Privacy policy

In this policy “we”, “us”, “our” or “banpay” refers to BanPAY (CA) Limited, and “you”, “your” or “yours” refers to the persons to whom this policy applies. “The Banpay Group” refers to The Banpay Group Holdings Limited and its affiliates. “Applicable regulations” refers to the Canadian Personal Data (Privacy) Ordinance, Canada’s Anti-Spam Legislation (CASL), the Personal Information Protection and Electronic Documents Act (PIPEDA), and other regulations applying to banpay. At banpay, we value the security of personal data, comply with applicable regulations, and protect all personal data stored with us.

Please read this policy thoroughly before using any of banpay’s services. By accessing or using banpay’s platform, you agree to the practices described within this policy.

1. Collection and Data Processing
   1. Information given to banpay by the Client. The Client may give banpay information by filling in forms on banpay’s website or by corresponding with banpay’s service teams by phone, e-mail or otherwise, including when registering to use our website, subscribing to services, placing orders, transacting on the website, or reporting a problem. The information received may include personal particulars, financial details, images and voice recordings, employment details, personal opinions, mobile-device information shared with consent, specimen signatures, beneficiary and ownership information, and other commercial or identification information required for anti-money laundering and anti-terrorist financing compliance.
   2. Information banpay collects about the Client. During each visit to banpay.com, we may automatically collect technical information including IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, page response times, download errors, page interaction data, and methods used to browse away from the page.
   3. Information banpay receives from other sources. banpay works closely with partners, subcontractors in technical, payment and delivery services, analytics providers, search information providers, and credit reference agencies, and may receive information about Client activity from them in compliance with applicable regulations.
2. How banpay Uses Client Information
   1. Information given to banpay, and information collected by banpay about a Client, may be used for:
      1. Executing commercial transactions, clearing, or reporting transactions; carrying out research; data planning, statistical analysis; and analytics for the development or improvement of products, services, security, service quality, and advertising strategies.
      2. Assessing and processing applications, instructions, or requests.
      3. Communicating and providing updates on changes to products, services, and facilities.
      4. Managing banpay’s infrastructure and business operations while complying with internal policies and procedures.
      5. Carrying out obligations arising from contracts entered into between the Client and banpay.
      6. Providing information about other products and services offered by banpay.
      7. Notifying the Client about changes to BASE conditions or parameters.
      8. Responding to enquiries made through banpay.com, by phone, e-mail, or otherwise.
      9. Complying with applicable legal obligations as a data controller and regulated business.
      10. Protecting the Client’s vital interests or those of another natural person.
      11. Administering the website for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
      12. Improving the website so content is presented effectively across desktop and handheld devices.
      13. Allowing the Client to participate in interactive service features when chosen.
      14. Measuring and understanding the effectiveness of advertising and delivering relevant advertising.
      15. Responding to queries or feedback.
      16. Addressing or investigating complaints, claims, or disputes.
      17. Verifying the Client’s identity for the purpose of providing products or services.
      18. Conducting screenings and due diligence checks as required by law, regulation, or directive.
      19. Complying with all applicable laws, regulations, rules, directives, orders, instructions, and requests from local or foreign authorities.
      20. Financial reporting, regulatory reporting, management reporting, risk management, audit, and recordkeeping.
      21. Enforcing obligations owed to banpay and obtaining professional advice, including legal advice.
   2. Information received from other sources may be used for the same purposes set out above.
   3. banpay may share a Client’s personal information with members of the Banpay Group and selected third parties in Canada or elsewhere, including:
      1. Business partners, suppliers, and subcontractors for the performance of services under an entered agreement.
      2. Search engine and analytics providers that assist banpay in improving and optimizing banpay.com.
      3. Compliance service companies used to meet anti-money laundering and anti-terrorist financing obligations.
      4. Data storage providers supplying physical or cloud-based storage services.
      5. Banking and payments network providers that support banpay’s payments network, including banks, PSPs, and liquidity providers.
      6. Communications providers that supply internal and external communication solutions.
      7. Prospective buyers or sellers, where required in the context of a business or asset sale, always in compliance with applicable regulations.
   4. banpay may use a Client’s personal data for marketing purposes, including special offers, promotions, or entitlements that may be of interest to the Client. Marketing messages may be sent through electronic mail, direct mail, SMS, phone calls, or other mobile messaging services in compliance with applicable regulations. A Client may request that banpay stop contact for marketing purposes at any time.
3. Where Client Personal Information Is Stored

   The data collected from the Client may be transferred to, and stored at, a destination outside Canada. It may also be processed by staff operating outside Canada who work for banpay, its subsidiaries, or vetted suppliers in connection with support services.

4. Cookies

   banpay operates under implied consent for processing cookies. Upon first visit to banpay.com, we inform users about the cookies we use and that continuing to browse the website implies consent to their use.

   1. Strictly necessary cookies: cookies required for the operation of the banpay website, including secure login functionality.
   2. Analytical and performance cookies: cookies that recognize and count visitors and usage patterns to help improve website flow.
   3. Functionality cookies: cookies used to recognize returning users and remember preferences such as language, region, and previously registered interests.

   Third parties, including providers of external services like web traffic analysis, may also use cookies over which banpay has no control. You may block cookies using your browser settings, but doing so may affect site functionality.

5. Access and Correction

   You may contact our Data Protection Officer at dpo@banpay.ca to exercise your rights, request access to personal data held by banpay, or request corrections. Subject to applicable regulations, processing fees may apply depending on the nature and complexity of the request.

6. Data Retention

   The period for which banpay retains Client data depends on statutory retention periods applicable to regulated organizations. After that period, personal data is securely deleted when no longer required for contractual, operational, or legal purposes.

7. Soft Token

   The app may pair the mobile number with the one previously registered in the Client’s account to avoid linking a soft token on an unauthorized mobile phone. The mobile device may require access to the camera and contacts. The device’s unblocking mechanism authenticates the user’s identity to enable the soft token, and the app relies on the device’s security settings rather than authenticating the user internally.

8. Third-party Websites

   Our website may contain links to other websites not maintained by banpay. This policy applies only to banpay’s website. When visiting third-party websites, please review their privacy policies.

9. Use of Location Information

   Banpay collects and uses location information to help protect customers, prevent fraud, and comply with regulatory requirements. Location may be determined through device settings, IP address, or other technical means when accessing the platform or conducting transactions.

   1. Regulatory Compliance: to meet obligations under the Bank Secrecy Act (BSA) and other applicable laws, including detection of unusual access patterns and verification that transactions are conducted from permitted jurisdictions.
   2. Fraud Prevention and Security: to identify suspicious logins or transaction activity that may indicate account compromise or unauthorized access.
   3. Service Optimization: to tailor available products and services based on region and ensure accurate processing of payments and transfers.

   You can manage or disable location permissions through your device or browser settings, although doing so may limit access to services that require location verification for security or compliance purposes.

10. Contact Us

    To contact banpay about this policy, your personal data, or to provide feedback, please reach out to us. Support Team: support@banpay.ca Data Protection Officer (DPO): dpo@banpay.ca BanPAY (CA) Ltd. 535 Yates St., Suite 311 Victoria BC, V8W 2Z6