Effective Date: Janauary 01, 2025
We appreciate that you trust us with your personal information. Here we provide an overview of what personal information we collect from you and why, how we handle it, and your rights and choices.
This Privacy Policy describes how your UseePay entity as indicated below and affiliates (“UseePay,” “we,” “us”, and “our”) collects, uses, discloses, transfers, stores, retains and otherwise processes your personal information (“you”, “your”, and “customer”) when you visit our website, apply for and use your UseePay account, or otherwise interact and engage with us in relation to our customer products, features, and services, including as outlined in our Terms of Service (“agreement”) (collectively, “Services”).
Partners, retailers, online marketplaces, and suppliers that UseePay interacts with are independent of UseePay and responsible for their own privacy policies and practices. This includes, content on their websites or app, and products or services provided. Please refer to their privacy policy or reach out directly to these third parties for further information.
1. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND WHY
Personal information reasonably identifies you and is about you, directly or indirectly, as described in applicable privacy laws in countries we operate in.
We collect and process personal information about you in two ways:
(i) when we gather personal information while you are using our Services, including through cookies and similar technologies (see 4. How We Use Cookies and Similar Technologies below); and
(ii) when we collect personal information from other third party sources, such as ecommerce Merchants.
We explain in the table below what types of personal information we collect and process, how and why we do so, and the lawful bases that apply in particular as prescribed under the General Data Protection Regulation. We will collect and process your personal information with your knowledge and consent, including as set out in this Policy, except where otherwise required or permitted by law. We may collect or process personal information in other ways than as described below. We will let you know at that time, unless otherwise inappropriate or unlawful to do so.
If you fail or refuse to provide us with personal information we request from you directly, or we do not obtain your consent where we rely upon it, including to gather personal information while you are using our Services or from third party sources, we may not be able to proceed with entering into or fulfilling some of our Services. Consequently, we will not be able to provide or continue to provide those Services to you.
| Purpose of processing | Categories of personal information we collect and how | Why we collect and process personal information, and lawful bases where applicable |
| To provide (and assess whether to provide) our UseePay Services, including to process transactions. We will also provide transaction support and communications as necessary about our Services. | From you – Contact information, such as your phone number and email address. From your use of our Services – Orders and payments attempted or made and history, including refunds. From other sources – Transaction information, such as the retailer you attempted or made a transaction with using our Services, the items you have purchased, promotions or discounts applied, and shipping details. | Legal obligation – to comply with applicable anti-money laundering and counter terrorism financing and sanctions laws. For the performance of our agreement with youFor our legitimate interest to protect our business, detect, investigate and prevent suspected or actual money laundering, fraud, and other crimes or illegal activities. |
| To provide you support, resolve disputes,, and troubleshoot problems | From you – Contact information, such as your name, address, phone number, and emailIdentity verification information requested to discuss your account with you. Information about the subject of your support request or complaint. Call recording of a conversation with you. From your use of our Services – Orders and payments attempted or made and history, including refunds. From other sources – Identity verification information requested from an agent you have authorized to discuss your account on your behalf. Information relevant to the subject of the support request or complaint from retailers or other relevant and appropriate sources. | For the performance of our agreement with you. For our legitimate interests, such as to protect our business, investigate or respond to a support request or complaint, ensuring the accuracy and completeness of the information provided, and for quality assurance and training purposes. |
| To detect, investigate and prevent suspected or actual money laundering, fraud, or other crimes or illegal activities on an ongoing basis, including in relation to credit card rules, and to protect UseePay’s legal rights and claims. | From your use of our Services – Information about your use of our Services. From other sources – Information from third parties, including from our affiliates, about you, such as identity and transaction information, where permitted and consistent with applicable law. | Legal obligation – to comply with applicable anti-money laundering and counter terrorism financing and sanctions laws. For our legitimate interests to protect our business by determining any risks in providing services to you and to detect, investigate and prevent suspected or actual money laundering, fraud, and other crimes or illegal activities. |
| To provide by the use of cookies and similar technologies on our website better functionality, to assess our performance, for advertising by us and our partners, and to provide a personalized experience. Refer also to 4. How We Use Cookies and Similar Technologies below | From your use of our Services – Technical information, such as date and time you visited a site or took an action, IP address, contact details such as your email address, your location, device or browser settings. | With your consent or where otherwise consistent with applicable law. |
| As required or permitted by applicable laws and regulations, including to satisfy our bookkeeping, taxation, auditing, and accounting requirements, and to carry out business, operational, and legal functions. | Unspecified information from you, from the use of our Services, or other sources. | As required or permitted by applicable laws and regulations. For our legitimate interests to uphold our right, protect our business, and carry out business, operational and legal functions. |
2. WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION
We share personal information described in 1. Personal Information We Collect and Why above with the following categories of service providers and other third parties.
| Categories of third parties | When and why we may share your personal information |
| Affiliates within our group of companies | We may share your personal information for the following purposes for our legitimate interests or as otherwise required or consistent with applicable law. l To provide (or assess to provide), maintain or improve our Servicesl To understand how you engage with our Services to help make them better for you and for everyonel To help us manage our relationship with you across our group of companies and for customer support issues and to enforce our agreement with youl For us and our affiliates to detect, investigate and prevent money laundering, fraud and other crimes or illegal activitiesl For marketing purposes where legally permittedl As instructed by you and choices available to youl As required or permitted by applicable law |
| Service providers and subcontractors | We share your personal information with the following service providers for our legitimate interests to provide, maintain and improve our Services. l Technology and IT infrastructure providers to store information and to provide software or programs that help us provide our Servicesl Identity verification and fraud prevention providers and credit reference agencies to help us confirm your identity and prevent fraud, to assist us in meeting our obligations under anti-money laundering / counter terrorism financing and sanctions laws, and other compliance requirements. These companies process your personal information in accordance with their own privacy policiesl Outbound phone and text messaging service providers. Our service providers may need to access and intercept messages between us and you from time to time or disclose your personal information to a government body or telecommunications network provider to comply with applicable telecommunications laws, or a court or tribunal order l Analytics providers, to understand how you engage with our Services to help make them better for you and for everyone. |
| third party suppliers | We share your personal information for the following purposes to fulfill our agreement with you and for our legitimate interests. l To provide (or assess to provide) our Servicesl For retailers to provide their goods and services to you (or the recipient of the third party goods or services)l To manage an order, including dealing with any refunds, disputes or claimsl To respond to an inquiry or complaint made by youl To help them improve the quality and standard of the services that they provide to youl Other permitted purposes outlined in our agreement with you |
| Financial institutions that we may partner with to jointly create and offer a product, including banking partners as may be required by credit card association rules for inclusion on their list of terminated merchants | We share your personal information for the following purposes with your consent, to fulfill our agreement with you, or for our legitimate interests. To provide products and services of UseePay and our partners.To maintain funding lines so that our business remains commercially viable and to provide (or assess to provide) our Services to you. |
| Online trackers, advertising partners, and external affiliate networks | We share your personal information for the following purposes with your consent or for our legitimate interests. Consistent with applicable law and choices that may be available to you, we share your personal information with advertising partners for interest-based advertising or “targeted” advertising campaigns, and with advertising partners that help analyze our site, run contests, special offers, or other events or activities, and track metrics on our behalf or in connection with our Services. Refer to 4. How We Use Cookies and Similar Technologies for more information. We share the information that you have clicked on a sponsored Retailer link from our website or app with our external affiliate network partner. We use a unique UseePay URL or “hyperlink,” and will not share any personal identifiers or information in doing so. Our external affiliate network partner may track you through that Retailer’s website, including connecting our hyperlink with you in order to calculate a potential commission to UseePay in line with their own privacy policies and practices. |
| Law enforcement agencies, government agencies, officials, or other authorities or third parties pursuant to a subpoena, court order, or other legal process, requirement, or legitimate interest | We share personal information for the following purposes for our legitimate interests, to protect our business and enforce our agreement with you, or where required or authorized by law. To detect, investigate and prevent suspected or actual fraud, money laundering, or other crimes or illegal activities, including credit card rules. To comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.) To establish, exercise or defend our legal rights, including to enforce our agreement with you. To protect ours or our customers’ rights or property, including from harm, fraud, or potentially prohibited or illegal activities, and for the security or integrity of our Services. |
| With your consent | Other third parties with your consent or direction to do so, such as to provide (or assess to provide) our Services, or to discuss your account with an authorized agent. |
| Other third parties where required by law, or our legitimate interests as permitted by law | To comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.) Other purposes as permitted by applicable laws. |
3. HOW WE SECURE YOUR PERSONAL INFORMATION
We take appropriate measures, including administrative, technical, and physical safeguards, to protect your personal information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. The internet is not a 100% secure environment, so we cannot guarantee absolute security of the transmission or storage of your information. We are a compliant-oriented company, and require our third parties to meet appropriate privacy and security standards when handling data on our behalf. Your personal information will be accessible by our employees, contractors and service providers who require access for the purposes described in this Privacy Policy.
For more information about our security practices, please visit Security Policy.
4. HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small data files stored on your browser or device. They may be sent by the operator of the site or app you are visiting, in this case UseePay (“first-party cookies”), or by third parties, such as our service providers and digital partners (“third-party cookies”). Other similar technologies may be used, such as tracking pixels or browser local storage (together “cookies”). The analytics providers that administer these services use cookies to help us analyze how you use our online services. We may disclose your site-use information (including IP address) to these analytics providers, and other service providers who use the information to help us figure out how you and others use our online services.
5. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
The retention periods for personal information we collect and process about you are determined on a case-by-case basis that depends on the following factors below.
● The nature of the personal information, and why it is collected and processed, as described in this Privacy Policy. This includes to provide our Services, to comply with legal obligations, to enforce and prevent violations of our agreement with you, and to protect us against fraudulent activity.
● To manage and enforce our agreement with you. Your use of our Services is subject to the agreement between us. So if, for example, you decide to quit, we retain personal information about you for a period of time so as to collect any debt or fees owed, resolve disputes, troubleshoot problems, assist with any investigations or complaints, and to prevent fraud or risk.
● To establish, exercise, or defend our legal claims or rights. For example, we preserve your personal information related to a legal claim or complaint, such as where we are subject to a regulatory investigation, or we need to defend ourselves in legal proceedings involving your personal information, or respond to a government authority or body in relation to a legal or regulatory complaint made by you or someone else.
● As required or otherwise permitted by applicable law. For example, retention periods may be imposed under law or regulation for a prescribed period of time and for instance, to protect our or other’s legitimate interests, such as to prevent fraud.
6. YOUR RIGHTS AND CHOICES
You can see or change personal information you gave us, ask us to delete your information, control your device location tracking settings at any time. We also respect other privacy rights and choices you make consistent with applicable law. These rights and choices available to you are based on your country of residence and which UseePay entity you are dealing with, and are subject to limitations as required or permitted by applicable law.
We may ask you to verify your identity in accordance with our standard procedures, including any authorized agent who would like to act on your behalf, or clarify your request, before taking further action on your privacy right or choice request. We endeavor to respond and address all privacy rights and choices requests within the applicable statutory time frame. We will let you know if we need more time, and why. We may not always be able to fulfill your request if we have a legitimate basis to refuse it. We will tell you why. For example, if you seek to erase your personal data in a way that would mean we are not able to comply with our obligations under law.
We will not discriminate against you, deny, charge different prices or rates for, or provide a different level or quality of goods or services if you choose to request these rights and choices. If you would like to make a privacy right or choice request, please refer to 11. How To Contact Us below.
| Right to | Description |
| Withdraw your consent | You have the right to withdraw your consent where we have relied on it to process your personal information. If you withdraw your consent, we may not be able to provide you with certain Services. It will not affect our lawful basis for processing based on consent before your withdrawal. |
| Access | You have the right to request a copy of your personal information held by us. |
| Further information | You have the right to enquire further about the personal information we hold about you and our privacy practices, including how we transfer personal information internationally and onward disclosures of personal information. |
| Correction | You have the right to ask us to correct your personal information held by us, including where you believe it is not accurate, complete, up to date, or relevant. |
| Erasure | You have the right to ask us to erase your personal information, and where personal information is made public, to inform other controllers of your personal information to erase your personal information where you have a lawful erasure right. |
| Restrict Processing | You have the right to ask us to restrict processing of your personal information. |
| Object to processing | You have the right to object to us processing your personal information where we process it based on our legitimate interests, including for direct marketing purposes and other profiling activities. You can also opt out of direct marketing at any time as described above. |
| Data Portability | You have the right to ask us to access or transfer on your behalf personal information we hold about you to a third party in a structured, commonly used and machine-readable format. |
| Make an enquiry or complaint | You have the right to make an enquiry or complaint, including to lodge a complaint with your local privacy authority. |
| Object to automated decision making | You have the right to object to solely automated decisions that we may have made about you that produce a legal or similarly significant effect, and ask for more information about the decision and have a person review it, unless we are prohibited or exempt from doing so under law. More information We use systems to make decisions about you through automated means, including behavioral profiling, without our staff being involved. We complete the following decision making by automated means, with legal or similarly significant effects on you, to enter into and perform our Services you request from us, or to comply with laws that apply to us: Verify your identity to assess your application to provide you our Services. This decision helps us make sure we’re lending responsibly, protecting you and your money from financial crime, and ensures our decisions are fair and consistent. It also helps us prevent fraud, money laundering, terrorism financing, and allows us to check against sanction lists in relevant cases. Approve or decline orders when providing you our Services. Our fraud risk and money laundering assessments are necessary to make sure we’re lending responsibly, protecting you and your money from financial crime, and ensuring our decisions are fair and consistent. It also helps us prevent fraud, money laundering, and terrorism financing. Determine your available account spending limit when providing you our Services. Our internal credit risk assessments are based on a customer’s interactions and experiences with us. This decision is necessary to ensure our decisions are fair and consistent and reward positive customer behaviors. It also reduces the risk of customers failing to meet payments by offering customers limits that they can afford to repay. These decisions rely on personal information we collect or hold about you from your applications and your interactions and experiences with us, such as transactions you have attempted to make or made with us. We may also use information about you we collect from third party credit reference and fraud prevention agencies for bullet points 1 and 2 above. Automated decisions can affect the products, services or features we may offer you. As a result of the above decisions, you may be declined access or have limited access to our Services. We perform regular checks of our automated decision models to ensure they are operating correctly. |
7. RIGHTS OF CALIFORNIA RESIDENTS
If you live in California, the following additional rights apply to you.
| Right to | Description |
| Know | You may have the right to request, up to twice in a 12-month period, to see the following information about the personal information we have collected about you: l The categories and specific pieces of personal information we have collected about you;l The categories of sources from which we collected the personal information;l The business or commercial purpose for which we collected the personal information;l The categories of third parties with whom we shared the personal information; andl The categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose. California law also gives you the right to ask if we share your personal information to third parties for their direct marketing purposes (we do not disclose your personal information for unaffiliated third parties’ direct marketing purposes). |
| Erasure | You have the right to ask us to delete the personal information we have collected from you (subject to exceptions the law provides). Please note that you may no longer be able to use our Services if you delete your personal information. |
| Correction | You have the right to correct the personal information we have collected about you (subject to exceptions the law provides). |
| Non-Discrimination | You have the right to not be discriminated against if you exercise these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise these rights. |
| Opt-Out | You have the right to opt-out of the sharing of your personal information for purposes of certain targeted advertising known as cross-context behavioral advertising. If we share your personal information to third parties for such purposes, we will provide you the right to opt out of such sharing (subject to exceptions the law provides). Although some of the information we collect and process about you may be considered sensitive personal information, we only process such information for purposes authorized by law, such as to provide services you request from us or to verify your information. Although we disclose your personal information to third parties as described above, we do not sell your personal information. |
How to Exercise Your Rights
You may submit an access, deletion, or correction request here or by emailing [email protected]. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. You may also designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.
To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
Exceptions to These Rights
California law provides for certain exceptions to the rights described above. We reserve the right to avail ourselves of these exceptions where applicable. For example, these rights do not apply to personal information collected, processed, shared, or disclosed pursuant to the Gramm-Leach-Bliley Act.
8. INTERNATIONAL DATA TRANSFERS
Personal information we collect and handle about you may be transferred to or stored in a jurisdiction outside your country of residence and where the UseePay entity you are dealing with operates. We may do so, for example without limitation, when sharing personal information with our affiliates and service providers to help us provide (or assess to provide) our Services or other third parties that we partner with. Your personal information may be transferred to or stored in the United States. We may transfer your personal information to other countries, but we will always take steps to ensure your personal information is afforded equivalent levels of protection and rights as are required under your country of residence and where the UseePay entity you are dealing with operates. For more information please reach out using the details in 11. How to Contact Us below.
Where we transfer your personal information outside the United Kingdom or European Union to countries that are not covered by an adequacy decision of the UK government or the European Commission (as applicable), we use appropriate safeguards that include Standard Contractual Clauses approved by the UK’s Information Commissioner’s Office or European Commission as appropriate, or other applicable measures, including transfers to a third party that has implemented Binding Corporate Rules, or specific situations outlined under Article 49 of the GDPR. UseePay entities are bound by an Intercompany Personal Data Transfer Agreement that contains Standard Contractual Clauses.
For further information about our policies and practices with respect to international data transfers, please refer to 11. How To Contact Us below.
9. CHILDREN’S PERSONAL INFORMATION
Our Services are not directed at children under the age of 13. We do not knowingly collect, sell or share for cross-context behavioral advertising any information from children under the age of 13. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information as consistent with applicable law.
10. CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy from time to time, as may be required. We will provide you with reasonable prior notice of any material changes in how we use your personal information, including by email if you have provided one. If you disagree with these changes, you may ask for deletion at any time. Any amendments will be published by posting a revised version of the Privacy Policy and updating the “Effective Date” above. The revised version will be effective on the “Effective Date” listed.
11. HOW TO CONTACT US
If you have any questions or concerns regarding this Privacy Policy, or would like to exercise your rights and choices, you can contact with us by email [email protected] or call us at 400-096-0868.