Last revised: October 25, 2021
For the purpose of the relevant data protection regulations, NearPay is the data controller regarding your personal data. If you have any questions about how We protect or use your data, please email Us at firstname.lastname@example.org.
1. How do we protect your personal information
1.1 We are serious about guarding the security of your personal information and use a secure server to store your personal information. All information that you provide to Us is stored on our secure servers.
1.2 Transmission of information via the internet is not completely secure. Although We will do our best to protect your personal information, we cannot guarantee the security of your information during transmission, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
1.3 We restrict access of your personal information to those employees of NearPay who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from unauthorised access.
2. Information we may collect from you
2.1. We may collect and use the following information about you:
2.1.1. Information you give us:
a) You may give Us information about you when you sign up to use Our Service, e.g. when you provide Us with your name and email address. This also includes information you provide through your continued use of our Services, enter a competition, promotion or survey, and when you report a problem with our Services. The information you give Us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), geographical location, social security number, personal description and photograph.
b) We may also need additional commercial and/or identification information from your e.g. if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.
2.1.2. Information we collect about you. With regard to your use of our Services we may automatically collect the following information:
a) details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;
b) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
c) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.
2.1.3. Information we receive from other sources. We may receive information about you if you use any of the other websites We operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. For example:
a) the banks you use in the Service will provide Us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;
b) business partners may provide Us with your name and address, as well as financial information, such as card payment information;
c) advertising networks, analytics providers and search information providers may provide Us with pseudonymised information about you, such as confirming how you found our website;
d) credit reference agencies do not provide Us with any personal information about you, but may be used to prove the information you have provided to Us.
3. Uses made of the information
We use your information in the following ways:
a) to carry out Our obligations relating to your contract with Us and to provide you with the information, products and Services, to notify you about changes to our Services;
b) to comply with any applicable legal and/or regulatory requirements;
c) in Our legitimate interests, including as part of Our efforts to keep our Services safe and secure, to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to improve our Services and to ensure that they are presented in the most effective manner, to measure or understand the effectiveness of advertising that We serve and to deliver relevant advertising to you, to allow you to participate in interactive features of Our Services, when you choose to do so, to provide you with information about other similar goods and services we offer.
4. Disclosure of your information
4.1. We may share your information with selected third parties including:
a) Our affiliates, business partners, suppliers and sub-contractors for the performance and execution of any contract We enter into with them or you;
b) advertisers and advertising networks solely to select and serve relevant adverts to you and others; and
c) analytics and search engine providers that assist Us in the improvement and optimisation of the Website.
4.2. We may disclose your personal information to third parties:
a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
b) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other applicable agreements; or to protect the rights, property, or safety of NearPay, our customers, or others. This includes exchanging
information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
c) to assist Us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
d) to prevent and detect fraud or crime;
e) in response to a subpoena, warrant, court order, or as otherwise required by law;
f) to assess financial and insurance risks;
g) to recover debt or in relation to your insolvency; and
h) to develop customer relationships, services and systems.
5. Where we store your personal data
5.1. The data that we collect from you is stored on our servers located in Switzerland. We rely on adequacy decisions and Standard Contractual Clauses, introduced and/or approved by the European Commission when transferring your data outside European Economic Area ("EEA").
6. Data Retention
6.1. Generally, we store your data as long as you remain a holder of NearPay Account. Nonetheless, we may store some of your personal and transactional data beyond the closure of your account with us to fulfill out legal obligations. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.
6.2. We will always delete data that is not longer required by a relevant law or jurisdiction in which we operate.
7. Your rights
7.1. You have the right to ask us not to contact you for marketing purposes by contacting us at email@example.com.
7.2. You have the right to correct any personal information We hold on you that is inaccurate, incorrect, or out of date.
7.3. You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which NearPay is subject to.
7.4. You have the right to transfer your personal data between data controllers, for example, to move your account details from one online platform to another.
7.5. Subject to applicable laws, you may have the right to access information We hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation.
7.6. Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
7.7. If you feel that we have not addressed your questions or concerns adequately, you may make a complaint with your local supervisory authority.