Privacy Policy

1. Collection Of Personal Data

As part of accessing and using the Site and the Services, we may ask you to provide us with certain personally identifiable information (“Personal Data”). You must ensure that all the Personal Data you provide to us is accurate and complete. You may request access to your Personal Data within our possession or under our control at any time. Where there is any change to or inaccuracies in your Personal Data, you must promptly update us or correct your Personal Data in your User Account.

2. The personal information we collect about you

· Your name;

· Your contact information such as Your email address, postal address and telephone number (or any telephone number used to call our customer services);

· Your demographic information such as age, education, gender, and interests;

· evidence of Your identity (for example passport information);

· any correspondence or complaint made to us;

· unique identifiers such as Your username, account number and password;

· Your profiles and postings on any other social media applications and services that we provide or that You make available to us;

· Your payment details and other financial data (for example, Your bank or payment method provider’s name and Your account number and sort code); and
information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), 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. We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers), where You provide us with such information. In providing this information you confirm to us that you have obtained all necessary permissions from them to the reasonable use of their information for the purposes and in the manner described in this Policy, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.

3. Sensitive personal information

Some information is classed as sensitive personal information. This includes information or an opinion about a person’s political opinions, philosophical or religious beliefs or affiliations, membership of a political, trade or professional association or trade union, sexual preferences or practices, criminal record, health or genetic information, biometric information that is used for the purpose of biometric verification or identification, or biometric templates.

4. We will only collect, hold or disclose Sensitive Information if:

· You have consented; or
· the collection is required or authorised by or under Privacy Laws or a court / tribunal order.

How we collect your personal information

· Information You give to us when You use our services. We also keep a record of any email correspondence you send us. This helps us provide you with better customer service, and to improve the experience of our customers overall. Telephone calls made to and from the Contact Centre will be recorded for quality, training and monitoring purposes.

· Your communication with us. We also keep a record of any email correspondence you send us. This helps us provide you with better customer service, and to improve the experience of our customers overall. Telephone calls made to and from the Contact Centre will be recorded for quality, training and monitoring purposes.

· Other information You give to us. This is information about You that You give us by filling in forms on our website (for example, the ‘contact us’ section) or when you communicate with us by phone, e-mail or you take part in competitions, surveys, or questionnaires about our products or services, or otherwise. It includes, for example, information You provide when You register on the website for us to contact You, when You inquire about any of our Services, and when You report a problem with our website. The information You give us may include, among other data, Your name and email address.

· Social Media. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, Linkedin and Instagram, You might give us permission to access information from those accounts or services.

· Other Sources. We may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You. This helps us to update, expand and analyse our records and provide services that may be of interest to You.

· Information we collect about You. Like most websites, we use “cookies” to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. They are small text files that websites transfer to Your computer (or phone / tablet). They improve website use and speed – for example by automatically filling Your name and address in text fields. Please see our Cookie Policy for further information.

· Log Files. In addition, with regard to each of Your visits to our site, we will automatically collect certain information (for example, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data). We may combine this automatically- collected log information with other information we collect about You.

· Social Media Widgets. Our website includes Social Media Widgets or Features, such as the Facebook Like button and Twitter button which are interactive mini-programs that run on our site to provide specific services from another company (e.g. displaying the news, opinions, music, etc). Personal information, such as Your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.

· Personal information from third parties. If we receive personal information about you that we do not request directly from you or from another party, we will decide whether we could have collected the information in accordance with this Policy and Privacy Laws. If so, we will keep the information and handle it in accordance with this Policy and applicable Privacy Laws. If we decide that we could not have collected the personal information in accordance with this Policy and applicable Privacy Laws, we will destroy or anonymise the information if it is reasonable and lawful to do so.

· Mobile App. When You download our Mobile App, in addition to the information mentioned above we collect information on the type of device You use, operating system version, and system and performance information. We may send You push notifications from time-to-time in order to update You about events or promotions that we may be running. If You no longer wish to receive these types of communications, You may turn them off at the device level. To ensure You receive proper notifications, we will need to collect certain information about Your device such as operating system and user identification information; and may use mobile analytics software to allow us to better understand the functionality of our Mobile Software on Your device. This software may record information such as how often You use the Mobile App, the events that occur within it, aggregated usage, performance data, and where the Mobile App was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the Mobile App.

5. Cookies

By accessing and using the Site and our Services, you consent to our use of cookies. For details please refer to our Cookie Policy.

6. Uses Of Personal Data

· fulfill the specific purpose for which the Personal Data was provided such as but not limited to: provide You with the Services in accordance with our terms and conditions and with this Policy, account registration; to fulfil Your Transaction
· to send You confirmations
· provide, maintain, and improve the Site and the Services;
· notify you about changes to the Site and the Services via short message service, e-mail, in-app notifications, or push notifications/pop-ups;
· provide customer care and support;
· monitor the usage of the Site and the Services;
· detect, prevent, and address technical issues;
· detect and protect users against illegal activity on the Site;
· enforce these Terms and Conditions; and
· carry out any other purposes that are related or incidental to any of the foregoing purposes customer.

7. Marketing And Promotions

We may use your Personal Data to send you marketing and promotional materials in relation to products and services offered by us by notifications such as short message service, electronic mail, in-app notifications, or push notifications/pop-ups. If you wish to unsubscribe to such notifications, you may click on the “unsubscribe” link in the relevant notification. For contracted partners/ vendors/ merchants, we may at our discretion display your name, logo, acronyms and other insignia in any material or medium for the advertisement, publicity and promotion of the Site and Services.

8. Disclosure Of Personal Data

ZooberPay works with third party companies and individuals to facilitate the provision of the Site and Services, provide the Services on our behalf, perform related services, and assist us in analyzing how the Site or Services are used (“Service Providers”).While we may disclose your Personal Data to our Service Providers, such disclosure will be limited to the extent reasonably necessary for the above purposes and will be done in compliance with the applicable privacy laws of Canada. We have also taken reasonable measures to ensure that our Service Providers do not disclose or use your Personal Data for any other purpose. ZooberPay may also disclose your Personal Data in good faith where it believes that such action is necessary to:

· comply with its legal obligations
· protect and defend the rights or property of ZooberPay or users of the Site or Services
· prevent or investigate possible wrongdoing in connection with the Site or Services
· protect the personal safety of users of the Site or Services or the public
· protect ZooberPay against legal liability

9. Transfer Of Personal Data

Your Personal Data may need to be transferred out of Canada, whether in the course of providing you with any Service or when storing your Personal Data on servers located outside Canada. In creating a User Account and accessing and using the Site or Services, you are deemed to agree to the transfer of your Personal Data outside Canada. ZooberPay has taken reasonable steps to ensure that your Personal Data is processed, held, or otherwise handled in accordance with the Personal data protection laws and your Personal Data will not be transferred to another organization or country unless there are adequate controls in place, including controls relating to the security of your Personal Data. However, if your Personal Data needs to be transferred to countries that have less stringent personal data protection laws than Canada in order to provide you with the Services, you are deemed to consent to such transfer in providing your Personal Data to us during your use of the Site or the Services.

10. Retention Of Personal Data

We will retain your Personal Data until the purpose for which that Personal Data was collected is no longer served by the retention of the Personal Data and the Personal Data does not need to be retained any longer for any legal or business purpose.

11. Security Of Personal Data

The security of your Personal Data is important to us. We take reasonable security measures to keep your Personal Data safe and to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or other similar risks. However, no method of electronic transmission or electronic storage is fully secure. You hereby acknowledge and accept that while we strive to protect your Personal Data, we cannot guarantee its absolute security.

12. Your Rights

You may contact our Data Protection Officer at Privacy@zooberpay.com to
(i) request to access or correct your Personal Data or
(ii) request information on how your Personal Data may have been used or disclosed in the past year (subject to payment to any reasonable fee we may charge). However, please note that Canadian law allows us to refuse such requests under certain circumstances

You may also withdraw your consent to our collection, use, disclosure, storage, transfer, or processing of your Personal Data at any time, upon which we will cease all such activities relating to your Personal Data and procure that our data intermediaries and agents also cease collecting, using, or disclosing your Personal Data. Please note that this may affect our ability to provide, or prevent us from providing, you with any or all of the Services.

13. Customer Feedback

If you have any questions, feedback, or complaints, you may contact ZooberPay via our customer service at ZooberPay Support. Please provide identifying information such as your name, telephone number, unique identification number, and details of the Transaction.

14. Change In Terms And Conditions

ZOOBERPAY may change the Terms and Conditions of this Agreement from time to time. The effective date will be the date the change is made unless noted otherwise.