Your Privacy Rights
Scope and Consent
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 automatically:
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.
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 FacePay 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, 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.
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.
Using Your Mobile Device:
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.
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 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 as described in our User Agreement. Where applicable and permitted by law, you may decline to receive certain communications.
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.
When you access our website or use FacePay 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, e-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 FacePay 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 FacePay 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 FacePay Services.
Do Not Track:
Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to DNT signals. We do, however, provide you notice of the tracking by advertisers and other third parties in our Privacy and Cookies policies.
How We Protect and Store Personal Information
We store and process your personal information on our computers. 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.
How We Share Personal Information with 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, account ID, contact details, 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.
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 FacePay. 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 FacePay customer and that FacePay 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 FacePay customer with a third party, we will do so.
If you link your promotion or gift card of a FacePay merchant to your account, we may share your card number with that merchant when you pay using FacePay.
Please note that merchants, sellers, and users you buy from or contract with have their own privacy policies, and although FacePay’s user agreement does not allow the other transacting party to use this information for anything other than providing FacePay Services, FacePay 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 FacePay, or with the third parties that offer or use FacePay 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.
How We Share Personal Information with Other Third Parties
We may share your personal information we collect from you, including your name, contact details, and transactions and activities, with:
- Members of the FacePay corporate family, such as FacePay 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. These financial institutions may only use this information to market FacePay-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 FacePay close your FacePay Account due to your breach of the FacePay User Agreement).
- Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to FacePay or one of its affiliates; when we need to do so to comply with 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 to 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.
- Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional).
- Legal Compliance: to help 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.
If you open a FacePay 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 FacePay 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. FacePay is not responsible for the content or information practices of such third parties.
Using Log In with FacePay
Log In with FacePay is a tool we’ve developed to improve your Internet experience. Log In with FacePay 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 FacePay allows you to sign in to a participating website using your existing FacePay login information. When you use Log In with FacePay, you agree that FacePay can share the information listed on the Log In with FacePay consent screen or in your Log In with FacePay account settings with the participating website. Information you allow FacePay 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.
How You Can Access or Change Your Personal Information