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Privacy Policy for Pallapay Services

Effective Date: 29 Feb, 2018

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 Pallapay 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 (collectively “Pallapay Services”).  This Privacy Policy is intended to govern the use of Pallapay Services by our users (including, without limitation those who use the Pallapay 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 as of the published effective date. In addition, if the revised version includes a substantial change, we will provide you with 30 days’ prior notice by posting notice of the change on the "Policy Updates" page of our website. After this 30-day notice period, you will be considered as having expressly consented to all amendments to this Privacy Policy.

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Collection of Personal Information

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

Information we collect automatically: When you use Pallapay 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 also collect anonymous information through our use of cookies and web beacons .

Information you provide to us: We may collect and store any information you provide us when you use Pallapay 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 Pallapay Services.

When you use Pallapay Services, we also collect information about your transactions and your activities. In addition, if you open a Pallapay account or use Pallapay 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 Pallapay account or give us when you use Pallapay Services.
  • Detailed personal information such as your date of birth or national ID number.

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 members of the Pallapay corporate family 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, Pallapay may monitor or record its telephone conversations with you or anyone acting on your behalf. By communicating with Pallapay, 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 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 Pallapay account and authorizing Pallapay to have access to this information, you agree that Pallapay 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 Pallapay Services. We may also evaluate your computer, mobile phone or other access device to identify any malicious software or activity.

Using Your Mobile Device: We may offer you the ability to connect with Pallapay 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 download or use our mobile applications, or 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.

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How We Use the Personal Information We Collect

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 PallaPay 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 PallaPay Services by customizing your user experience;
  • measure the performance of the PallaPay 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, and 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 PallaPay Services and the services of our corporate family. 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. Where applicable and permitted by law, you may decline to receive certain communications.

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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 information with information we collect from other companies and use it to improve and personalize PallaPay 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 logging into your account and going to the Notifications section and updating your preferences, or by following the directions that may be provided within the communication or advertisement.

We respect your communication preferences. If you no longer wish to receive notifications via our application, you can adjust your preferences by visiting the settings page of the application.

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How We Use Cookies and Similar Technologies

When you access our website or use PallaPay Services, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, "Flash cookies," or other local storage provided by your browser or associated applications (collectively "Cookies"). We use these technologies to recognize you as a customer; customize PallaPay Services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our sites and PallaPay Services.

You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our website and PallaPay Services.

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How We Protect and Store Personal Information

Throughout this Privacy Policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous so that it does not identify a specific user.

We store and process your personal information on our computers in North America, Asia, Europe and elsewhere in the world where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.

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How We Share Personal Information with Other PallaPay Users

When transacting with others, we may provide those parties with information about you necessary to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction. To facilitate dispute resolution, we may provide a buyer with the seller’s address so that goods can be returned to the seller.  The receiving party is not allowed to use this information for unrelated purposes, such as to directly market to you, unless you have agreed to it. Contacting users with unwanted or threatening messages is against our policies and constitutes a violation of our User Agreement.

If someone is sending you money and enters your email address or phone number, we will provide them your registered name so they can verify they are sending the money to the correct account.

We work with third parties, including merchants, to enable them to accept or send payments from or to you using PallaPay. In doing so, a third party may share information about you with us, such as your email address or mobile phone number, to inform you that a payment has been sent to you or when you attempt to pay a merchant or third party. We use this information to confirm that you are a PallaPay customer and that PallaPay as a form of payment can be enabled, or to send you notification of payment status. Also, if you request that we validate your status as a PallaPay customer with a third party, we will do so.

If you link your loyalty or gift card of a PallaPay merchant to your account, we may share your card number with that merchant when you pay using PallaPay.

Please note that merchants, sellers, and users you buy from or contract with have their own privacy policies, and although PallaPay’s User Agreement does not allow the other transacting party to use this information for anything other than providing PallaPay Services, PallaPay is not responsible for their actions, including their information protection practices.

Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you using PallaPay, or with the third parties that offer or use PallaPay Services, except with your express permission or if we are required to do so to comply with credit card rules, a subpoena, or other legal process.

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How We Share Personal Information with Other Third Parties

We may share your personal information with:

  • Members of the PallaPay corporate family, such as PallaPay Credit, to provide joint content, products, and services (such as registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, and communications. Members of our corporate family will use this information to send you marketing communications only if you have requested their services.
  • Financial institutions that we partner with to jointly create and offer a product (including but not limited to, the PallaPay Extras credit card where we share information with GE Capital to determine whether you should receive pre-approved offers for the PallaPay Extras credit card). These financial institutions may only use this information to market PallaPay-related products, unless you have given consent for other uses.
  • Credit bureaus and collection agencies to report account information, as permitted by law.
  • Banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you meet their criteria which includes having PallaPay close your PallaPay Account due to your breach of PallaPay’s User Agreement).
  • Companies that we plan to merge with or are acquired by. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice.)
  • Law enforcement,  regulators, government officials, or other third parties (in Singapore or elsewhere) in relation to a subpoena, court order, or other legal process or requirement  under Singapore law or regulation, or the laws and regulations of other jurisdictions that are applicable to PallaPay or one of its Affiliates; when we need to do so to comply with such law or credit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss; to report suspected illegal activity or investigate violations of our User Agreement 
  • Other unaffiliated third parties, for the following purposes:
    • Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.  For example, if you use the PallaPay Services to buy or sell goods, we may share account information in order to help protect your account from fraudulent activity, alert you if we detect such fraudulent activity on your accounts, or evaluate credit risk.

       
    • Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional). 
    • Shipping: in connection with shipping and related services for purchases made using PallaPay. 
    • Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.
    • Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
  • Other third parties with your consent or direction to do so.

Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in your country.

If you open a PallaPay account directly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a PallaPay website) will be shared with the owner of the third party website or application. These sites are governed by their own privacy policies and you are encouraged to review their privacy policies before providing them with personal information. PallaPay is not responsible for the content or information practices of such third parties.

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Cross Border Transfers of Personal Information

PallaPay is committed to adequately protecting your personal information regardless of where the data resides and to providing appropriate protection for your personal information where such data is transferred across borders, including outside of the EEA.

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How You Can Access or Change Your Personal Information

You can review and edit your personal information at any time by logging in to your account and reviewing your account settings and profile. You can also close your account through the PallaPay website. If you close your PallaPay account, we will mark your account in our database as "Closed," but may retain personal information from your account for a certain period of time to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce our User Agreement, or take other actions as required or permitted by law.

If you would like to limit the processing of your personal data, please feel free to contact us at the contact details as provided below. Please note however, that all information requested from you is obligatory to be provided by you unless stated otherwise. Should you fail to provide us with your personal data, we may not be able to process your request for our product and / or services.

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How You Can Contact Us about Privacy Questions

If you have questions or concerns regarding this Privacy Policy, you should contact us by telephone using the numbers contained this linkAlternatively, for data privacy and protection matters, you may also contact our Data Privacy and Protection Officer at the following link.

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Using Log In with PallaPay

Log In with PallaPay is a tool we’ve developed to improve your Internet experience. Log In with PallaPay allows you to streamline and simplify the account creation and login process when using third-party websites, and it allows these websites to enhance your experience on their sites. Instead of creating multiple usernames and passwords for each website you visit, Log In with PallaPay allows you to sign in to a participating website using your existing PallaPay login information. When you use Log In with PallaPay, you agree that PallaPay can share the information listed on the Log In with PallaPay consent screen or in your Log In with PallaPay account settings with the participating website. Information you allow PallaPay to share with these third-party websites is subject to each third-party’s terms of service and privacy agreement, so you are encouraged to review their policies.

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