Global PayEx is committed to protecting the privacy of its Users whose information is collected and stored while using Global PayEx’s Platform through our Website or App.
The capitalized terms have the same meaning as ascribed in our Terms of Use or Terms of Service as applicable, unless otherwise noted here.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE, APP, AND PLATFORM, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE, APP, AND PLATFORM.
IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT [email protected] .
WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO.
WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.
Geolocation and Equipment Information. We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App, or Platform, and usage details.
Financial Information. We collect and/or store credit cards or bank information. For payment transactions, your PII is shared with others to enable the transaction. For example, when you choose to use a payment method for the transaction with Global PayEx (e.g. credit card, debit card, buy now pay later, or direct debit), that payment method will receive transaction information that includes your PII. Please review your payment method’s privacy policy to learn more.
1. At registration on our Website, App, or Platform;
2. Through mobile and desktop applications your downloads from our Website, App, or Platform, which provides dedicated non-browser based interaction between you and our Website App, or Platform;
3. From forms filled out by you;
4. From records or copies of correspondences (including email addresses) if you contact us; and
5. From search queries on our Website, App, or Platform.
We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:
1. IP addresses;
2. Information obtained through browser cookies;
3. Web beacons on emails sent by us; and
4. Other tracking technologies.
1. Provide you with information, products, or services requested from us;
2. Present our Website, App, and Platform and their contents to you;
3. Notify you about changes to our Website, App, and Platform and any products or services;
4. Allow you to participate in interactive features on our Website, App, and Platform;
5. Administer contests, promotions, and surveys or other Website, App, and Platform features;
6. Process transactions;
7.Payment reconciliation;
8.User Authentication;
9. Contact you about our products and services that may be of interest;
10. Enable the display of advertisements to our advertisers’ target audiences, although Personal Information is not shared with advertisers without your consent; Please note in case of Hong Kong User, with your prior consent only any display of third party advertisements will be enabled; and
11. Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 14, via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process invoices and send information and updates pertaining to such invoices; (iii) send additional information related to your product and/or service; and (iv) market to our mailing list or continue to send email to you after the original transaction has occurred.
Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.”
We use Cookies on our Website and App (a) keep track of advertisements, (b) compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future, and (c) allow trusted third-party services that track this information on our behalf. You can set your browser to refuse all or some browser Cookies, but it may affect your user experience. We honor Do Not Track signals and, if one is in place, we will not track, plant cookies, or use advertising.
We allow third party behavioral tracking and links to third-party web pages. Occasionally, at our discretion, we may include or offer third-party products or services on our Website, App, or Platform. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, App, or Platform and welcome any feedback at about these sites. Please contact us at [email protected] .
2. Fair Information Practice Principles. In the event of a personal data breach, we will notify you within fifteen (15) days via (i) email and/or (ii) our Platform notification system on our Website and/or App. If you are a resident of the European Union, we will notify you of such a personal data breach within 72 hours as per the GDPR requirements. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors, users and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
1. We may disclose Personal Information to our subsidiaries and affiliates.
2. We may disclose Personal Information in the event of a merger, sale of business, etc.
3. We require all other Partners, to whom we disclose your Personal Information, to enter into contracts with us to keep Personal Information confidential and use it only for the purposes for which we disclose it to such Partners.
Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Website, App, and Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform. We currently use Google Analytics to collect and process certain Website and App usage data. To learn more about Google Analytics and how to opt-out, please visit https://policies.google.com/privacy/google-partners .
We have implemented advertising features on our Website, App, and Platform including: (a) remarketing with Google AdSense; (b) Google Display Network Impression Reporting; (c) Google Demographics and Interests Reporting; and (d) Google’s DoubleClick platform integration.
We use these Cookies to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Website or App.
1. We will comply with the EU Standard Contractual Clauses with respect to the transfer of Personal Data from the EU to the US for processing. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the EU Standard Contractual Clauses, the terms and conditions in the EU Standard Contractual Clauses will govern. For the purposes of this Privacy Policy, “EU Standard Contractual Clauses” mean the standard contractual clauses for the transfer of personal data to processors established in the US. (Commission Decision 2010/87/EC).
Obligations of the data importer (processors)
The data importer agrees and warrants:
1. that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;
2. that it has instructed and throughout the duration of the personal data processing services will instruct the data importer to process the personal data transferred only on the data exporter’s behalf and in accordance with the applicable data protection law and the clauses;
3. that the data importer will provide sufficient guarantees in respect of the technical and organizational security measures;
4. that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
5. that it will ensure compliance with the security measures;
6. that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;
7. to make available to the data subjects upon request a copy of the Clauses, with a summary description of the security measures, as well as a copy of any contract for sub-processing services which has to be made in accordance with the clauses, unless the clauses or the contract contain commercial information, in which case it may remove such commercial information; and
8. that, in the event of sub-processing, the processing activity is carried out in at least the same level of protection for the personal data and the rights of the data subject as the data importer under the Clauses.
To make any of the following requests, please contact us (i) via email at [email protected] , or (ii) by writing to us at Global PayEx, 38 Tower Drive, Darien, Connecticut 06820 , USA .
1. Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.
2. Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
3. Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.
4. Erasure: You can request that we erase some or all of your Personal Information from our systems.
5. Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
6. Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
7. Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services or Platform and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services and Platform.
8. Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to locate your Data Protection Authority.
9. Response. We will respond to your inquiry within thirty (30) days of the receipt.
FOR OUR CANADIAN USERS
This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website, App, or Platform, who reside in Canada (“consumers” or “you”). We ensure with the Personal Information Protection and Electronics Document Act of 2000 (“PIPEDA”) and any terms defined in the PIPEDA have the same meaning when used in this Section.
1. Definition of Personal Information. Any information about an identifiable individual. Whatever may be the physical form or characteristics of a particular regime for “business contact information” (name, position, title, address, professional phone number, etc.)
2. Right to Access Personal Information. You can request to access your personal information we hold about you. We will first confirm whether you have requested such information, explain how we have used your information, provide a list of names with whom your information has been shared and provide a copy of your information in an accessible format and make alternative formats available if requested.
3. Right to Correction/Limited Right to Deletion. You can request us to correct or delete your information if you demonstrate that the personal information we hold on you is inaccurate. We will delete or correct your information within thirty (30) calendar days. When we delete/correct your personal information we will inform the third parties with whom we have shared your information.
4. Right to be Forgotten. Your information will be kept with us for as long as it is required for the fulfillment of the purposes of Global PayEx Platform. Unless we otherwise give you notice, we will retain your information on the Global PayEx Platform on your behalf until such times as you or we terminate your User Account.
5. Data Breach Notification. We will send a notification to you as soon as feasible regarding the information of any breach that creates a “real risk of significant harm” to you. We keep a record of every data breach and, on request, provide the Office of the Privacy Commissioner with access to the record.
6. Two Factor Authentication. You may enable two-factor authentication on your account to help ensure that only you can access your account. If you do, in addition to entering your password to log in to your account to access the Global PayEx Platform, we will send a code to your mobile number, which you will need to enter. This added security prevents anyone else from accessing your Global PayEx account unless they have access to your login information.
YOUR CALIFORNIA PRIVACY RIGHTS
Global PayEx does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to [email protected] or write us at Global PayEx, 38 Tower Drive, Darien, Connecticut 06820.
Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at [email protected] or write us at Global PayEx, 38 Tower Drive, Darien, Connecticut 06820.
COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)
The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website, App, and Platform are not meant for use by children under the age of 13. Our Website, App, and Platform do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at [email protected] .
IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, OR PLATFORM.
CAN-SPAM ACT OF 2003
The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:
1. not use false or misleading subjects or email addresses;
2. identify the email message as an advertisement in some reasonable way; include the physical address of Global PayEx, which is 38 Tower Drive, Darien, CT 06820 .;
3. monitor third-party email marketing services for compliance, if one is used;
4. honor opt-out/unsubscribe requests quickly; and
5. give an “opt-out” or “unsubscribe” option.
If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at [email protected] and we will promptly remove you from all future marketing correspondences.
MODIFICATIONS TO OUR PRIVACY POLICY
Global PayEx reserves the right, at its sole discretion, to change or modify this Privacy Policy at any time. In the event we modify this Privacy Policy, such modifications shall be binding on you only upon your acceptance of the modified Privacy Policy. We will inform you about the modifications on our Privacy Policy page via email, on our Website, App, or Platform by posting a modified version of the Privacy Policy page, or by a comparable means within a reasonable time period. Your continued use of our Website, App, or Platform shall constitute your consent to such changes.
LIST OF THIRD-PARTY SERVICE PROVIDERS
Global PayEx uses the following third-party service providers for the provision of services as detailed under the Terms of Use or Terms of Service, as applicable
Name of Third-Party Service Provider | Contact Information |
Amazon Web Services Inc. (North Virginia, US) | Website: https://aws.amazon.com/premiumsupport/knowledge-center/aws-phone-support/ Address: 410 Terry Avenue North, Seattle, WA 98109-5210 |
Stripe, Inc. | Email: [email protected] Address: 510 Townsend St, San Francisco, CA 94103 |
Google Cloud | Website: [email protected] Telephone: (855) 817-0841 |
Microsoft Azure | Website: https://support.microsoft.com/en-us/contactus/ Address: 1 Microsoft Way, Redmond, WA 98052-6399 |
PayPal | Website: https://www.paypal.com/us/smarthelp/contact-us Address: 2211 North First Street San Jose, CA 95131 |
Additionally, if you have any questions or concerns about our third-party service providers, please email us at [email protected] .
COPYRIGHT INFRINGEMENT/DMCA NOTICE
If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.
1. Your physical or electronic signature;
2. Identification of the copyrighted work(s) that you claim to have been infringed;
3. Identification of the material on our Website, App, or Platform that you claim is infringing and that you request us to remove;
4. Sufficient information to permit us to locate such material;
5. Your address, telephone number, and email address;
6. A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
7. A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.
Global PayEx’s Copyright Agent to receive DMCA Takedown Notices is Abhilash Edakadampil, at [email protected] with a carbon copy to [email protected] and at Global PayEx, Attn: DMCA Notice, 38 Tower Drive, Darien, Connecticut 06820. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by Global PayEx in connection with the written notification and allegation of copyright infringement.
CONTACT US
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
Privacy Officer
Email: [email protected]
Address: Global PayEx, 38 Tower Drive, Darien, Connecticut 06820.
PLEASE NOTE: IF YOU USE OUR WEBSITE, APP, OR PLATFORM, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF USE OR OUR TERMS OF SERVICE, AS APPLICABLE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE, APP, OR PLATFORM.
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