1.1 Information given to banpay by the Client:

The Client may give banpay information by filling in forms on banpay’s website or by corresponding banpay’s service teams by phone, e-mail or otherwise, including information providing when registering to use our website, subscribe to services, place orders, transact on the website or report a problem with our (banpay.com) website. The information received may include: a) personal particulars (such as name, contact details, residential address, date of birth, passport/identity card) information; b) financial details (such as income, expenses); c) images and voice recordings of our communications with you; d) employment details (such as occupation, directorships and other positions held, employment history, salary, and/or benefits); e) personal opinions disclosed to us (such as feedback on our products and website); f) information obtained from a mobile device with the Client’s consent; g) specimen signatures(s); h) beneficiaries, shareholders, ultimate beneficial owners, trustees, directors; and/or i) commercial and/or identification information allowing us to comply with our obligations in terms of anti-money laundering and anti-terrorist financing.

1.2 Information banpay collects about the Client.

During each visit to (banpay.com) , we may automatically collect technical information, including but not limited to: the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products & services viewed or searched for; page response times, download errors, 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 and any phone number used to call Our customer service number.

1.3 Information banpay receive from other sources.

2.1 Information given to banpay, and information collected by banpay about a Client.

The collected information will be used to: a) develop and provide banpay’s solutions through our products and services including but not limited to:

1. Executing commercial transactions, clearing, or reporting transactions; carrying out research; data planning, statistical analysis; analytics for the development or improvement of available products, services, security, service quality, and advertising strategies. 
2. Assessing and processing applications, instructions, or requests
3. Communicating and providing the Client with updates on changes to products, services, and facilities including additions, expansion, suspension, and replacement of or to such products, services and facilities and their terms and conditions
4. Managing banpay’s infrastructure and business operations while complying with internal policies and procedures
5. Carry out obligations arising from any contracts entered between the Client and banpay to provide information on the requested products and services
6. Provide information about other products and services offered by banpay
7. Notify the Client about changes to any BASE conditions or parameters
8. Respond to any enquiry made through banpay.com website, via phone, e-mail or otherwise 
9. Comply with applicable legal obligations as a data controller and regulated business
10. Protect Client’s vital interests or that of another natural person
11. Administer the banpay.com website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
12. Improve banpay.com website to ensure that its content is presented in the most effective manner for the Client and for optimal view (computer and handheld devices) 
13. Allow the Client to participate in interactive service features when chosen to do so
14. Measure and understand the effectiveness of advertising offered, delivering relevant advertising to each Client
15. Respond to queries or feedback
16. Address or investigating any complaints, claims or disputes
17.     XVII.Verify the Client’s identity for the purposes of providing optimal products or services
18.     XVIII.Conduct screenings and due diligence checks as may be required under applicable law, regulation, or directive
19. Comply with all applicable laws, regulations, rules, directives, orders, instructions, and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities
20. Financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes
21. Enforced obligations owed to banpay; and/or seeking professional advice, including legal advice.

2.2 Information we receive from other sources.

Banpay may combine this information with information given and collected from the. Banpay may use this information for the purposes set out above.

2.3 Information banpay discloses about the Client.

Banpay may share a Client’s personal information with any member of the Banpay Group or to selected third parties, whether located in Canada or elsewhere, under full compliance with applicable regulations. The following are the types of third parties we may share some of your personal data with: 

1. Business partners – suppliers and sub-contractors for the performance of any services provided under an entered agreement
2. Analytics – search engine and analytics providers that assist banpay in the improvement and optimization of the banpay.com website 
3. Compliance – service companies used in order to meet our anti-money laundering and anti-terrorist financing obligations
4. Data storage – providers who supply physical or cloud-based storage services.
5. Banking and payments network – providers who support banpay’s payments network including banks, PSPs and liquidity providers. These providers will have their own legal obligations when processing the Client’s data. We facilitate payments to numerous jurisdictions where we may not have a direct relationship with the businesses in these jurisdictions – for example the beneficiary bank. If a Client is making a payment to a beneficiary in a certain jurisdiction, Client’s data will by default be processed by this entity.
6. Communications – providers who supply communications solutions both internally and externally. 
7. Prospective Buyers/Sellers – banpay may transfer, store, process and/or deal with your personal data outside Canada. In doing so, banpay will strictly comply with applicable regulations. Banpay will never sell your personal data without your consent.

Notwithstanding the foregoing, if any business or assets were sold, we may then disclose your personal data to the prospective buyer of such business or assets. If the Company were to be sell, the company or any substantial assets to a third party, the Client’s personal data may then be one of the transferred assets.

2.4 Use of personal data for marketing purposes

Banpay may use a Client’s your personal data to offer dedicated products or services, including special offers, promotions or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to the Client through various channels including but not limited to electronic mail, direct mailers, short message service, telephone calls, and other mobile messaging services, in compliance with applicable regulations. 

Marketing messages to a Client’s Canadian telephone number via short message service (SMS), telephone calls, facsimile, and other mobile messaging services, banpay shall only do so if under clear and unambiguous recorded consent, or if the Client has not otherwise made the appropriate registration of that number with the Do-not-call Registers. (If a Client has not indicated not to receive telemarketing messages, banpay may send telemarketing messages to that number related to the subject of our ongoing relationship via short message service, facsimile and other mobile messaging services (other than a voice or video call). A Client may at any time request that banpay stop contact for marketing purposes via selected, or all notification ways. To find out more on how to change personal data usage for marketing purposes, please contact banpay (consult through the “Contact us” section below). 

Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.