This notice applies to RedPay Holdings Inc. and its group companies, which sometimes use trading names including "The-RedPay" (together "us" or "we" or "our"). RedPay Holdings Inc. is committed to protecting your privacy and will take all necessary precautions to guarantee that your personal information is treated securely and that it is collected, kept, and published following this notification.
In this notice, references to "you" refer to the individual who is accessing or applying to use the RedPay Holdings Inc. services (as defined below) on your behalf or on behalf of the corporation. This includes any single trader or principle, including the management and directors, any other financial directors and officers, partners, shareholders, and beneficial owners of a client, as well as any member of staff accessing or utilizing the RedPay Holdings Inc. services on behalf of a customer.
This notice (together with our terms of service for any specific services you may purchase or use) covers the following:
• to the portal/website features and services provided to you when you visit our portals, our payment panels or websites our clients may use on their portals/websites;
• when you are applying to use and/or use RedPay Holdings Inc. services and products (including any reward or loyalty schemes, whether points-based or otherwise ("Promotion" or "Loyalty"));
• to your use of software including terminals, desktop and mobile applications provided by Redpay Holdings Inc.; and
• to email, other electronic messages including telephone, SMS, website/portal, LiveChat, and other communications between you and RedPay Holdings Inc..
Altogether, these are referred to in this notice as "TheRedpay Services".
Please read this notice very carefully to understand our policies and practices regarding your personal information and how we will treat it. Redpay Holdings Inc. takes a "layered approach" to explain its privacy practices, as recommended by controllers. This means we try to present you with the most critical privacy information in the form of a "short form" privacy notice at first. This, on the other hand, is our comprehensive privacy notice, which contains a detailed explanation of our data protection procedures and to which the short form privacy notice will link. In addition, Contact Us details are provided at the end of the page/notice for feedback or any inquiries if you may have.
INFORMATION WE MAY COLLECT FROM YOU
Personal and non-personal information
We may or may not collect and process personal and non-personal information relating to you.
Personal information is defined as information that may be used to identify a single individual, either directly or indirectly uniquely.
RedPay Holdings Inc. also collects non-personal information or may anonymity personal information to make it non-personal. Non-personal information which is also known as (NPI) is the information that cannot be used to define a particular individual, either knowingly or unknowingly. RedPay Holdings Inc. may collect, create, store, use, and disclose such non-personal information for any reasonable business purpose. For example, RedPay Holdings Inc. may utilize aggregated transnational information for commercial reasons such as trend research and data analytics to get insights and leanings about payment transaction trends and use.
We shall manage Internet Protocol (IP) addresses (or similar identifiers) as personal information to the extent that such identifiers are clearly defined as such under any local legislation and where such local law is relevant to RedPay Holdings Inc. Services.
Collecting your information
We may or may not collect the following information through the following means:
We can receive and store any personal information (including personal and financial information) that you provide to us, such as when you (or your business) enquire about or apply for TheRedpay Services; register to use and/or use any TheRedpay Services; upload and/or store information with us using the TheRedpay Services; and when you communicate with us via email, SMS, a website or the telephone, or other electronic means. This information might be about you or your clients, and it could include:
• First and last name, date of birth, email address, billing address, username, password, and/or picture, address, nationality, and country of residency;
• Card main account number, card expiration date, CVC (card security code) information, and bank and/or issuer information;
• When you or any of your customers are transacting for plane tickets or other travel-related services, information about the products purchased, including the location of the transaction, the value, the time, and any comments offered about the purchase, including travel-related personal information;
• Any loyalty scheme's points or prizes earned or redeemed;
• Photos and videos recorded at Redpay Holdings Inc. events that you have registered for, for distribution to event attendees and use in promotional materials for future events; and
• Any other information you or your customer give.
Information we collect; about you automatically: Redpay Holdings Inc. receives and stores certain information automatically whenever you interact with Redpay Holdings Inc.; for example, by way of "cookies" or the same technology. We also obtain some information when your web browser accesses TheRedpay Services or advertisements and other content provided by or on behalf of Redpay Holdings Inc. on other websites or when clicking on emails. Collecting this information enables us to know better about the visitors and customers who use and interact with Redpay Holdings Inc., where they come from, and how they use our services. In addition, we use this information for our analytics purposes and improve our services' quality and relevance for our visitors and customers. This information includes:
• Technical information, such as the Internet Protocol address that your computer or device uses to access the Internet, your login information, browser version and type, time zone setting, browser plug-in types and versions, and operating system platform.
• Information about your visits, including the full clickstream of Uniform Resource Locators (URLs) to, through and from our site (including the day, date and time); the products or services you have viewed or searched for; download errors, page response time, duration of visits to certain pages, information about the communication of the page (such as scrolling, clicking, and hovering) and the methods used to exit the page from the site, as well as any phone number used to call our customer service department.
Information acquired through our apps; if you download or use Redpay Holdings Inc. mobile or desktop applications, we may get information about your location, device, and the service you are using (including where a payment transaction takes place). Applications on some devices can access real-time location-based data (for example, GPS). If any of your devices have real-time location data access enabled, our mobile and desktop applications may collect such information from your mobile device or computer at any time while you use our apps. Where ever required, we will always seek to notify you if we intend to collect real-time location information and, also, where required by the law, obtain your consent. We may use such information for regulatory purposes, our due diligence checks to better understand transaction patterns and optimize your experience.
Email and Other Communications; when we communicate with each other, we may receive information about you and your use of TheRedpay Services, such as when you open messages from us and the use of electronic identifiers (also known as "device fingerprints"), such as Internet Protocol addresses or telephone numbers.
Other Sources of Information; we may acquire information about you from other sources and combine it with your account information. For example, we collaborate with and receive data from third parties such as business partners, financial institutions, merchants, technical, payment, and delivery service subcontractors, advertising networks, analytics providers, search information providers, credit reference, and fraud prevention agencies. The usage of credit reference and fraud prevention agencies is discussed in more detail below. We may also examine public comments and views posted on social networking sites (such as Facebook and Twitter) in order to better understand our consumers and the services we provide and develop.
Information about other people; if you provide us with information on other people, you must have notified them before (for example, by providing them with this privacy notice) and verify that you have the legal right to do so.
We may use and may disclose the personal information we collect for the following purposes:
• To provide you (and/or your company) with our TheRedpay Services, including to fulfill Redpay Holdings Inc.'s obligations to you or to financial or other institutions in connection with the TheRedpay Services we provide. In this context, we record and track the details of transactions you (and/or your customers) conduct in relation to the TheRedpay Services; analyze and report on your (and/or your customers') use of any of the Loyalty services; facilitate the collection or redemption of any points or other rewards currency in respect of any of the Loyalty programme; inform you about significant changes or developments to our app/website or our goods and services;
• To grow and enhance our company, including, but not limited to, optimizing our websites/portals, goods, and services. This might include utilizing the information you enter into forms but do not submit to us in ways like optimizing our website(s) and contacting you for customer service purposes related to that form. Your personal source of information may also be used to create and test new goods and services.
• To monitor and enforce our rights, terms of service, or any other contracts with you (and/or your company), including any disputed transactions, rewards, or points; to manage, investigate, and resolve complaints; or to collect a debt or in connection with your insolvency;
• In order to prevent, detect, and prosecute fraud or crime, TheRedpay participates in anti-fraud initiatives, which include assessing you (and/or your clients) and monitoring your transactions and/or locations to detect patterns requiring investigations or otherwise profiling and assessing the likelihood of fraud occurring. We can do so by leveraging third-party goods and services. Furthermore, if you provide us with incorrect or inaccurate information about yourself, or if we discover or suspect fraud or a crime, we may disclose your information to fraud prevention and law enforcement organizations, and we may elect to take legal action against you.
• To avoid or reduce the danger of information security;
• We may use your private information for marketing, market research, and similar activities whether or not you are admitted as or continue to receive TheRedpay Services. To send marketing information, to provide you with information on products and services you have requested or that we think may be of curiosity to you; to obtain your views on our goods, services, and website/s; and to obtain your views on our goods, services, and website/s. If you no longer wish to accept marketing or promotional information from Redpay Holdings Inc., you can always stop it.
• To comply with local and nationwide laws;
• To comply with inquiries from law enforcement and regulatory agencies in the public interest, to establish, exercise, or defend legal claims, or to safeguard your essential interests or those of others, such as in the fight against offence and terrorism; and
• To comply with card scheme rules.
If you submit information to be published or shown on public sections of the website/portal or sent to another website/portal users or third parties, you agree that any third parties who get access to the information may use it for any reason. You submit this material at your own risk, and you must abide by the site's terms of service.
DISCLOSURE OF YOUR INFORMATION
Except as indicated in this notice and for the purposes described in this notice, we do not release information that might be used to identify you personally to anybody.
• Within the Redpay Holdings Inc. to help us provide our services and for our internal customer relationship management, analytical and reporting purposes;
• Credit reference agencies, as mentioned above (if authorized by any Terms of Service or other arrangements). Please contact us if you may require any further information about how we utilize credit reference agencies.
• Fraud prevention organizations, such as Action Fraud, Financial Fraud Action, and the Financial Fraud Bureau;
• Third Party Service Providers, including suppliers who support us in providing TheRedpay Services, such as processing applications, fulfilling orders, processing payments, managing credit, security, sector, and fraud risk, and marketing, market research, and survey activities performed on Redpay Holdings Inc.'s behalf;
• Where we are expected or authorized to do so by law, Redpay Holdings Inc. may be required by law to pass information about you to regulatory authorities and law enforcement bodies nationwide or worldwide, or we may otherwise determine that it is appropriate to do so. Such disclosures may also include requests from governmental or public authorities, or with commercial businesses with whom you may have had dealings and who are seeking to mitigate cheat risk, or for the purposes of litigation or judicial process, national security or where we deem it in the national or public interest or otherwise legal to do so;
• Redpay Holdings Inc. may purchase or sell company units or affiliates as part of a business transfer. We may transfer client information as a corporate asset in such cases. Without limiting the above, if our company forms a joint venture with, sells to, or merges with another company, your information may be shared with our new business partners or owners. In these cases, we shall notify the receiver that your information must be treated in accordance with the standards outlined in this notice; and
• With your consent, your information may also be used for other reasons for which you have expressly granted permission.
Redpay Holdings Inc. does not sell, rent, distribute, or otherwise disclose personal information about its customers to other parties for commercial reasons, except as required for the execution of its services and as mentioned above.
For regulatory, quality assurance, security or training purposes, we may monitor or record telephone calls, emails, online chat, or other contacts with you. Furthermore, when visiting our offices, CCTV, access control systems, and/or other monitoring systems may be in use for security and health and safety management.
WHERE WE STORE YOUR PERSONAL INFORMATION
We, our service providers, and our other parties with whom we may disclose your personal information (as mentioned above) may process your personal information in countries other than the European Economic Area ("EEA") or in countries other than the country in which you reside. It may also be handled by personnel working for one of our suppliers or us who work outside the EEA or the area in which they were gathered. Such personnel may be involved in, among other things, order fulfillment, payment processing, and support services in the operation of TheRedpay Services. In addition, these countries may have data protection standards that are separate to (and, in some instances, lower than) those in which you reside.
In these cases, we will make reasonable efforts to shield your personal information in accordance with this privacy note and applicable data protection laws, including by implementing any appropriate safeguards required by law to ensure that such foreign data transfers are lawful. Redpay Holdings Inc. generally uses "Model Clauses" as approved by the European Commission when contracting with third-party data recipients outside the EEA. They are receiving data from inside the EEA in order to process personal data sent outside of the EEA. We may use the "Privacy Shield" with firms that have joined the scheme on occasion, where the receiver is situated in the United States.
HOW WE KEEP YOUR PERSONAL INFORMATION SECURE
We've put in place safeguards to protect your personal information against loss and unauthorized access, use, modification, and disclosure.
You are also accountable for the safety and security of your data. If we have provided you (or you have selected) a password or access code for specific areas of our website/portal, mobile applications, or other services, you are responsible for keeping this password and/or access code private. Your password and/or access code must not be shared with anybody. You must check that your password and access code are not being used by anybody else. Any individual who enters your user id and password will cause Redpay Holdings Inc. to act on their instructions and information, and you accept that you are completely liable for any use and activities that occur while using your account. You must quickly tell Redpay Holdings Inc. of any changes to the information you have supplied to us.
The transfer of data via the Internet is not entirely safe. We will do our best to shield your personal information, but we cannot guarantee the security of any information submitted to our site unless you communicate with us over a secure route that we have established. We will employ stringent processes and security mechanisms to try to prevent unauthorized access after we have received your information.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We calculate the length of time we keep your personal information depending on the nature and kind of information, the TheRedpay Service, and the country in which it is offered, as well as any relevant local legal or regulatory requirements. In general, if your information is no longer required, it will be destroyed, or it may be anonymized or aggregated with other information to make it non-personal.
If you use TheRedpay Services, we will keep your personal information for as long as it is required to provide you with the aids you have requested. That typically means we keep your personal information for as long as you are a client of ours and for a length of time beyond that.
When our connection with you ends, we must preserve some of your personal information for a period of time determined by the legal and regulatory requirements of the country in which you reside. For example, we will keep your information for the duration allowed by local laws to file a legitimate claim (so-called "statute of limitation") or for as long as we are compelled to do so by the courts, law enforcement agencies, or our regulators.
We can also continue to send you direct marketing, according to local regulations and if you haven't objected to it.
YOUR DATA PROTECTION RIGHTS
You have the several rights in regard to your personal information that you can exercise. You have the option of accessing, correcting, or updating your personal information. You may also ask us to erase your personal information, object to its processing, or temporarily restrict its processing in specific circumstances while exercising your other rights. You can also request that portions of your personal information be transferred to another service provider (so-called data portability).
You have the right to depart your consent to the use of your personal information at any time. By Withdrawing your consent has no effect on the lawfulness of any processing we carried out previous to your withdrawal, nor does it impact the processing of your personal information carried out in reliance on legitimate processing grounds other than consent. You can, for example, stop receiving marketing communications from us by clicking on the "unsubscribe" or "opt-out" link in the communications you have receive or by following the instructions we provide each time, however we will continue to send you some operational or service messages related to your TheRedpay Services.
Please make sure that not all of the above-mentioned rights may be available to you depending on where you use the TheRedpay Services. You can not object to us using your information where it is necessary by law or to manage a complaint, and you cannot ask us to remove your information if you wish to continue using our TheRedpay Services.
You always have the right to lodge a grievance with the data protection authorities concerning our acquisition and use of your personal information at any time. For more information, don't hesitate to get in touch with your local data protection authority. Also, you can initiate a court action to claim remuneration for damage or suffering caused by our failure to comply with data protection bill.
If you wish to learn more about your rights or exercise them, please contact us by using the data provided in the Contact Us section.
AUTOMATED DECISION MAKING
In some cases, our use of your personal information may result in automated conclusions (including profiling) that are legally binding or have a substantial impact on you.
Automated decisions mean that a choice concerning you is made automatically on the basis of a computer determination, without our human review. For example, we use computerized decisions to complete the credit assessments on you when you apply to certain TheRedpay Services or to carry out anti-fraud checks, as explained in the section "What We Use Your Personal Information For". We have implemented measures to safeguard the interests and rights of individuals whose personal information is subject to automated decision-making. In addition, if you are using the TheRedpay Services in the European Union, when we make an computerized decision about you, you have the right to challange the judgment, to express your point of view, and to want a human revision of the decision. You can also exercise this right by contacting us at the details below.
LEGAL BASIS FOR PROCESSING
Redpay Holdings Inc. will only process your personal information if we have a legal basis to do so. Such laws range from one territory to the next, and more precise information is available upon request. Redpay Holdings Inc. will often process:
• Based on your consent, for example, to send you marketing communications about products and services based on your interests and preferences;
• • Where necessary for the execution or entrance into any contract we have with you, such as to supply you with the TheRedpay Services to which you have subscribed;
• Where Redpay Holdings Inc. has a legitimate interest in processing data, subject to such processing not infringing on your own rights and freedoms in objecting to such processing, such as to keep you notified about your use of the services, enhance and develop our services, and manage and enforce any claim;
• Where Redpay Holdings Inc. is required by law to collect your personal information or otherwise need your personal information to safeguard your or another person's interests. For instance, when it is required to follow the regulations established by our authorities; or
• Exceptionally, we can share your information with a third party when necessary, for example, when law enforcement bureaus request information to investigate a crime.
If you have any concerns or require further information about the legal basis on which we collect and use your private information for any specific processing activity, please contact us using the data given in the Contact Us section below.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to modify our privacy notice at any moment. If we make important changes to how we treat your information, we will tell you via this website/portal. The date at which the privacy notice was last updated may be seen at the bottom of the page. You are responsible for checking our website/portal and this privacy notice for updates on a regular basis. We will, however, provide you with enhanced notice of any changes to this privacy notice and/or seek your permission to changes in our uses of your personal information as required by law.
LINKS TO THIRD PARTY SITES
From time to time, our site may contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow such links, kindly note that these websites have their own privacy and cookies policies. RedPay Holdings Inc. does not accept any responsibility or liability for these third-party websites.
This notice is the global in scope but is not intended to override any of the legal rights or prohibitions in any territories where such prohibitions prevail. In such event, the obligations and rights set out in this notice will apply, subject only to the amendment under any applicable local law having precedence.
All comments, requests, and queries relating to our use of your information are most welcomed. Suppose you wish to exercise any of your rights or receive the additional source of information as to the applicable RedPay Holdings Inc. to which this notice applies. In that case, you should write to the address below or through Contact Us
RedPay Holdings Inc.'s Data Protection Officer is as stated below and can be contacted via the Contact us above or at the address below:
Ruth M. Fredericksen
RedPay Holdings Inc.
315 Madison Ave, New York, NY 10017, United States.