LAST UPDATE: May___, 2023
VoPay International Inc. (“VoPay”, “we”, or “us”) respects your privacy and is committed to protecting the personal information you may provide to us while using or accessing our payment services offered in the US (“Services”).
Please review the Policy carefully. By submitting your personal information to us via the Services, by using our Services, or by voluntarily interacting with us via the Services, you consent to our collecting, using and disclosing your personal information as set out in this Policy, as revised from time to time.
Your continued use of our Services following the posting of any amendment to this Policy and, as applicable following the dissemination of a notice to inform you of those changes, shall constitute your acceptance of such amendment.
|Business Users||VoPay provides Services to entities (“Business Users”) who directly and indirectly provide us with information, including Personal Information, about their customers and clients (“End Users”) in connection with their business and activities.|
|Client Account Users||VoPay provides Services to Business Users, which can include digital wallet services provided by Business Users to their customers (“Client Account Users”).|
|End Users||When you do business with one of VoPay’s Business Users, but are not directly doing business with us, we refer to you as an “End User”|
|Representative||When you are acting on behalf of a current or prospective Business User, we refer to you as a “Representative”.|
Consent and Other Individuals
What Information We Collect
The information we may collect about you varies depending on the nature of our relationship with you and depends on whether you are a Business User, End User, or Representative. Generally, in connection with providing the Services, the personal information we collect falls into the following categories (not all of which may apply to you).
As outlined above, VoPay provides Services Business Users who directly and indirectly provide us with information about their business, Representatives, and End Users. In conjunction with providing those Services, we may collect the following information.
In conjunction with Services provided to Business Users, we process Personal Information in accordance with our agreements and lawful instructions. We may collect the following categories of personal information about End Users from our Business Users in conjunction with providing the Services.
In conjunction with Services provided to Business Users, including maintaining and supporting Client Account Users, we may collect the following information:
D. Other Interactions
General, aggregated, demographic, and non-personal information may be collected by us through our Services, but any such information will not be linked to any of your personal information. This type of anonymous, aggregated profiling and session data may include information that you have provided to us through surveys, polls, etc., and may also include aggregated anonymous information about our Services’ usage and the customer base.
We will take reasonable measures to ensure the aggregated/anonymized information cannot be associated with an individual, we will maintain and use such information only in an aggregated/anonymized form, and we will not attempt to reidentify such information except as permitted by law. We may disclose aggregated information about you, and information that does not identify any individual, without restriction.
We use the information we collect from users in connection with providing the Services to provide, maintain, analyze, and improve our products and Services, including to:
Whatever the purpose may be, we will collect and process your personal information to the extent you have provided us with your consent, or alternatively as reasonably necessary to fulfill our contracts with you, or as may be required by applicable law. We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.
A more detailed list of third-party service providers is outlined below under “Third Party Websites and Services”.
If we provide your information to third party service providers, we take reasonable measures to ensure that this Policy and its principles are complied with and these third parties provide sufficient guarantees to implement appropriate security measures. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes.
In some circumstances, we may permit our service providers to retain aggregated or statistical information that does not identify you directly.
Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate:
(a) under applicable law, including laws outside your country of residence;
(b) to comply with legal process, including outside of your country of residence;
(c) to respond to requests from public and government authorities, or to cooperate with law enforcement, including public and government authorities outside your country of residence;
(d) to enforce the terms of the agreements for our products and services;
(e) to protect our operations or those of any of our affiliates or subsidiaries;
(f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others;
(g) to allow us to pursue available remedies or limit the damages that we may sustain; and
(h) in connection with a sale or business transaction, we may transfer, disclose or sell your personal information to a third party to the extent necessary to conclude any reorganization, merger, acquisition, financing due diligence, bankruptcy, receivership, purchase or sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.
(i) to assist with an investigation or prosecution of suspected or actual illegal activity.
If we otherwise intend to disclose your personal information to a third party, in a manner not identified in this Policy, we will identify that third party and the purpose for the disclosure, and obtain your consent.
We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law. These times vary depending on the purpose for which the information was collected and the need for the information. We will destroy records containing personal information or in some cases, anonymize all personal information in the records, when we no longer need the information for the purpose for which it was collected, or for other business or legal purposes, or its retention is no longer required by law.
This Policy applies only to our products and Services. It does not extend to any websites, products, social media platforms or services provided by third parties.
There may be times where a third party may ask to collect your personal information themselves. These third parties can include advertisers and third-party service providers and payment processors. When you provide your personal information to such third parties, they will use your personal information in accordance with their own privacy policies and not this Policy. Therefore, you should read their privacy policies carefully before providing them with your personal information. We are not responsible for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.
The third-party service providers we use, include but are not limited to, the following:
If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.
INTERNATIONAL TRANSFER AND STORAGE
Your personal information may be transferred, processed and stored anywhere in any country where we have facilities or in which we engage third party service providers. As a result, to the extent permitted under applicable law, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your home country. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
We make reasonable efforts to ensure that your personal information is kept as accurate, complete and up to date as reasonably necessary. We will not routinely update your personal information, unless such a process is necessary. We expect you, from time to time, to supply us with updates to your personal information, when required.
In accordance with applicable law, you may have the right to make a written request to delete or review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required and/or permitted by law. You may also request corrections to your personal information. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required and/or permitted by law. To exercise these rights, please contact us by using the contact information in the “Contact Us” section below. We will process such requests in accordance with applicable laws. Please note that certain regulations and laws may require us to retain certain records for a prescribed period of time after the close of the business relationship.
We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose.
If you are a Business User’s End User or Client Account User, the Business User is the party responsible for responding to your query; and we recommend reaching out to them for assistance.
If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
Our Services are not intended for children under the age of 16. Children under the age of 16 should not use our website and should not supply us with any personal information.
If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16 without the consent of their parent or legal guardian, please contact us using the information in the “Contact Us” section below.
As part of your use of our products or Services, or other interactions with us, we may send you emails to operate or promote our services, or other products and information we believe may be of interest to you. In addition, we may contact you using other personal information that you have provided to us (such as a physical mailing address) or contact information that you have made publicly available (such as through a social networking service). We provide an opt-out function within all email communications of this nature, or alternatively we will cease to communicate with you for this purpose if you contact us and tell us not to communicate this information to you.
This Policy is current as of the “updated” date which appears at the top of this page. It may be modified or updated from time to time. When changes are made to this Policy, they will become immediately effective when published in a revised Policy posted on our website unless otherwise noted. We may also communicate the changes through our services or by other means.
By submitting your personal information to us, by accessing or using any of the products or our Services, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this Policy, you consent to our collecting, using and disclosing your personal information as set out in the revised Policy.
All comments, questions, concerns or complaints regarding your personal information or our privacy practices should be sent to our Privacy Officer as follows:
|Address:||Attention: Privacy Officer|
8 The Green, STE BDover, DE 19901 USA
|By e-mail:||[email protected]|
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