Privacy policy
Last updated: November 10, 2024
This Privacy Policy outlines our practices regarding the collection, use, and disclosure of your personal information when you use our Service. It also informs you of your privacy rights and how the law safeguards your data. We use your personal data to provide and enhance the Service. By using the Service, you consent to the collection and use of information as described in this Privacy Policy.
INTERPRETATION AND DEFINITIONS
Interpretation
Words with capitalized first letters have meanings defined under the following conditions. The definitions will have the same meaning whether they appear in the singular or plural form.
Definitions
For the purposes of this Privacy Policy:
Account: A unique account created for you to access our Service or its parts.
Affiliate: An entity that controls, is controlled by, or is under common control with a party, where "control" refers to owning 25% or more of the shares, equity interest, or securities entitled to vote for directors or other managing authority.
Company: Refers to PRIVATEPAY LIMITED, located at 329 HOWE STREET VANCOUVER BC V6C 3N2 CANADA, registered under number BC1505968. In this Agreement, "the Company," "We," "Us," or "Our" refers to PRIVATEPAY LIMITED. Under the GDPR, the Company is the
Data Controller.
Cookies: Small files placed on your computer, mobile device, or other devices by a website to store details of your browsing history, among other uses.
Country: Refers to British Columbia, Canada.
Data Controller: For the purposes of the GDPR (General Data Protection Regulation), this refers to the Company, as the legal entity that determines the purposes and methods of processing personal data.
Device: Any device that can access the Service, such as a computer, smartphone, or tablet.
GDPR: Refers to the EU General Data Protection Regulation.
Personal Data: Any information related to an identified or identifiable individual. Under the GDPR, personal data includes identifiers such as name, identification number, location data, and other factors related to an individual's physical, genetic, mental, economic, cultural, or social identity.
Service: Refers to the Website https://privatepay.io
Service Provider: A third-party company or individual who processes data on behalf of the Company. Service Providers assist in providing the Service, performing services related to the Service, or analyzing how the Service is used. Under the GDPR, Service Providers are Data Processors.
Usage Data: Data collected automatically through the use of the Service or its infrastructure, such as the duration of page visits.
You: The individual using the Service, or the company or legal entity on behalf of which the individual is accessing or using the Service. Under the GDPR, You may be referred to as the Data Subject or User.
COLLECTING AND USING YOUR PERSONAL DATA
Types of Data Collected
Personal Data
You may provide us with personal information when signing up to use our Services, such as your name and email address. This also includes data provided through your continued use of our Services, participation in discussions, surveys, promotions, or by reporting issues with the Services. Additional information we may collect includes:
Personal identification details like address, phone number, financial information (credit/debit card or bank account details), geographical location, social security or national ID number, personal description, photos, tax reference, proof of address or residency, passport, and other identification documents.
Communication content with us, including records of phone calls, online chats, emails, direct messages, and other interactions.
In some cases, such as for large transactions or compliance with anti-money laundering regulations, we may require further identification details, including bank account statements.
When you provide personal data of others (e.g., connected persons), you confirm that you have obtained their consent to share their information with us or are otherwise authorized to do so. You also confirm that you have informed them of this Privacy Policy and obtained their consent for the collection, use, and disclosure of their personal data.
To ensure accuracy, please keep your personal data up to date by logging into your account and making necessary updates.
Usage Data
Usage Data is collected automatically when you use the Service. It includes information such as:
Your Device's IP address, browser type, browser version, pages visited on our Service, time and date of visits, time spent on those pages, unique device identifiers, and other diagnostic data.
When accessing the Service via a mobile device, we may collect additional information, such as device type, mobile operating system, mobile browser type, and other device-specific identifiers.
TRACKING TECHNOLOGIES AND COOKIES
- We utilize cookies and other tracking technologies to monitor activity on our Service and to store certain information. These technologies, including beacons, tags, and scripts, help us collect data and analyze how the Service is used. The tracking technologies we use may include:
- Cookies or Browser Cookies: A cookie is a small file placed on your device. You can set your browser to refuse all cookies or to notify you when a cookie is being sent. However, if you refuse cookies, some parts of our Service may not be accessible to you. Unless you adjust your browser settings to reject cookies, our Service may use them.
- Web Beacons: Some sections of our Service and our emails may contain small electronic files, known as web beacons (or clear gifs, pixel tags, and single-pixel gifs), which allow the Company to count users who have visited certain pages or opened emails, and gather other related statistics (such as measuring page popularity and verifying system integrity).
- Cookies can be either "Persistent" or "Session" cookies:
- Persistent Cookies: These remain on your personal computer or mobile device even when you are offline.
- Session Cookies: These are deleted when you close your web browser.
- We use both types of cookies for the following purposes:
- Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These cookies are necessary to provide you with services available through our Website and to enable you to use some of its features. They help authenticate users and prevent fraudulent account use. Without these cookies, the requested services cannot be provided.
- Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These cookies identify whether users have accepted the use of cookies on the Website.
- Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These cookies help us remember your preferences, such as login details or language preferences, offering you a more personalized experience. These cookies eliminate the need for you to re-enter your preferences each time you visit the Website.
- Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These cookies are used to track website traffic and analyze how users interact with our Service. The information gathered may be linked to a pseudonymous identifier associated with the device you use. This data helps us evaluate and test new pages, features, and functionalities of the Website.
- For more information on the cookies we use and your options regarding cookies, please refer to our Cookies Policy or the Cookies section of this Privacy Policy.
- Information We Receive from Other Sources
- We may obtain information about you if you use any of the other websites or services we operate. We also collaborate with third parties and may receive information about you from them. This could include:
- Payment Service Providers: If you use a payment service to transfer money to us, these providers may share your personal and financial information with us, such as your name, address, and bank account details.
- Banks: If you link a bank account to your PRIVATEPAY LIMITED account for regulatory verification purposes, your bank may share your personal and financial details with us, including the source of funds and bank statements.
- Connected Persons: If you are a connected person to an PRIVATEPAY LIMITED customer, that customer may provide us with your personal information, including payment beneficiary details (e.g., name, account details, email), or director and beneficial owner information (e.g., name, date of birth, country of residence).
- Business Partners: Our partners may provide us with your name, address, and financial details, including payment card information.
- Advertising Networks, Analytics Providers, and Search Information Providers: These third parties may provide us with pseudonymized information about you, such as how you found our website.
- Identity Verification: In some jurisdictions, we may verify the information you provide by cross-checking it with government or private identity record databases or credit reference agencies to confirm your identity and prevent fraud.
- Information from Social Networks
- If you log into our Services using your social network account (e.g., Apple ID, Facebook, Google, Instagram, Twitter, WeChat), we may receive the necessary information to authenticate your access. The social network will provide us with information you’ve shared with them, such as your name, profile picture, and email address, in accordance with the social network provider’s privacy policy.
- We use this information along with other data you provide to us when registering or using our Services, to create your account and communicate with you about the products, services, and information you request. Additionally, you may request that we access the contacts in your social network account.
Sensitive Data
As part of our identity verification process, we may collect, use, and store biometric data. This includes:
Face Scan Information: We extract face scan data from photos and videos to compare pictures on your identity documents with each other and with a selfie you provide. This is done to verify your identity, for anti-fraud checks, and to improve these processes. We may ask for your explicit consent to collect, use, and store your biometric data during the verification process, especially where privacy regulations require it in your jurisdiction. If you do not consent, we offer alternative methods of verification, though they may take longer. The documents and photos required for both methods remain the same.
Storage and Disclosure: We will not share biometric data except with our identity verification providers, or as required by law or by a court order. We never sell, lease, or benefit from your biometric data. It will be retained only for the time necessary to complete the identity verification process, and for no longer than 1 year, unless required by law to retain it longer.
Login Monitoring: We track how you log in and interact with our website or app to validate your identity and detect fraudulent or suspicious activity related to your account.
Financial Verification: If you consent to link your bank account for regulatory verification, we may process sensitive financial data as part of verifying your financial documents.
Your jurisdiction may classify other information mentioned in this section as sensitive, and all sensitive data will be protected accordingly.
Use of Your Personal Data
The Company may use your personal data for several purposes, including:
To Provide and Maintain Our Service: This includes monitoring how the Service is used.
Account Management: To manage your registration and give you access to the features of the Service available to registered users.
Performance of a Contract: To fulfill the terms of a contract, such as the purchase of products or services through the Service.
Communication: To contact you via email, phone, SMS, or push notifications for updates or security-related communications.
Marketing and Offers: To provide you with news, special offers, and information on products or services similar to what you've already purchased or shown interest in, unless you opt out.
Managing Requests: To address and manage requests you make to the Company.
Targeted Advertising: To deliver tailored content and advertisements, including working with third-party vendors to help with this.
Business Transfers: To use your data in the evaluation or execution of business transactions like mergers, acquisitions, or asset transfers.
Data Analysis and Improvement: For internal purposes like analyzing usage trends and improving the Service, products, and marketing strategies.
Sharing Your Personal Data
We may share your personal data in the following circumstances:
With Service Providers: To monitor and analyze Service usage, process payments, advertise to you, and contact you.
Business Transfers: During business transactions such as mergers or acquisitions.
With Affiliates: We may share your data with subsidiaries or other entities controlled by us, and they will be required to honor this Privacy Policy.
With Business Partners: For certain products, services, or promotions that we offer jointly with business partners.
With Other Users: Information you share in public areas of the Service may be visible to all users and could be publicly distributed.
With Your Consent: If you give consent, we may disclose your personal data for additional purposes.
Retention of Your Personal Data
We will only retain your personal data for as long as necessary for the purposes set out in this Privacy Policy. Your data will also be retained as long as needed to comply with legal obligations, resolve disputes, and enforce agreements. Usage data is generally kept for a shorter period, except when needed to improve the Service or required by law.
Transfer of Your Personal Data
Your personal data may be transferred to and maintained on servers outside your jurisdiction, where the data protection laws may differ. By submitting your personal data, you consent to this transfer. We will take appropriate steps to ensure your data is protected and handled securely according to this Privacy Policy.
Deleting Your Personal Data
You have the right to delete or request assistance in deleting your personal data. You can manage your personal information by signing into your account and adjusting settings. You may also contact us to request access, correction, or deletion of your data. However, some data may need to be retained for legal reasons.
Disclosure of Your Personal Data
We may disclose your personal data under the following circumstances:
Business Transactions: In case of mergers, acquisitions, or asset sales, your personal data may be transferred.
Law Enforcement: If required by law or a valid request from authorities, we may disclose your data.
Other Legal Requirements: If necessary, to comply with legal obligations, protect the company’s rights, prevent fraud, or ensure public safety.
Security of Your Personal Data
While we take commercially reasonable measures to protect your personal data, no method of online transmission or storage is entirely secure. We strive to ensure the security of your data but cannot guarantee its absolute safety.
Processing of Your Personal Data by Service Providers
Our third-party service providers may have access to your personal data. These vendors process information in accordance with their own privacy policies while performing tasks related to our Service.
Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
Snov.io
Their Privacy Policy can be viewed at https://snov.io/privacy-policy
gmass.co
Their Privacy Policy can be viewed at https://www.gmass.co/blog/gmassprivacy-information-what-data-does-our-server-store/
Payments
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
PayPal
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/ mpp/ua/privacy-full When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.
Behavioral Remarketing
The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.
These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:
- Measure and analyze traffic and browsing activity on Our Service
- Show advertisements for our products and/or services to You on thirdparty websites or apps
- Measure and analyze the performance of Our advertising campaigns
Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:
- The NAI's opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA's opt-out platform http://www.youronlinechoices.com/
- The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.
Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Bing Ads Remarketing
Bing Ads remarketing service is provided by Microsoft Inc. You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/ policies/personalized-ads
You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://privacy.microsoft.com/en-us/ PrivacyStatement
Twitter
Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405 You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
Facebook
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266 To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http:// youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
LinkedIn
Their Privacy Policy can be viewed at https://www.linkedin.com/legal/ privacy-policy
medium.com
Their Privacy Policy can be viewed at https://help.medium.com/hc/en-us/ articles/360052305234
Usage, Performance and Miscellaneous We may use third-party Service Providers to maintain and improve our Service.
Google Places
Google Places is a service that returns information about places using HTTP requests. It is operated by Google Google Places service may collect information from You and from Your Device for security purposes.
The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/ GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process your personal data under the following conditions, as permitted by the General Data Protection Regulation (GDPR):
Consent: You have provided explicit consent for the processing of your personal data for one or more specific purposes.
Performance of a Contract: The provision of personal data is necessary for fulfilling a contract with you, or for pre-contractual obligations related to it.
Legal Obligations: Processing personal data is necessary to comply with a legal obligation to which the Company is subject.
Vital Interests: Processing is necessary to protect your vital interests or those of another individual.
Public Interests: Processing personal data is related to a task carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate Interests: Processing personal data is necessary for the legitimate interests pursued by the Company, except where such interests are overridden by your rights and freedoms.
The Company will help clarify the specific legal basis for processing your personal data, especially regarding whether providing personal data is required by law, a contractual obligation, or necessary to enter into a contract.
Your Rights under the GDPR
Under the GDPR, you have the following rights regarding your personal data:
Access to Your Personal Data: You have the right to access, update, or delete the personal data we hold about you. If you cannot do this directly within your account, you can contact us for assistance. You can also request a copy of the personal data we hold about you.
Correction of Personal Data: If any information we hold about you is incomplete or inaccurate, you have the right to request its correction.
Object to Processing: You can object to the processing of your personal data, particularly where we are relying on legitimate interests as the legal basis. You also have the right to object to processing for direct marketing purposes.
Erasure of Personal Data: You may request that we delete or remove personal data when there is no valid reason for us to continue processing it.
Transfer of Personal Data: You have the right to request the transfer of your personal data to another party, or directly to you, in a structured, commonly used, and machine-readable format. This right applies to automated data that you have given consent for us to use or where the information was used to fulfill a contract.
Withdraw Your Consent: If we process your personal data based on your consent, you can withdraw that consent at any time. However, withdrawing consent may limit your access to certain features of the Service.
Exercising Your GDPR Data Protection Rights
To exercise any of your rights under the GDPR, you can contact us. We may ask for verification of your identity before processing your request. We will make every effort to respond as promptly as possible.
If you feel that we have not adequately addressed your request, you have the right to lodge a complaint with a Data Protection Authority. If you are in the European Economic Area (EEA), you can contact your local data protection authority.
Children's Privacy
Our Service is not directed at children under the age of 13, and we do not knowingly collect personal data from individuals under this age. If you are a parent or guardian and believe that your child has provided us with personal data, please contact us. If we discover that we have unintentionally collected personal data from a child without parental consent, we will take steps to delete that information.
If consent is required under your local laws for processing children's data, we will seek parental consent before collecting or using such data.
Links to Other Websites
Our Service may contain links to third-party websites not operated by us. Clicking on these links will direct you to the third-party website. We strongly advise you to review the privacy policy of each site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of third-party websites or services.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. When changes are made, we will notify you by posting the updated Privacy Policy on this page, as well as through email or a prominent notice on our Service. We will update the "Last updated" date at the top of the Privacy Policy.
Please review this Privacy Policy periodically to stay informed about any updates. Changes to this Privacy Policy take effect once they are posted on this page.
Contact
If you have any questions about this Privacy Policy, You can contact us:
By email: PayCoreCanada@proton.me