OVERVIEW
This privacy policy (this “Policy”) explains how Personal Information is collected, used, and disclosed by HUBPAL. This Policy applies to users (“you”) of HUBPAL’s services, websites, applications, and machines (each, a “Service”, and collectively, our “Services”).
By using our Services, to the extent permitted by applicable law, you are consenting to us gathering and processing information about you in accordance with this Policy, our Cookie Policy, and any other contract we may have with you including, without limitation, a Merchant Services Agreement. Although consent may not be required for all of the elements described in this Policy. For particular types of information or processing, we may provide you with choices or request your further consent related to what information we collect and how we may process it. If you do not agree to the terms set out in these policies, we do not give you permission to use the Services and you must cease to do so immediately.
Ⅰ. INFORMATION WE COLLECT
Personal Information. By using our Services, we may collect the following categories of personal information (“personal information”) of the person(s) who are company director(s), beneficial owner(s), or authorised person(s) of the merchant that we provide Services to:
– Name
– Date of birth
– Place of birth and nationality
– Identification documentation, such as copy of the passport, National Identity card or such other documentation as is required by local law, copies of these documents may include a photograph of your face
– Home address, email address and other contact details
We may ask for additional information such as, but not limited to, financial standing, employment details and experience to support merchant account application. We will also use our own records and information from other sources where applicable.
We process your Personal Information to meet our legal, statutory and contractual obligations and to provide you with our Services. We will never collect any unnecessary Personal Information from you and do not process your information in any way, other than as specified in this Policy.
Under certain circumstances, it may be necessary for you to provide us with your Personal Information, for example, to enable us to provide Services to you or to comply with our legal obligations. In other circumstances, it will be at your discretion whether you provide us with Personal Information or not. However, failure to supply any of the Personal Information we request may mean that we are unable to maintain or provide Services to you.
We make every effort to maintain the accuracy and completeness of your Personal Information which we store and to ensure all of your Personal Information is up to date. However, you can assist us with this by promptly contacting us if there are any changes to your Personal Information. We shall not be responsible for any losses you suffer arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.
Ⅱ. HOW WE USE YOUR INFORMATION
We only process your Personal Information where:
- the processing is necessary to comply with our legal obligations including:
– to carry out money laundering, financial and credit checks and for fraud and crime prevention and detection purposes;
– to comply with our legal and regulatory obligations; and
– to comply with court orders and exercise and/or defend our legal rights, as otherwise permitted or required by any applicable law or regulation; or
- the processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into such contract; or
- the processing is necessary for our legitimate interests or the legitimate interests of others (except where such interests are overridden by the interests or rights of your employees, agents and contractors and those of your associated entities requiring the protection of their Personal Information) including:
– for monitoring and assessing compliance with HUBPAL’s policies and standards;
– for promotional and marketing materials and activities;
– to comply with court orders and exercise and/or defend our legal rights, as otherwise permitted or required by any applicable law or regulation;
– to identify person(s) authorised to act on behalf of our clients;
– for administrative purposes in relation to the security and access of our systems, offices, platforms and secure websites and applications; and
– to contact you about the Services we offer
Our Role as Data Controller and Data Processor. We generally act as the data controller of your Personal Information. HUBPAL do not and will not share, disclose or trade your Personal Information collected from above processes. Under certain payment scheme, payment companies may engage us to provide them with certain processing services related to information owned or controlled by the payment companies. We are not responsible for any payment companies’ use of information for which it is an owner or controller.
Retention. We will only retain your Personal Information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. However, if you wish to have your Personal Information removed from our databases, you can make such a request by writing to the address detailed in the Contact Us section. Subject to any legal or regulatory requirements, we will then delete this information (to the extent technically practicable).
Ⅲ. SECURITY OF YOUR INFORMATION
HUBPAL takes commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorised access, disclosure, alteration, and destruction.
When your merchant transaction is being transmitted to our Services or through our Services, it will be protected by cryptographic protocols. To be clear, HUBPAL does not itself store any Personal Information of yours or your clients’ through transactions.
We assume no liability or responsibility for disclosure of any personal information due to errors in transmission, unauthorised third-party access, or other causes beyond our control.
You play an important role in keeping your information secure. You should not share your user name, password, or other security information for your HUBPAL account with anyone. If we receive instructions using your user name and password, we will consider that you have authorised the instructions. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed in the Contact Us section, below.
Ⅳ. COOKIES
We collect information about your usage and activity on our website using certain technologies, such as cookies, and other technologies. See our Cookie Policy for more details.
Ⅴ. YOUR CHOICES
Email. If you do not want to receive marketing and promotional emails from HUBPAL, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications. If you have a HUBPAL account, you may also opt-out of marketing emails in your account settings. Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, you can choose not to opt-in. Please note that even if you opt-out of receiving marketing communications from one or all of our Services, we may need to send you service-related communications.
Text Messages. If you no longer want to receive text messages from HUBPAL, please let us know to opt-out of text messages at dpo@hubpy.com or write to us, as detailed in Contact Us section.
Cookie Choices. To exercise choices regarding cookies set through our website, as well as other types of online tracking and internet advertising, see our Cookie Policy for more details.
In addition to the above methods of exercising choice, to the extent required by applicable law, we may provide you with additional choices regarding the processing of your information, which you may exercise by contacting us as detailed in the Contact Us section, below. We will try to comply with your request as soon as reasonably practicable as required by applicable law.
Ⅵ. ACCESS, CORRECTION AND DELETION OF YOUR INFORMATION
If you wish to update, modify/correct, delete or, access your Personal Information, receive a copy of the personal data collected from you, or if you would like us to stop processing any of your Personal Information, to the extent you are entitled to do so under applicable law, you can make such a request by writing to us detailed in the Contact Us section, below. We will respond to your request within the time prescribed by applicable law. If such changes are made pursuant to your request(s) this may affect our ability to continue to provide our Services to you and under such circumstances, we reserve the right to terminate our Services to you.
In any of the situations listed above, in order for us to comply with our security obligations and to prevent unauthorised disclosure of data, we may request that you provide us with a copy of a valid means of identification and verification of the identity of the individual whose Personal Information is the subject of such a request.
Ⅶ. WHEN WE MAY DISCLOSE YOUR PERSONAL DATA
HUBPAL do not and will not share, disclose or trade your Personal Information. We will only disclose your Personal Information in the ways set out in this Policy and in the following circumstances:
– To third parties who process your Personal Information on our behalf (such as our money laundering, financial and sanction check providers);
– To regulatory bodies, or there is a legal requirement.
Ⅷ. INTERNATIONAL TRANSFERS
Information about you may be transferred to, or accessed by, entities located around the world as described in this Policy. Some of these entities may be located in countries that do not provide an equivalent level of protection as your home country. Where required, HUBPAL will ensure that we have adequate safeguards in place so that your Personal Information is treated securely and in accordance with applicable law and regulation and with our policies and standards. By using our Services, and providing us information about you, you consent to the international transfer of information about you to the above parties.
The most common reason for us disclosing information overseas is because we use service providers to perform some functions on our behalf, and some of these service providers are located outside the European Economic Area (EEA). We only disclose information to these organisations when it is necessary for the services they provide to us. For the most part, these service providers are entities related to us which perform a range of technology and operational functions for us.
Ⅸ. CHANGES TO THIS POLICY
Except to the extent limited by applicable law, we reserve the right to update this Policy to reflect changes to our information practices by prominently posting notice of the update on our Services, and as required, obtaining your consent. Any updates will become effective immediately after posting the updates to this Policy and apply to all information collected about you, or where required, upon your consent. You agree that you will review this Policy periodically. If we make any changes to this Policy, we will change the “Last Updated” date above. You are free to decide whether or not to accept a modified version of this Policy, but accepting this Policy, as modified, is required for you to continue using our Services. If you do not agree to the terms of this Policy or any modified version of this Policy, your sole recourse is to terminate your use of our Services.
If we make any changes to this Policy that materially impacts previously collected information about you, we will obtain your prior express consent.
Ⅹ. CONTACT US
If you have any questions about this Policy or information we have collected about you, please contact us by email at dpo@hubpy.com
