Privacy Statement 2018

This privacy statement is effective as of 25th May 2018.

Debapay (“We” or “we” or “us”) means Debapay Limited registered in Ireland, with company number 549256 whose registered office is at Unit 1 Rockdean, Blyry Business Park, Athlone, County Westmeath, Ireland.

We are committed to protecting and respecting your privacy. We comply with the Data Protection Act 2018, the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (together “Data Protection and Privacy legislation”) and the EU General Data Protection Regulation (GDPR).

Any word defined in our Services Conditions of Use shall have the same meaning in this Privacy Statement.

This Statement (together with our Cookies Policy, our Website terms and conditions and our Services Conditions of Use and any other documents referred to in them) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to ascertain how we process your personal data (data or information).

If you do not agree with this Privacy Statement, you should not use our Website, our Site or our Services.

Our Privacy Statement comprises the following sections:
Information We Collect from You
How We Use this Information
How We Protect Your Personal Data
Third Parties and Your Data
Your Personal Data Rights
Changes to Our Privacy Statement
Contacting Us

Information We Collect from You
We collect and process the following data about you through our Website or Site (as defined below):Information, including personal data that you volunteer to provide through www.Debapay.com or debapay.com (our Website) or my.debapay.com (our Site) when you decide to use our Services (as defined in our Services Conditions of Use). Personal data includes user names, user ids, and addresses and such information which we collect when you access our Services and System. We may also ask you for information when you report a problem with our Site or as provided below.If you contact us by email, we may keep a record of that correspondence.We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.Details of your visits to our Website or Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.Our website uses cookies to distinguish you from other users of our website. Cookies are pieces of information that are stored on your device or within your browser. This helps us to provide you with a good experience when you browse our Website or use our Site and allows us to improve our Website and Site. For detailed information on the cookies we use and the purposes for which we use them see our Cookies Policy Debapay.com/cookie-policy.We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We collect this information to enable us to administer our services and continually improve our Website and Site for you and to help in identifying any problem that may arise with our Website or Site.

How We Use this Information
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to ensure that content on our Website and Site is presented in the most effective manner for you and for your computer.
- to make available our Website, Site and Services and improve all of them.
- to communicate with you about the Site, the Services and about Debapay.
- to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- to carry out our obligations arising from any transactions entered into between you and us.
- to notify you about changes to our Services and this Privacy Statement to use it or pass it to others where we are legally required to do so, to protect or enforce our rights or the rights of anyone else, in detecting and preventing fraud and other crimes and for the purpose of protecting national security.
- analyse information provided by you and others to help us administer, support and improve our business.
- to contact you about a query you may have submitted to our Support Team.

We retain Personal Data for the least amount of time necessary for business purposes, for delivery of our Services and to fulfill our legal or regulatory obligations. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law, in such cases we will continue to use and disclose such Personal data in accordance with this Privacy Statement.

How We Protect Your Personal Data
All information you provide to us in using the Services including passwords is stored on our secure servers or else on secure servers used by our service provider. We will ensure that your personal data will only be accessed by authorised personnel. Any payment transactions effected by us, will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. You must not share a password with anyone.

Appropriate measures will be taken to ensure confidentiality of all information required for the provision of our Services and operation of our business. Appropriate steps will be taken to protect data stored or transmitted against:

- unauthorised or unlawful access, processing, storage or disclosure.
- accidental destruction
- unlawful destruction
- accidental loss
- accidental alteration

The information that we collect from you may be transferred to, and stored with any supplier of data processing and data hosting services to us at, a destination within the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing.
We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy statement by imposing on any such supplier obligations of security and confidentiality.

Unfortunately, the transmission of information via the internet is not secure and you acknowledge and agree that. However if you request in writing that we communicate with you using a secure means of communication, we can arrange to do this.

Once we have received your information, we will impose obligations of confidentiality and security on any service provider to us who processes the information.

Third Parties and Your Data
We may share your Personal Data or other information with third parties for the following reasons:

With the other parties to transactions when you use the Services, such as financial institutions and other merchants. The information includes:
- Personal Data necessary to facilitate the transaction as part of delivering our Services.
- Anonymous data and performance analytics to help merchants better understand the uses of our Services and to help merchants enhance Users’ experiences.

With other companies that provide services to us. We share Personal Data with contracted third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may be helping us for the purposes of providing our Services and to deliver optimum customer support. Contracted third parties are obliged to ensure that your Personal Data is securely managed at all times and will only use this data in line with our specific instruction.

We may also share your Personal Data where:
- We are obliged to do so in order to comply with any legal obligation.
- We need to enforce or apply our Website Terms and Conditions or our Services Conditions of Use or other agreements;
- To protect the rights, property, or safety of us, our customers, or others.

Your Personal Data Rights
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data so as to obtain your consent) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You can exercise the right at any time for us to cease processing your information and if such request is received after Order Confirmation, then you agree that we may be unable to complete the Order and in such event you will not be entitled to any refund.

Our Website or Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

You have the right to be given a copy of your personal data which you may have supplied to us via the Website or Site. To exercise this right, you must make your request in writing, post it and send it to our address as specified above (and include with the request, a copy of your passport, a copy utility bill which will verify your address). A request will be dealt with as soon as possible and will take not more than 30 days to process.

You also have the right to have inaccurate personal data corrected. If you discover that we hold inaccurate personal data about you, you have a right to instruct us to correct that information. Such an instruction must be in writing and will not take more than 30 days to process.

In certain circumstances you may also request that personal data which you have supplied via the Website or Site be deleted, if we do not have a legitimate reason for retaining the personal data. We are not entitled to charge for dealing with such a request and we must comply within 30 days of the receipt of such a request. To exercise this right you would generally be expected to identify some contravention of data protection law in the manner in which the Site processes the personal data concerned.

You have the right to ask us to move, transfer or copy your information so that you can use this information in a different service. We will make this information available to you in a commonly used format so that you can transfer this to another service, to the extent to which we are able to carry out this action.

In each case, you must make your request in writing, post it and send it to our address as specified above and include with the request, a copy of your passport, and a copy utility bill which will verify your address.

Changes to Our Privacy Statement
Any changes we may make to our privacy statement in the future will be posted on the Website and the Website will draw attention that the privacy statement has been changed or updated.

Contact Us
Questions, comments and requests regarding this privacy statement are welcomed and should be addressed to compliance@debapay.com

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