Users are signing up to the Services in Canada, the Personal Information collected will be maintained on servers located in the United States.   

Please be aware that we and some of the third party service providers with whom we may share your information store information in the United States and other countries. As a result, your information will be transferred from Canada into the United States and may be transferred from there to another country to one of our third party service providers. Some of these countries (including the United States) may not have data protection laws as comprehensive or protective as those in Canada. For example, Personal Information may be subject to access requests from governments, courts or law enforcement agencies in those jurisdictions according to the laws in those jurisdictions. Personal Information may also be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. We will use reasonable efforts to ensure that appropriate protections of your Personal Information are in place during an international transfer of your Personal Information.  We will ensure such international transfers are legal by using valid legal methods (such as standard data protection clauses approved by the European Commission or the United Kingdom, or if we have your express consent to the transfer. 

Payroll Provider will take all steps reasonably necessary to ensure your Personal Information is treated securely and in accordance with this Privacy Policy. 

  1. Data Security  

We have implemented measures designed to secure Personal Information collected by us from accidental loss and from unauthorized access. For example, access to the Platform by a Payroll Provider Customer is available through a password and unique customer ID selected by the Payroll Provider Customer. This information is encrypted through the Services with secure socket layer technology (SSL) and is also encrypted when it is stored by us to prevent unauthorized parties from viewing such information. Also, we perform regular malware scanning of the Website, Platform and all servers and computers used by us to support the Services. All Payroll Provider employees are required to adhere to our security and confidentiality procedures and undergo training related to maintaining the security of user Personal Information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect Personal Information, we cannot guarantee the security of Personal Information transmitted to or through our Services. Any transmission of Personal Information is at the applicable user’s own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or through the Services.

      

  1. Legal Basis for Processing Personal Information

Our legal basis for collecting and using the Personal Information described in this Privacy Policy will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect or receive Personal Information from Users only (i) where we need the Personal Information to perform a contract with a Payroll Provider Customer; (ii) where the processing is in our legitimate interests and not overridden by Users’ rights; or (iii) where we have consent to do so.  We have a legitimate interest in operating our Services and communicating with Users as necessary to provide these Services, for example when responding to queries, improving our Platform, Website, and/or Services, undertaking marketing, or for the purposes of detecting or preventing illegal activities.

In some cases, we may also have a legal obligation to collect Personal Information or may otherwise need the Personal Information to protect Users’ vital interests or those of another person. If we ask Users to provide Personal Information to comply with a legal requirement or to perform a contract, we will make this clear at the relevant time and whether the provision of the Personal Information is mandatory.

  1. Third Party Links

The Services may contain links that lead to other websites, and Payroll Provider is not responsible for the privacy practices, content, and/or activities of these linked websites. In addition, our content may be integrated into web pages or other online services that are not associated with Payroll Provider. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control online services provided by third parties.  Nonetheless, we seek to protect the integrity of the Services and welcome any feedback about these external websites. 

  1. Changes to Our Privacy Policy  

This Privacy Policy may be amended by us from time to time in our sole discretion and without any prior notice to you.  The collection, use and disclosure of your Personal Information by us will be governed by the version of this Privacy Policy in effect at that time.  We will post any changes we make to the Privacy Policy on this page. Users may be notified of any material changes to our Services on our Website and/or by email to the most recent email address that was provided to us, if any. 

Users are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. 

  1. Individual Access and Accuracy of Personal Information

You may request access to your Personal Information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the Personal Information we hold about you. There is no cost for such access request unless you require copies of records. We may not be able to provide you with access to your Personal Information if the information cannot be separated from the Personal Information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your Personal Information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so. 

You may request to update and change your Personal Information at the contact information set forth below.  We shall endeavor to correct or complete any Personal Information which you advise us is inaccurate or incomplete. Where appropriate, the amended information shall be transmitted to third parties having access to such information.

  1. Contact Information  

We welcome your feedback. If you have questions, comments or concerns about this Privacy Policy, or would like to do any of the following: 

  • see your Personal Information that you have already sent us so that you can correct, update or delete it from our files;
  • if your child under 13 has used this Site and sent us Personal Information, delete that Personal Information from our files;
  • ask that we not send you electronic communications or otherwise contact you; or 
  • report any violation of this Privacy Policy,

Please contact our Privacy Officer at privacy@salsa.dev and we will endeavour to get back to you as soon as possible.