x0pay Privacy Policy
This Privacy Policy outlines how we, x0pay and/or its affiliates, collect, store, use, process, and protect your Personal Information.
INTRODUCTION
This Privacy Notice explains how we, x0pay and/or its affiliates ("x0pay"), collect, store, use, process, retain, transfer, disclose, and protect your Personal Information. This Privacy Notice applies to all websites, services, and products (collectively referred to as the "Application"), unless covered by a separate privacy notice.
Please read this Privacy Notice thoroughly to ensure that you understand our data protection practices. We aim to make it easier to understand, so we have written summaries highlighting all the key points. Unless otherwise stated, all capitalized terms used in this Privacy Notice have the same meanings as given to them in the Terms and Conditions that apply between you and x0pay.
ACKNOWLEDGEMENT AND CONSENT
By accepting this Privacy Notice, you acknowledge that you have read and understood this Privacy Notice and you accept all its terms. In particular, you agree and consent to us collecting, using, sharing, disclosing, retaining, transferring, or processing your Personal Information as described in this Privacy Notice.
In situations where you provide us with Personal Information relating to other individuals (such as Personal Information related to your spouse, family members, friends, or other parties), you represent and warrant that you have obtained the consent of such individuals for, and hereby consent on their behalf to, the collection, use, disclosure, and processing of their Personal Information by us.
You may withdraw your consent for any or all collection, use, or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details provided below. You may also withdraw your consent for us to send certain communications and information to you through the "opt-out" or "unsubscribe" facility contained in our messages to you. Depending on the circumstances and the nature of the consent you withdraw, you must understand and acknowledge that after such withdrawal of consent, you may no longer be able to use the Application or services. Your withdrawal of consent may result in the termination of your account or your contractual relationship with us, with all rights and obligations remaining fully protected. Upon receiving your notice to withdraw consent for the collection, use, or disclosure of your Personal Information, we will inform you of the potential consequences of such withdrawal so that you can decide whether you still wish to withdraw consent.
COLLECTION AND USE OF PERSONAL DATA
Personal data is information that directly or indirectly relates to you, which is identified or identifiable from such information or from that and other information. In your transactions and dealings with x0pay, you may be asked to provide your personal data from time to time. x0pay and third-party service providers may share personal data with each other and use personal data consistent with this Privacy Policy. They may also combine it with other information to provide and improve x0pay' products and services.
RETENTION OF PERSONAL INFORMATION
Please note that there is still a possibility that some of your Personal Information might be retained by other parties or Users in some way (such as through screenshots). Information communicated between Users and Third Parties outside the use of the Application (such as via phone, mobile messaging, or other communication modes) may also be retained in some manner. We do not permit the retention of Personal Information in such a manner and are not responsible to you for the same. To the extent permitted by Applicable Law, we shall not be liable for the retention of your Personal Information in such manner. You agree to hold us, our officers, directors, employees, agents, suppliers, contractors, and Affiliates harmless from and against any and all claims, losses, liabilities, expenses, damages, and costs (including but not limited to legal fees and expenses on a full indemnity basis) arising directly or indirectly from unauthorized retention of your Personal Information.
SUMMARY
What information do we collect about you?
We collect Personal Information when you use our Application. We also collect device information and technical information from you, as well as any other information you may submit while using our Application. If you choose not to provide such information, we may not be able to provide the Application to you normally.
When you register, we may collect various personal data including but not limited to:
a. Email address;
b. Phone number;
c. National Identification Number (“NIK”);
d. Selfie photo;
e. Occupation;
f. Income;
g. Source of income;
h. Purpose; and
i. Bank account number.
How will we use information about you?
As a User, we use your information to manage and administer your Account with us, communicate with you, and provide various services and functions available in the Application to better deliver the services and information you need. To this end, we use your personal information to:
a. Respond to your inquiries and/or requests.
b. Manage or fulfill our obligations in relation to any Agreement between you and x0pay.
c. Anticipate and resolve issues related to the products we offer.
d. Monitor transactions you conduct with us or with other products.
e. Record all information from your computer/application and browser, including IP address, cookie information, software, and hardware attributes, and pages you request, using your information to customize ads and content displayed by x0pay, and conduct research to improve x0pay' services.
With whom do we share your information?
We share your data with Users and Service Providers (as applicable) to facilitate the provision of services to or by you, with our third-party partners and suppliers to the extent necessary for them to provide their services, such as payment processing. We use these third-party services solely to process or store your information for purposes described in this Privacy Notice. We also share your information with our Affiliates for purposes described in this Privacy Notice and with government and regulatory bodies as required by Applicable Law.
Where do we process your information?
Our servers may be located outside the Region. We may also transfer your information to our Affiliates and third-party suppliers and partners outside the Region for the purposes set out in this Privacy Notice.
How long do we retain your information?
We retain your information as long as necessary to fulfill the purposes for which the information was collected, or as required by applicable law.
How can I exercise my rights regarding my information?
You may have various rights related to your data under Applicable Law, and you can contact us to exercise your rights.
Contact us If you have any questions, concerns, or complaints, please contact us using the contact details found in the Contact Us section.
How will we notify you of changes?
We will amend this Privacy Notice from time to time and notify you of the updated version through our Application. Please check back periodically for updates or changes to this Privacy Notice.
For further explanation regarding the above, please refer to the detailed sections below.
PERSONAL INFORMATION WE COLLECT
Types of Personal Information We Collect About You "Personal Information" refers to information that identifies or can be used to identify, contact, or locate the person or device associated with the information. Personal Information includes, but is not limited to, email addresses, bank accounts, and wallet addresses. The types of Personal Information we collect depend on the circumstances of the collection and the nature of the services requested or transactions conducted.
To the extent permitted by applicable law, we may collect, use, store, and transfer different kinds of Personal Information about you, which we have categorized as follows:
a. Identity Data includes full name, identification card, date of birth, occupation, income, source of income, purpose, photo, and/or biometric data.
b. Contact Data includes billing address, delivery address, email address, and phone numbers.
c. Eligibility Data includes, in relation to Service Providers, licenses, consents, and other authorizations that permit you to operate vehicles and provide transportation or other services, and insurance policy details.
d. Transaction Data includes purchases or orders you make, interests, preferences, feedback, and survey responses, in relation to Users, types of services sought, details about pickups and/or deliveries; and in relation to Service Providers, types of services currently acceptable.
e. Financial Data includes bank account and payment card details such as the type of payment card or account used, the name of the issuer of that payment card or account, the name of the payment card or account holder, the identification number of the payment card or account, the verification code of the payment card or account, and the expiration date of the payment card or account, as applicable, financial history (including but not limited to payment card or account transaction history, payment card or account details and mapping and/or status of the payment card or account) and credit score.
f. Payment Data includes payment or transfer details made through the electronic money and/or e-wallet facilities we provide such as information relating to usage, payment, recipient details (including their account details), payment amounts, billing details, and invoice details.
g. Technical Data includes details about your use of our Application such as in-app messages, in-app search history, Internet Protocol (IP) address, information such as previously or subsequently viewed web pages, the duration of each visit/session, device internet identity (ID) or media access control address, mobile advertising ID, and other device information including information regarding the manufacturer, model, and operating system of the device you use to access the Application and crash logs.
h. Location Data includes your real-time geolocation information. We may create, use, license, or disclose Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data can be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity because we will ensure:
(i) that all identifiers have been removed so that the data, alone or in combination with other available data, cannot be associated with or identify anyone, and
(ii) that the data is then combined with similar data so that the original data forms part of a larger dataset.
If You Fail to Provide Personal Information
Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you choose not to provide that Personal Information or provide incomplete Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).
How We Collect Your Personal Information
Personal Information we collect can be provided by you directly or by third parties (e.g., when you register or use the Application, when you contact our customer service, or when you provide Personal Information to us). We may collect information in various forms and for various purposes (including purposes permitted under applicable law).
a. Information obtained from you or your mobile device directly You may provide us with your Identity, Contact, Eligibility, Profile, Financial, and Payment Data, including in situations where requested by us or where required by Applicable Law, when interacting with us directly or by corresponding with us via mail, phone, email, or otherwise. This includes Personal Information you provide when you:
1) register and create an Account with us using the Application;
2) use the Application, including if you register as a Service Provider or use services as a User;
3) use the electronic money and/or e-wallet facilities we provide (whether as a payer or recipient);
4) register as a registered or verified account holder on an electronic money facility;
5) add a funding source for payments within the Application; vi. use the chat feature within the Application; and vii. provide feedback or contact us.
b. Information collected each time you use the Application
You may provide us with Technical and Location Data each time you use and/or visit the Application. Whenever you access the Application through your Mobile Device, we will track and collect your real-time geographic location information. In some cases, you will be asked or required to enable the Global Positioning System ("GPS") on your Mobile Device to enable us to provide a better experience in using the Application (for example, to provide information on how close a Service Provider is to you). You can always choose to temporarily disable geolocation tracking on your Mobile Device. However, this may affect the functions available on the Application. If you use and/or when payments or transfers are made through the electronic money and/or e-wallet facilities we provide (whether as a payer or recipient), we may collect certain Financial, Profile, and Payment Data relating to those payments and transfers.
c. Information collected from third parties
We may also collect your Personal Information from third parties (including agents, vendors, suppliers, contractors, partners, and other parties providing services to us, who collect your Personal Information and/or perform functions on our behalf, or who collaborate with us). In such cases, we will only collect your Personal Information for or in relation to the purposes the third party is engaged for or our collaboration with the third party (as the case may be). Specifically, if you register for a payment card or account through the Application and/or access, add, and/or link a payment card or account to the Application (as applicable in your country), we may collect certain financial information and your financial history (including but not limited to payment card or account transaction history, payment card or account details, and mapping and/or status of the payment card or account) from the payment card issuer or account issuer or other third parties.
d. Information about third parties you provide to us You may provide us with Personal Information relating to other third-party individuals (including Personal Information relating to spouses, family members, friends, or other individuals). In such cases, you must, of course, obtain their consent to do so – see "Acknowledgment and Consent" above, for more information. When you use the chat feature in our mobile application, you will provide us with the phone numbers stored in your mobile phone's address book so you can use our chat feature and for other purposes.
USE OF PERSONAL INFORMATION
How We Use Your Personal Information
We may use the Personal Information collected for the following purposes and for other purposes permitted by applicable law ("Purposes"):
a. If you are a User, we may use your Personal Information:
(i) to identify you and register you as a User and to manage, verify, deactivate, or manage your account;
(ii) to facilitate or enable any verification we deem necessary before a Service Provider provides services to you or before we register you as a User;
(iii) to allow Service Providers to provide services to you as requested;
(iv) to process and facilitate orders and payment transactions made by you, including where applicable, transactions made via payment cards or accounts available through the Application;
(v) to notify you about any transactions or activities occurring within the Application or other systems connected to our Application;
(vi) to facilitate linking accounts and/or wallets if you initiate account and/or wallet linking features between your x0pay account or third-party platforms (as applicable);
(vii) to communicate with you and provide information regarding the use of the Application;
(viii) to inform you about any updates to the Application or changes to available services;
(ix) to process and respond to inquiries and feedback received from you;
(x) to maintain, develop, test, enhance, and personalize the Application to meet your needs and preferences as a User;
(xi) to monitor and analyze user activity, behavior, and demographic data, including trends and usage of various services available on the Application;
(xii) to process and manage reward points (as applicable); xiii. to offer or provide services from our affiliates or partners (as applicable); and
(xiii) to send you direct or targeted marketing communications, advertisements, vouchers, surveys, and information about special offers or promotions.
b. Whether you are a User or provide us with Personal Information, we may also use your Personal Information more generally for the following purposes (although in each case we will always act reasonably and not use Personal Information more than necessary for the specific purpose):
(i) to conduct business processes and functions related thereto;
(ii) to monitor the use of the Application and manage, support, and improve performance efficiency, growth, user experience, and functions of the Application;
(iii) to provide assistance in and resolve technical or operational issues with the Application or services;
(iv) to generate statistical information and data analytics for testing, research, analysis, product development, commercial partnerships, and collaboration;
(v) to prevent, detect, and investigate prohibited, illegal, unauthorized, or fraudulent activities;
(vi) to facilitate business asset transactions (which may include mergers, acquisitions, or sales of assets) involving us and/or our affiliates;
(vii) to enable us to comply with our legal obligations, including but not limited to responding to inquiries, investigations, or directions from authorities, complying with filing, reporting, and licensing requirements under laws or regulations, and conducting audits, due diligence, and investigations; and viii. for any other purpose we notify you of and, if required by applicable law, obtain your consent.
Disclosure of Your Personal Information
We may disclose to, allow access to, or share your Personal Information with Affiliates and other parties for any of the following purposes and for other purposes permitted by applicable law:
a. If you are a User, to enable Service Providers to perform or provide services, including contacting you;
b. If you are a Service Provider, to enable Users to request or receive services from you, including contacting you;
c. if required or permitted by applicable law (including but not limited to responding to inquiries, investigations, or directions from authorities, or complying with filing, reporting, and licensing requirements under laws or regulations), for the purposes specified in such applicable law;
d. when instructed, requested, required, or authorized by government authorities, for the purposes set forth in government policies, regulations, or applicable laws;
e. in the event of any legal process between you and us, or between you and other parties, related to or in connection with the services, for the purposes of such legal process;
f. in connection with any verification we or third parties deem necessary before a Service Provider provides services to you or before we register you as a User;
g. where we activate our services on any third-party platforms, (i) to assist us in obtaining your Personal Information and/or
(ii) to register you or allow you to use our services from such platforms;
h. in emergencies concerning your health or safety (whether you are a User or Service Provider) for the purpose of handling such emergencies;
i. in situations involving your health or public interest (whether you are a User or Service Provider), we may share your Personal Information with government authorities and/or other agencies that may be designated by government authorities or have cooperation with us, for purposes of contact tracing, supporting government initiatives, policies, or programs, public safety, and other purposes as reasonably required;
j. in connection with any merger, asset sale, consolidation or restructuring, financing or acquisition of all or part of our business by or into another company, for the purpose of such transaction (even if the transaction is ultimately not proceeded with);
k. in connection with insurance claims, we will share your Personal Information for processing insurance claims with the involved insurance companies or those working with us;
l. to third parties (including agents, vendors, suppliers, contractors, partners, and others providing services to us or you, performing functions on our behalf, or with whom we have commercial collaborations) for or in relation to such third parties' purposes, to make certain disclosures to relevant third parties that are technically necessary to process your transactions or for our collaboration with such third parties (as applicable), which may include allowing such third parties to introduce or offer products or services to you, authenticate you or link with your Account, or perform other activities including marketing, research, analysis, and product development; and
m. If we share Personal Information with affiliates, we will do so for them to assist us in providing the Application, operating our business (including, if you have subscribed to our mailing list, for direct marketing purposes), or to process data on our behalf. For example, x0pay affiliates in other countries may process and/or store your Personal Information on behalf of the x0pay group in your country. All our affiliates are committed to processing the Personal Information they receive from us in accordance with this Privacy Notice and applicable laws.
If Personal Information does not need to be linked to you, we will make reasonable efforts to remove any means that can be used to link such Personal Information to you as an individual before disclosing or sharing such information. We do not sell or rent your Personal Information. Except as set forth in this Privacy Notice, we may disclose or share your Personal Information if we notify you and have obtained your consent for such disclosure or sharing.
INTERNATIONAL TRANSFERS
When you use our App and services in another country where our App is also accessible ("Designated Country"), we may transfer your Personal Information from your country of origin ("Country of Origin") to the Designated Country to facilitate and ensure a smooth customer experience when using our App abroad.
Your Personal Information may also be stored or processed outside of your country by our personnel working for us in other countries or by our third-party service providers, vendors, suppliers, partners, contractors, or affiliates.
We will comply with Applicable Laws and make reasonable efforts to ensure that our overseas Affiliates and all third-party service providers provide a level of protection equivalent to our commitment under this Privacy Notice and as required by the laws in your country.
You understand and consent to the transfer of your Personal Information out of your country of origin and/or the Country of Origin as described in this Privacy Notice.
PROTECTING YOUR PERSONAL INFORMATION
Data Security
The confidentiality of your Personal Information is very important to us. We will make reasonable efforts to protect and secure your Personal Information from unauthorized access, collection, use, or disclosure and from unlawful processing, accidental loss, destruction, and damage, or similar risks. Unfortunately, the transmission of information over the Internet is not entirely secure. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information you send over the Internet or that such Personal Information will not be intercepted, accessed, disclosed, altered, or destroyed by unauthorized third parties, due to factors beyond our control. You are responsible for maintaining the confidentiality of your Account details and must not share your Account details, including your password and One-Time Password (OTP), with anyone and must always ensure and be fully responsible for the security of the device you use.
Data Retention
Your Personal Information will only be retained as long as necessary to fulfill the purposes for which it was collected, or as required or permitted by Applicable Laws. We will cease retaining your Personal Information, or remove identifiers that can link the Personal Information to you as an individual, once it can be assumed that the purposes for which the Personal Information was collected are no longer being fulfilled and retention is no longer necessary for legal or business purposes.
Please note that some of your Personal Information may still be retained by others, including government institutions in certain ways. If we provide your Personal Information to government authorities and/or other institutions that may be designated by government authorities or have a partnership with us, you agree and acknowledge that the retention of your Personal Information by such institutions will be governed by their respective data retention policies. Information conveyed through communications between Users and Service Providers conducted outside the use of the App (such as via phone calls, SMS, text messages, or other communication methods and collection of your Personal Information by our agents) may also be stored in various ways. We do not encourage the storage of Personal Information in such ways and are not responsible to you for the same. To the extent permitted by Applicable Laws, we are not responsible for the storage of your Personal Information. You agree to indemnify, defend, and hold harmless us, our officers, directors, employees, agents, partners, suppliers, contractors, and affiliates from and against any and all claims, losses, liabilities, expenses, damages, and costs (including but not limited to legal fees and expenses on a full indemnity basis) arising directly or indirectly from the unauthorized storage of your Personal Information.
YOUR RIGHTS AS A USER
Legal Rights
You may have certain rights under Applicable Laws to request access to, correct, and/or delete your Personal Information that we hold and control. To the extent these rights are available to you under Applicable Laws, you can exercise these rights by contacting us using the details provided below.
We reserve the right to refuse your request to access, correct, and/or delete some or all of your Personal Information that we hold or control if permitted or required by Applicable Laws. This may include situations where the Personal Information may contain references to other individuals or where the request for access or correction is for reasons we consider trivial, frivolous, or vexatious. Subject to Applicable Laws, we may charge an administrative fee for any access and/or correction requests.
ADDITIONAL NOTES
Third-Party Websites and Services
The App and Marketing Materials may contain links to third-party websites. We do not control or accept any responsibility for these third-party websites and their data collection, use, maintenance, sharing, or disclosure practices. Please review the terms and conditions and privacy policies of such third-party websites to understand how they collect and use your Personal Information.
When using our App and enabling fingerprint and/or facial recognition features on your Mobile Device for authentication purposes, please note that we do not store this biometric data. Unless otherwise notified, this data is stored on your mobile device and may also be stored by third parties, such as the manufacturer of your Mobile Device. You agree and acknowledge that we are not responsible for any unauthorized access to or loss of biometric data stored on your Mobile Device.
Advertisements on our App or Marketing Materials operate as links to advertisers’ websites, and any information they collect through your click on these links will be collected and used by the relevant advertiser in accordance with their privacy policy.
Marketing and Promotional Materials
We and our partners (including vendors, suppliers, traders, and/or other third parties involved with us for commercial and/or non-commercial activities) may send you direct marketing, advertisements, and promotional communications through push notifications, in-App messages, mail, phone calls, SMS, chat platforms, social media, and email ("Marketing Materials") if you have opted to subscribe to our mailing list and/or agreed to receive marketing and promotional materials from us. You may choose to opt out of receiving such marketing communications at any time by clicking the "unsubscribe" facility in the relevant message or contacting us using the contact details provided below. Please note that if you choose to unsubscribe, we may still send you non-promotional messages, such as travel receipts or information about your Account.
Privacy Notice Updates
We may review and amend this Privacy Notice at our discretion from time to time, to ensure it aligns with our future developments and/or changes in legal or regulatory requirements. If we decide to amend this Privacy Notice, we will notify you of the changes through a general notice published on the App and/or website or to the email address listed in your Account. You agree that it is your responsibility to review this Privacy Notice periodically to stay informed about our data processing and protection practices, and that by continuing to use the App or website, communicating with us, or accessing and using the services after changes to this Privacy Notice, you are consenting to this Privacy Notice and all its amendments.
CONTACT US
How to Contact Us
If you have any questions or concerns regarding this Privacy Notice or if you wish to access and/or correct your Personal Information, please contact the relevant DPO for your country:
X: https://x.com/x0payCom
Telegram: https://t.me/x0payCom
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