Privacy Policy for Facepay, Inc.

Last updated: January 15, 2020

Your Privacy Rights

This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. It applies to the Facepay Inc, referred to herein as Facepay, website and all related sites, applications, services and tools regardless of how you access or use them.

Scope and Consent

You accept this Privacy Policy when you sign up for, access, or use our products, services, content, features, technologies or functions offered on our website and all related sites, applications, and services.

This Privacy Policy is intended to govern the use of Facepay Services by our users (including, without limitation those who use the Facepay Services in the course of their trade or business), unless otherwise agreed through contract. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. If the revised version includes changes that reduce your rights or increase your responsibilities, we may provide you with notice regarding these changes via email. We reserve the right to amend this Privacy Policy at any time without notice, subject to applicable law. By using our services after any changes to this Privacy Policy become effective, you agree to abide and be bound by those changes. If you do not agree with any changes to this Privacy Policy, you may close your account.

Please note that this Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Facepay Services or that you submit to us through email, text message or other electronic message or offline.

Collection of Personal Information

We collect the following types of personal information in order to provide you with the use of Facepay Services, and to help us personalize and improve your experience.

Information We Collect From You

When you use Facepay Services, we collect information sent to us by your computer, mobile phone, or other access device. The information sent to us includes, but is not limited to, the following: data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information. We may collect anonymous information through our use of cookies and web beacons to analyze trends, administer the website, track users’ movements around the website and gather demographic information about our user base.

We also use Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics’ use of your personal data here: https://policies.google.com/privacy?hl=en

Information We Will Never Collect

We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.

Information You Provide to Us

We may collect and store any information you provide us when you use Facepay Services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, or dispute resolutions, or when you otherwise correspond with us regarding Facepay Services.

When you use Facepay Services, we also collect information about your transactions and your activities. In addition, if you open a Facepay account or use Facepay Services, we may collect the following types of information:

Contact information, such as your name, address, phone, email and other similar information.
Financial information, such as the full bank account numbers and/or credit card numbers that you link to your Facepay account or give us when you use Facepay Services.
Detailed personal information such as your date of birth or national ID number.
Business Information such as your business name, employer identification number (EIN) and business classification code.

We may also collect information from or about you from other sources, such as through your contact with us, including our customer support team, your results when you respond to a survey, your interactions with Facepay partner or other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole).

Additionally, for quality and training purposes or for its own protection, Facepay may monitor or record its telephone conversations with you or anyone acting on your behalf. By communicating with Facepay, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.

Information from Other Sources

We may also obtain information about you from third parties such as credit bureaus and identity verification services.

You may choose to provide us with access to certain personal information stored by third parties such as Amazon or social media sites (e.g., Facebook and Twitter). The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your Facepay account and authorizing Facepay to have access to this information, you agree that Facepay may collect, store and use this information in accordance with this Privacy Policy.

Authentication and Fraud Detection

In order to help protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with Facepay Services. We may also evaluate your computer, mobile phone or other access device to identify any malicious software or activity. We utilize a third party vendor called SIFT which may also determine risk and/or fraud detection from this information. Their use is required to use our product.

Using Your Mobile Device

We offer you the ability to connect with Facepay Services using a mobile device, either through a mobile application or via a mobile optimized website. The provisions of this Privacy Policy apply to all such mobile access and use of mobile devices.

When you access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device's setting's menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.

How We Use Your Personal Information

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:

provide Facepay Services and customer support;
process transactions and send notices about your transactions;
verify your identity, including during account creation and password reset processes;
resolve disputes, collect fees, and troubleshoot problems;
manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
detect, prevent or remediate violations of policies or applicable user agreements;
improve the Facepay Services by customizing your user experience;
measure the performance of the Facepay Services and improve their content and layout;
manage and protect our information technology infrastructure;
provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences;
contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging, as authorized by our User Agreement;
perform creditworthiness and solvency checks, compare information for accuracy and verify it with third parties.

We may contact you via electronic means or postal mail to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account. Additionally, we may contact you to offer coupons, discounts and promotions, and inform you about Facepay Services. Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you. When contacting you via phone, to reach you as efficiently as possible we may use, and you consent to receive, autodialed or prerecorded calls and text messages as described in our User Agreement. Where applicable and permitted by law, you may decline to receive certain communications.

In addition, we may use your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Site, you instruct us to take a specific action with respect to your personal information.

Sharing of Personal Information

We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We disclose personal information to third parties under the following circumstances:

Affiliates

We may disclose your personal information within our corporate family of companies that are related by common ownership or control for purposes consistent with this Privacy Policy.

Business Transfers

We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

Other Facepay Users

When transacting with others, we may provide those parties with information about you necessary to complete the transaction, such as your name, business name, account ID, contact details, billing address, or other information needed to promote the reliability and security of the transaction.

Compliance with Laws and Law Enforcement; Protection and Safety

We may share personal information for legal, protection, and safety purposes.
We may share information to comply with laws.
We may share information to respond to lawful requests and legal processes.
We may share information to protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

Professional Advisors and Service Providers

We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the Service on our behalf (such as customer support, hosting, email delivery and database management services), as well as lawyers, bankers, auditors, and insurers.

Other

You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities.

We may also share aggregated and/or anonymized data with others for their own uses.

How Information is Secured

We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this privacy policy. In addition, we retain personal information to comply with applicable law where required, resolve disputes, troubleshoot problems, prevent fraud, assist with any investigation, enforce our Terms of Use, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.

Marketing

We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your personal information with information we collect from other companies and use it to improve and personalize Facepay Services, content, and advertising. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference by notifying us.

We respect your communication preferences. If you no longer wish to receive notifications via our application, you can notify us.

Information Choices and Changes

Accessing, Updating, Correcting, and Deleting your Information

You may access information that you have voluntarily provided through your account on the Services, and to review, correct, or delete it by sending a request to [email protected]. You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.

Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. For more information, please see the section entitled Cookies Policy below.

Google Analytics

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

Contact Information

We welcome your comments or questions about this Policy, and you may contact us at: [email protected]

Changes to This Privacy Policy

We may change this privacy policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the Site or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Eligibility

If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site and subsequently we will delete that information.

Notice to California Residents

Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we collect from you, please see the “What We Collect” section above. We collect this information for the business and commercial purposes described in the “Use of Personal Information” section above. We share this information with the categories of third parties described in the “Sharing of Personal Information” section above. Company does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please refer to our Cookie Policy below for more information regarding the types of third-party cookies, if any, that we use.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected]. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

Our Cookies Policy

We understand that your privacy is important to you and are committed to being transparent about the technologies we use. In the spirit of transparency, this policy provides detailed information about how and when we use cookies on our Site.

Do we use Cookies?

Yes. We and our marketing partners, affiliates, and analytics or service providers use cookies, web beacons, or pixels and other technologies to ensure everyone who uses the Site has the best possible experience.

What is a Cookie?

A cookie (“Cookie”) is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used. You can find out more about each cookie by viewing our current cookie list below. We update this list periodically, so there may be additional cookies that are not yet listed. Web beacons, tags and scripts may be used in the Site or in emails to help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis.

Why we use Cookies.

We generally use Cookies for the following purposes:

To recognize new or past customers.
To store your password if you are registered on our Site.
To improve our Site and to better understand your visits on our platforms and Site.
To integrate with third party social media websites.
To serve you with interest-based or targeted advertising.
To observe your behaviors and browsing activities over time across multiple websites or other platforms.
To better understand the interests of our customers and our website visitors.

Some Cookies are necessary for certain uses of the Site, and without such Cookies, we would not be able to provide many services that you need to properly use the Site. These Cookies, for example, allow us to operate our Site so you may access it as you have requested and let us recognize that you have created an account and have logged into that account to access Site content. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure our Sites.

We also use functional Cookies and Cookies from third parties for analysis and marketing purposes. Functional Cookies enable certain parts of the site to work properly and your user preferences to remain known. Analysis Cookies, among other things, collect information on how visitors use our Site, the content and products that users view most frequently.

Cookies are either “session” Cookies which are deleted when you end your browser session, or “persistent,” which remain until their deletion by you (discussed below) or the party who served the cookie.

How to Disable Cookies

You can generally activate or later deactivate the use of cookies through functionality built into your web browser. Click on the links below to learn more about:

If you want to learn more about cookies, or how to control, disable or delete them, please visit http://www.aboutcookies.org for detailed guidance. In addition, certain third party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing.

To control flash cookies, which we may use on our Site from time to time, you can go to this link because Flash cookies cannot be controlled through your browser settings. Please note that if you decline the use of Cookies, some functions of the website may be unavailable and we will not be able to present personally tailored content and advertisements to you.

We may link the information collected by Cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein. Similarly, the third parties who serve cookies on our Site may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information. If you are located in the European Economic Area, you have certain rights that are described above under the header “Notice to EU Data Subjects”, including the right to inspect and correct or delete the data that we have about you.