Last updated: June 2nd, 2021
CREDEQUiTY is a financial technology company that provides internet infrastructure for user KYC, identification and verification. Businesses of all sizes use our software and services to manage their businesses online. CREDEQUiTY cares about the security and privacy of the personal data that is entrusted to us.
This policy describes the Personal Data that we collect, how we use and share it, your rights and choices, and how you can contact us about our privacy practices.
We may collect and use personal data when we do business with you or when you do business with those that use our services. Some of our services may be accessed directly by you, including through our websites that reference this policy (e.g. credequity.com) (collectively “Sites”). Many of our services are provided to others in connection with their own business and activities, and you may engage with CREDEQUiTY services as part of another’s service. This policy applies to CREDEQUiTY’s own Services. Websites, products and services of third-parties and some affiliates of CREDEQUiTY are subject to their own separate privacy policies.
CREDEQUiTY obtains Personal Data about you from various sources. “You” may be a visitor to one of our Sites (“Visitor”), a user of one or more of our Services (“User” or “CREDEQUiTY User”), or a direct or indirect customer of a User (“Customer”). If you are a Customer, your agreement with the relevant CREDEQUiTY User should explain how the CREDEQUiTY User shares your Personal Data with CREDEQUiTY. If you have questions about this sharing, then you should direct those questions to the CREDEQUiTY User.
Personal Data We Collect
- Personal Data that we collect about you
Personal Data is any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. device information, IP Address). In many cases, the Personal Data that you provide directly to us through our Services will be apparent from the context in which you provide the data:
- When you register for a CREDEQUiTY account on our Site we collect your full name, email address, and account log-in credentials.
- When you fill-in our online form to contact our sales team, we ask for your name, contact information, country, and other information about your interest in our Services.
- When you authorize us to store information about you in connection with CREDEQUiTY Checkout, we collect your name and contact information and information about your stored payment methods (e.g. payment card number, CVC code and expiration date).
- When you submit your ID and/or a “Selfie” for purposes of verification.
- When you respond to CREDEQUiTY emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call CREDEQUiTY, as well as other information you may provide during the call. If you are a CREDEQUiTY User or Customer, when you contact us, we may collect additional information in order to verify your identity.
- If you are a CREDEQUiTY User, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, we may also collect financial and personal information about you, such as your date of birth and government identifiers associated with you and your organization (such as your social security number, tax number, or Employer Identification Number). You may also choose to provide bank account information.
- If you are a Customer, when you make payments to, or transact with a User through CREDEQUiTY’s Services or a CREDEQUiTY provided device, we will receive your transaction information. If you are transacting directly with CREDEQUiTY, we receive the information directly from you. If you are transacting with a User, depending on how they integrated our Services, we may receive this information directly from you, from the CREDEQUiTY User or third parties. The information that we collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and in some cases, some information about your purchases. Different payment methods may require the collection of different categories of information. The payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you at the time of check-out. We may also receive your name, email, billing or shipping address and in some cases, your transaction history to authenticate you.
In connection with fraud monitoring, prevention, detection, and compliance activities for CREDEQUiTY and its Users, we receive identity related from the following sources:
- From Customers (including through their devices (e.g. IP Addresses)) related to Customers.
- From Users about themselves and their Customers, including as collected through our Services.
- From our business partners, financial service providers, identity verification services, and publicly available sources.
This Personal Data (e.g., name, address, phone number, country) helps us to confirm identities and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by a Customer with a CREDEQUiTY User.
You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details in connection with trade shows or other events.
- Information that we collect automatically on our Sites and through marketing of our products.
- Browser and device data, such as IP Address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting.
- Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
- Online activities. We collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online services.
- We collect information when you engage with our marketing messages and when you click on links included in ads for our products. We use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues.
How We Use Personal Data
- Our Services: We rely upon a number of legal grounds to enable our use of your Personal Data. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete transactions and to provide payment-related services to our Users.
- Marketing and events-related communications: We may send you email marketing communications about CREDEQUiTY products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with applicable law, including any consent requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.
We do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site Visitors.
How We Disclose Personal Data
CREDEQUiTY does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.
We share Personal Data with other CREDEQUiTY affiliated entities in order to provide our Services and for our administration purposes.
We share Personal Data with certain of our service providers subject to contract terms that limit their use of Personal Data. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, marketing service, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf.
We share Personal Data with third party business partners in connection with our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks) when we provide our services, and the professional services firms that we partner with.
Our Users and third parties authorized by our Users
Compliance and harm prevention
We share Personal Data as we believe necessary: (i) to comply with applicable law, or rules imposed by payment method in connection with use of that payment method; (ii) to enforce our contractual rights; (iii) to protect the Services, rights, privacy, safety and property of CREDEQUiTY, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
Your Rights and Choices
You may have choices regarding our collection, use and disclosure of your Personal Data:
- Opting out of receiving electronic communications from us: If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you other messages in connection with providing our Services.
- How you can see or change your account Personal Data: If you would like to review, correct, or update Personal Data that you have previously disclosed to us, you may do so by signing in to your CREDEQUiTY account or by contacting us.
- Your data protection rights: Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you.
Your right to request could include the following;
- The right to request confirmation of whether CREDEQUiTY processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
- The right to request that CREDEQUiTY rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
- The right to request that CREDEQUiTY erase your Personal Data in certain circumstances provided by law;
- The right to request that CREDEQUiTY restrict the use of your Personal Data in certain circumstances, such as while CREDEQUiTY considers another request that you have submitted (including a request that CREDEQUiTY make an update to your Personal Data);
- The right to request that we export your Personal Data that we hold to another company, where technically feasible;
- Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or
- In some cases, you may also have the right to object to the processing of your Personal Data.
Process for exercising data protection rights: To exercise your data protection rights, we will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may have the right under applicable laws to consult with the data protection authority in your country.
For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
Security and Retention
We retain your Personal Data as long as we are providing the Services to you or our Users (as applicable). Even after we stop providing Services directly or indirectly to you, and even if you close your CREDEQUiTY account or complete a transaction with a CREDEQUiTY User, we keep your Personal Data in order to comply with our legal and regulatory obligations. We may also keep it to assist with our fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In all cases where we keep data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
International Data Transfers
We are a global business. Personal Data may be stored and processed in any country where we do business or our service providers do business. We may transfer your Personal Data to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. Officials (such as law enforcement or security authorities) in those other countries may be entitled to access your Personal Data.
Use by Minors
The Services are not directed to minors, including children under the age of 13, and we request that they not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law. We do not sell any Personal Data of Customers, Visitors or Users, including those aged between 13 to 16.
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