- The kinds of Personal Information which we may collect about you and how it may be used;
- Any disclosure of personal information to third parties;
- The transfer of personal information;
- Your ability to correct, update and delete your personal information;
- The security measures we have in place to prevent the loss, misuse, or alteration of personal information under Our control; and
- Retention of personal Information.
THE PERSONAL INFORMATION WE COLLECT
PERSONAL INFORMATION COLLECTED
We collect personal information to provide you with our services. When we require certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our services when you do choose not to share certain information with us.
For example, we collect personal information that is required under the law to activate, register or open your account, add a payment method, or execute a transaction. We also collect personal information when you use or request information about our Services, subscribe to marketing communications, request support, or complete surveys. We may also collect personal information from you offline, such as when you contact customer support. We may use this information in combination with other information we collect about you as set forth in this policy.
Depending on what services we provide, we may collect the following types of information:
- Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
- Identification Information: Tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.
- Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
- Transaction Information: Information about the transactions you make on our services, such as the name of the recipient, your name, the amount, and/or timestamp.
- Employment Information: Office location, job title, and/or description of role.
- Online Identifiers: Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses.
- Usage Data: Survey responses, the information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data and other data collected via cookies and similar technologies.
HOW YOUR PERSONAL INFORMATION IS USED
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. In general, we use personal information to create, develop, operate, deliver, and improve our services, content and advertising, and for loss prevention and anti-fraud purposes. We may use this information in the following ways:
● Legal and regulatory compliance
Our core services are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, financial information, transaction information, employment information, online identifiers, and/or usage data in certain ways. For example, Awipay must identify and verify customers using our Services in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, we may use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records. The consequences of not processing your personal information for such purposes ranges from a limitation of services to the termination of your account, as we need to act prudently and perform the services in accordance with legal and regulatory requirements. The customer acknowledges and agrees that this agreement will be regarded as having been entered into in Jamaica and any breach of this agreement will be considered as having taken place within the jurisdiction of the courts of Jamaica. This agreement is governed by the laws of Jamaica and is subject to the exclusive jurisdiction of the courts of Jamaica.
● Enforcement of our terms in our agreements
AwiPay handles very sensitive information, such as your identification and financial data, so it is very important for us and our customers that we are actively monitoring, investigating, preventing and mitigating any potentially prohibited or illegal activities, enforcing our agreements with third parties, and/or violations of our posted user agreement or agreement for other services. In addition, we may need to collect fees based on your use of our services. We collect information about your account usage and closely monitor your interactions with our services. We may use any of your personal information collected on our services for these purposes. The consequences of not processing your personal information for such purposes ranges from a limitation of Services, to the termination of your account, as we need to act prudently and perform the services in accordance with legal and regulatory requirements.
● Providing Service communications
We send administrative or account-related information to you to keep you updated about our services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services.
● Providing customer service
We process your personal information when you contact us to make inquiries, resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
● Quality control
We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the services such as inaccurate transaction records or other interruptions. Our basis for such processing is based on the necessity of performing our contractual obligations with you.
● To ensure network and information security
We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our services. Without processing your personal information, we may not be able to ensure the security of our Services.
● For research and development purposes
We process your personal information to better understand the way you use and interact with Awipay’s services. In addition, we use such information to customize, measure, and improve Awipay’s services and the content and layout of our website and applications, and to develop new services.
● To engage in marketing activities
Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. We use information about your usage of our services and your contact information to provide marketing communications. You can opt-out of our marketing communications at any time.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt-out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or AwiPay services may not be available to you.
INFORMATION FROM THIRD-PARTY SOURCES
From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms.
● Public Databases, Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. Pursuant to applicable Data Protection Law, our lawful basis for processing such data is compliance with legal obligations. In some cases, we may process additional data about you to ensure our services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contract with you and others.
COLLECTION & USE OF INFORMATION COLLECTED AUTOMATICALLY
We receive and store certain types of information automatically, such as whenever you interact with the sites or use the services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.
For example, we automatically receive and record information on our server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted with our website, including pages accessed and links clicked. We may use identifiers to recognize you when you arrive at the site via an external link, such as a link appearing on a third-party site.
WHY WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES
We take care to allow your personal information to be accessed only by those who need to in order to perform their tasks and duties and to share with third parties who have a legitimate purpose for accessing it. AwiPay will never sell or rent your personal information. We will only share your information in the following circumstances:
● We share your information with third-party identity verification services in order to prevent fraud. This allows AwiPay to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.
● We may share your information with service providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.
● We share your information with financial institutions with which we partner to process payments you have authorized.
● We may share your information with companies or other entities that purchase AwiPay assets pursuant to a court-approved sale under U.S. bankruptcy law and / or where we are required to share your information pursuant to insolvency law in Jamaica or in any other jurisdiction.
● We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement or any other applicable policies.
If you establish a AwiPay account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on an Awipay website) will be shared with the owner of the third-party website or application and your information will be subject to their privacy policies.
HOW PERSONAL INFORMATION IS SHARED WITH THIRD-PARTY SITES AND SERVICES
If you use your Awipay account for the purchase or sale of goods or services, we or you may also provide the seller with your shipping address, name, and/or email to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. To facilitate dispute resolutions, we may provide a buyer with the seller’s address so that goods can be returned to the seller.
Please note that merchants you interact with may have their own privacy policies, and Awipay is not responsible for their operations, including, but not limited to, their information practices. Information collected by third parties, which may include such things as contact details or location data, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
If you authorize one or more third-party applications to access your Awipay Account, then the information you have provided to Awipay may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using Awipay services.
HOW WE PROTECT AND STORE PERSONAL INFORMATION
We understand how important your privacy is, which is why Awipay maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.
We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted by Awipay, or off-site by a payment vendor, in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to Awipay or Awipay staff.
Awipay cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third party, and to immediately notify us if you become aware of any unauthorized access to or use of your account.
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account.
+RIGHTS IN RELATION TO THE USE OF YOUR PERSONAL INFORMATION
Rights of access, correction and deletion
You have a right of access to the personal information that we hold about you under Jamaica’s data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.
AwiPay does not sell, trade, transfer or otherwise share your personal information except in the following instances:
● as required by law, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution or similar legal process;
● when we believe in good faith that disclosure is necessary to protect our rights, protect your security, investigate fraud or respond to a law enforcement request;
● with AwiPay service providers, field engineers, contractors who work on our behalf and who do not have an independent right to use the information to which they have access or that we disclose to them;
● with our business partners for AwiPay’s marketing activities, in such case no specific personally identifiable information is provided, as such information is generally aggregated;
● with our subsidiaries and affiliates such as AwiPay agents;
Third parties must in all cases agree to a strict duty to keep all personal information confidential and to use it only for the purpose for which it was obtained.
Right to object
You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact us as set out below.
RETENTION OF PERSONAL INFORMATION
We store your personal information securely throughout the life of your AwiPay account. We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information is described below.
● Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you un-subscribe. Thereafter we will add your details to our suppression list indefinitely.
● Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept indefinitely after you close your account for audit and crime prevention purposes.
● Recording of our telephone calls with you may be kept for a period of up to six years.
● Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.
CHILDREN’S PERSONAL INFORMATION
We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Awipay will require the user to close his or her account and will not allow the user to continue buying or selling digital currencies. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our services so we can take action to prevent access to our services.