We shall endeavor to comply with the General Data Protection Regulation (GDPR 2016/679) (GDPR) in relation to personal data processing rules within the European Union (EU) and European Economic Area (EEA).
In operating the Company Websites and/ or nCashPay, the Company may require you to register for an account to utilize its services. When opening an account or electing to receive email newsletters and offers from us, or when you call our customer service center, or enter our social media sites, walk-in or contact us through other distribution channels, we will collect personal information from you, such as your full name, email address, phone number, wallet address, financial and banking information, and other information that may be used to personally identify you (collectively “Personal Information”). We will only collect data from third parties with your authorization and consent, solely for the purpose of providing the Services to you through the Company Websites and nCashPay. As described below, Personal Information does not include any anonymized aggregated data that is collected for analysis and reporting purposes.
In some situations, we may need to request additional information from you in order to provide our services to you.
We use the Personal Information you provide for the specific purposes of:
You may choose to not provide us with Personal Information or any requested additional information, understanding that your ability to use the Company Websites, nCashPay and our services may be impacted if you do not provide the minimum information necessary to complete a transaction on the merchant websites, the Company Websites and nCashPay.
With your consent, we may also obtain additional Personal Information and non-Personal Information from third party providers.
When you use the Company Websites and nCashPay, we collect usage data and other information regarding your communications, transaction history and interactions with the Company Websites and nCashPay and other users using cookies (see the “Cookies” section below) or other similar technology.
The Company Websites and nCashPay are supported by a network of computers, cloud-based servers and other infrastructure and information technology including but not limited to third-party service providers. By using the Company Websites and nCashPay, you consent to your Personal Information possibly being transferred and processed to various countries that have different data protection rules and requirements than your country of residence.
However as the Company Websites and Mobile App is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us and you do so at your own risk
We collect information that your device sends whenever you visit the Company Websites and nCashPay (“Data”). This Data may include information such as your device's Internet Protocol (“IP”) address, details about how you used the Company Websites and nCashPay, the time and date of your visit, your location, the time spent on the Company Websites and nCashPay and other statistics. You may choose to not have us collect this information, understanding that it may impact your ability to use the Company Websites, nCashPay and our services.
Your Personal Information is retained as long as you are continuing to use the Company Websites, nCashPay and our services. If you decide to close your account, the Company will continue to store and share your Personal Information as described in this Policy unless you provide a written request to [email protected] to have your Personal Information deleted, understanding that the Company shall retain copies of transaction history on the Company Websites and nCahsPay for the Company’s record keeping purposes.
How we respond to Personal Information Breach Incidents
When we learn of a suspected or actual Personal Information breach, we shall perform an internal investigation and take appropriate remedial measures in a timely manner. Where there is any risk to the rights and freedoms of the User, the Company will notify the relevant supervisory authorities without undue delay and, when possible, within 72 hours from when it learns of such breach.
Audit and Accountability
From time to time, we may use the standard “cookies” feature of major browser applications that allows us to store a small piece of data on your computer about your visit to the Company Websites and nCashPay, and your use of our services. We only store Personal Information in cookies to identify you as a user and to enhance and customize the services provided to you on the Company Websites and nCashPay. Cookies also allow us to learn which areas of our Company Websites and nCashPay are useful and which areas need improvement, and cookies provide us with marketing data for analysis, for maintaining your session and saving the required details during the application, subscription, registration process and during transactions. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this functionality, your experience on the Company Websites and nCashPay may be diminished and some features may not work as intended.
We may communicate with you through multiple channels about your transactions on the Company Websites, merchant websites and nCashPay and to keep you up-to-date on promotions, offers, customer experience content and new products or services. We may also use the information you provide to send you marketing communications.
Once you provide your Personal Information, we may contact you through e-mail or text messages, if you choose to provide your mobile telephone number. We may continue to communicate with you through the channels you have selected until you request to stop receiving these communications by opting out.
Upon request, and within the limits allowed by applicable law, you have the right to have your Personal Information erased by us. We will take all necessary actions (including technical measures) to inform any third-party processors where applicable to comply with the request.
At times we may partner with a third party to create a site that may look as if you are on a Company page. These sites may be co-branded or may have the look and feel of being on the Company Websites or nCashPay. However, the information collected on these pages may not be covered under our Policy. It is your responsibility to review the privacy policies of those websites to confirm that you understand and agree with their policies.
We use reasonable security measures, including but not limited to physical, electronic, and procedural safeguards, to protect the confidentiality of Personal Information under our control and appropriately limit access to Personal Information, such as Secure Sockets Layer (“SSL”) protection technology.
The Company Websites and nCashPay will have security measures in place to prevent the loss, misuse, disclosure and alteration of the Personal Information that we obtain from you, but we make no assurances to you or to any third party about our ability to prevent any such loss or misuse arising out of any such loss, misuse, disclosure or alteration as a result of any malicious cyber-attacks against the Company, interruptions in telecommunications, utility, internet services or network provider services, disruption or malfunction of any network, acts or omissions of a third party, infiltration or disruption of services by a third party by any means, including without limitation, DDoS attacks, software viruses, Trojan horses, worms, time bombs or any other software program or technology designed to disrupt or delay services of the Company, which could impair the Company’s ability to complete your transactions.
We avoid storing data in plain text, our data security measures include data encryption. While we use the security measures described above along with others, we cannot ensure or warrant the security of any information you transmit to us by e-mail, and you do so at your own risk.
If we become aware of a security breach involving your Personal Information, we may need to notify you electronically of such breach at the email provided in the CONTACT US section of this Policy.
As our company evolves, there may be the need to update this Policy to keep pace with changes to the website, software, services, business and applicable laws. We will however, always maintain our commitment to respect your privacy. We will ensure that we will notify you with any material changes under this Policy by email (the most recent email provided by you) or post any other revisions to this Policy along with their effective date, in an easy-to-find area of the website.
This document was updated on 12/12/2018 and is effective from that date.
In accordance with the applicable regulations governing the protection of Personal Data, each request/inquiry will be resolved or closed without undue delay and at the latest within 30 days of receipt.
When contacting and posting such requests, we will invest reasonable efforts to confirm your identity and to prevent unauthorized Personal Data processing.