Privacy policy
We in our company respect and protect Your privacy. This Privacy notice describes our relations regarding Your personal data.
I. Introduction
Our company IMPAYA PAYMENTS LTD. is the Controller, which determines the purpose and means of processing of Your personal data.
Here are our contact information:
IMPAYA PAYMENTS Ltd.
Registration number: BC1313089
Address: 1095 McKenzie Ave., suite 300, Victoria, BC, V8P 2L5, Canada
If You have any questions regarding processing of Your personal data by us, feel free to contact our personal data protection officer via the following e-mail: dpo@impaya.com.
II. Purpose and legal basis for processing.
We shall never process Your personal data unlawfully. Thus, all Your personal data are processed on the following legal basis:
- Performance of the contract, which both You and us enter into when You chose to use our services;
- Compliance with our legal obligations including accounting rules and regulations related to combating money laundering, terrorism financing, proliferation, fraud and other financial and non-financial crimes;
- Protecting of our legitimate interests should there be any dispute regarding provision of our services to You. This includes protecting of our civil, commercial and procedural rights during related processes, disputes and litigations;
Since You visit our website and we hope that You are interested in using our services, our main and only purpose of processing of Your personal data is ensuring of provisioning our services to You.
Please, be informed, that a failure to provide Your personal data to us for the mentioned purposes makes it technically and legally impossible to provide our services to You as we shall not be able to fulfill our contractual obligations to You and our legal obligations in respect of Law and order (such as combating money laundering, terrorism financing, proliferation, fraud and other financial and non-financial crimes).
III. Processed personal data and methods of processing.
We shall process the following personal data of Yours:
- Your name / family name
- Your country of residence
- Your personal number
- Your date of birth
- Your nationality (citizenship)
- Your phone number
- Your e-mail address
- Your residence address
- Copy of Your ID document with the number, date of issuance, country of issuance and expiry date
- Dates of Your transactions
- Sums of Your transactions
- Your IP address
- Your picture and video recording of Your face
- Data on Your income (sums, source)
The following methods of processing of Your personal data will be used by us:
- Collecting
- Storing
- Transferring
- Amending
- Erasing
IV. Recipients of Your personal data.
Please, be informed, that for rendering our services in an appropriate way or for fulfillment of our legal obligations we’ll have to transfer Your personal data to the following recipients:
| Personal data recipient | Type of data transferred |
| Your payment card issuer | Name / family name |
| Sum of transaction |
| Date of transaction |
| |
| Acquiring financial institution | Your name / family name |
| Your country of residence |
| Your personal number |
| Your date of birth |
| Your nationality (citizenship) |
| Your phone number |
| Your e-mail address |
| Your residence address |
| Copy of Your ID document with the number, date of issuance, country of issuance and expiry date |
| Dates of Your transactions |
| Sums of Your transactions |
| Your IP address |
| Your picture and video recording of Your face |
| Data on Your income (sums, source) |
| |
| Recipient of Your payment: | Your name / family name |
| Dates of Your transactions |
| Sums of Your transactions |
| Purpose of payment |
| |
State authorities when prescribed by legal regulations: - Financial regulators;
- Financial investigation or intelligence services;
- Police;
- Courts
| Your name / family name |
| Your country of residence |
| Your personal number |
| Your date of birth |
| Your nationality (citizenship) |
| Your phone number |
| Your e-mail address |
| Your residence address |
| Copy of Your ID document with the number, date of issuance, country of issuance and expiry date |
| Dates of Your transactions |
| Sums of Your transactions |
| Your IP address |
| Your picture and video recording of Your face |
| Data on Your income (sums, source) |
| |
Our third party identification and verification services provider
Our third party identification and verification services provider | Name / family name |
| Country of residence |
| Date of birth |
| Residence address |
| Copy of Your ID document with the number, date of issuance, country of issuance and expiry date |
| Your IP address |
| Picture and video record of Your face |
V. Transfer to other countries.
Please be informed that Your personal data shall be transferred to other countries, but You do not have to be worried about that, as we thoroughly check all recipients of Your personal data outside Canada and we ensure, that both us and such a recipient undertake all necessary measures to keep Your personal data safe and secure.
VI. Term of storing.
Please be informed, that Your personal data are to be stored by us for at least 5 (five) years after termination of our relations. The said term is prescribed to us by regulations related to combatting money laundering / terrorism financing / proliferation / fraud and applicable accounting laws. The said regulations and laws may, from time to time, require personal data storing for a longer period and we shall have to comply with that.
VII. Your rights regarding Your personal data.
When it comes to processing of Your personal data You have the following rights.
| Your rights | What it means |
| Right of access | If you ask, we’ll provide a copy of Your personal data we process. |
| |
| Right to rectification | If You think Your personal data processed by us are incomplete or incorrect, You are entitled to rectification of such an incompleteness or incorrectness. But in this case, we shall need sufficient evidence from You to justify the requested corrections. |
| |
| Right to erasure (‘right to be forgotten’) | You can ask us to delete your personal data if: - the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- You object to processing of Your personal data and there are no overriding legitimate grounds for the processing;
- Your personal data have been processed unlawfully;
- the personal data have to be erased for compliance with a legal obligation in law to which we are the subject;
Please be informed that we are subject to strict regulations regarding combatting money laundering / terrorism financing / proliferation / fraud, thus we are obliged to keep Your personal data and transaction data and we may be forbidden from erasing any of Your personal data even if You request to do so. |
| |
| Right to portability | In case of necessity, You are entitled to request and we, subject to any legal restrictions, shall provide You with all Your personal data we process in a portable, structured, commonly used, machine-readable format. |
Any Your requests regarding Your personal data processed by us should be send to us via the e-mail: personal.data@freeply.com.
Any Your request shall be managed as quickly as possible, but not longer than in 30 (thirty) days. In case of necessity we can extend this term for another 30 (thirty) days.
VIII. Right to lodge a complaint.
If You feel Your privacy rights are infringed by our processing of Your personal data, You are entitled to lodge a complaint to a personal data authority of Your country.
If You are from the European Union here is a link where You can find contact details of Your personal data protection authority: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
If You are from Canada, here is the link to the Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca/en.
A large list of data protection authorities all around the world can be found here as well: https://en.wikipedia.org/wiki/National_data_protection_authority.
IX. Protection of Your personal data.
We understand the importance of protection of personal data. Thus, any Your personal data processed by us shall be handled with the utmost care and security.
We use a fusion of physical and technical measures to:
- keep your personal data secure and invincible;
- prevent unauthorized access to your personal data;
- prevent unauthorized actions (alteration, erasing) of Your personal data;
- make sure your personal data is not used in an improper way or disclosed to unproper recipients.
Your personal data is stored on secure computer systems with access restricted by both physical and electronic means. Unauthorized personnel have no physical admission to premises where terminals with access to Your personal data are located. All electronic devices with access to Your personal data are protected against unauthorized access with passwords.
All our employees dealing with Your personal data receive due training in data protection and security.
We have elaborated policies and procedures for dealing with personal data, all our members of staff duly follow these procedures.
Although we take all reasonable steps to ensure that Your personal data is kept invincible to unauthorized access, we cannot guarantee it is secure during transmission by You to our website as we are not responsible and we do not have a control over Your used device. We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for our website.
