WonPay (defined below under “Our relationship to you”) is committed to protecting the privacy of visitors to our websites and our customers. This Privacy Policy describes how we handle your personal data when you access our services, which include our content on the websites located at WonPay.io or any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”), or any WonPay API or third party applications relying on such an API, and related services (referred to collectively hereinafter as “Services”).
Changes to this privacy policy
We may modify this Privacy Policy from time to time. Please check the date at the top of this notice to see when it was last updated.
Our Relationship to you
WonPay operates internationally through different entities (together “WonPay”, “we”, “us”, “our”) in order to provide Services to our customers.
The WonPay entity you contract with decides how your personal information is processed in relation to the Services provided to you (typically referred to as a “data controller”).
WonPay entities may share your personal information with each other and use it in accordance with this Privacy Policy.
Personal Information we collect
Personal information means any data which relates to a living individual who can be identified from that data, or from that data and other information which is in the possession of, or is likely to come into the possession of, WonPay (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of WonPay or any other person in respect of an individual. The definition of personal information depends on the relevant law applicable for your physical location.
Information you provide to us
This includes information you provide to us in order to establish an account and access our Services. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services or is relevant for our legitimate interests described in greater detail below.
The nature of the Services you are requesting will determine the kind of personal information we might ask for, but may include:
● Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
● Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.
● Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
● Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
● Employment Information: Office location, job title, and/or description of role.
● Correspondence: Survey responses, information provided to our support team or user research team.
Information we collect automatically or generate about you
This includes information we collect automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
● Online Identifiers: Geo location/tracking details, operating system, browser name and version, and/or personal IP addresses.
● Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.
Anonymized and aggregated data
In addition to the categories of personal information described above, WonPay will also process anonymized information and data that is not processed by reference to a specific individual. Types of data we may anonymize include transaction data, click-stream data, performance metrics and fraud indicators.
How we use your personal information
We may use your information in the following ways and for the following purposes:
1) To maintain legal and regulatory compliance
WonPay needs to process your personal information in order to comply with anti-money laundering and security laws. we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. We also process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our Services and to protect you against account compromise or funds loss. If you do not provide personal information required by law, we will have to close your account.
2) To provide WonPay’s Services
We process your personal information to provide Services to you. For example, when you want to store funds on our platform, we require certain information such as your identification, contact and payment information. Third parties that we use such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. The consequences of not processing your personal information for such purposes is the termination of your account.
3) To provide communications and customer services
According to your preferences and in compliance with applicable law, we may send you marketing communications to inform you about events, to deliver targeted marketing and to share promotional offers. If you are a new customer, we will contact you by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to send you marketing communications, please go to your account settings to opt-out or submit a request via unknown node
We may send you service updates regarding administrative or account-related information, security issues, or other transaction-related information. These communications are important to share developments relating to your account that may affect how you can use our Services. You cannot opt-out of receiving critical service communications.
We also process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
4) In our legitimate business interests
Sometimes the processing of your personal information is necessary for our legitimate business interests, such as:
● to enhance security, monitor and verify identity or service access, and to combat spam or other malware or security risks;
● to enhance your experience of our Services and Sites; or
● to facilitate corporate acquisitions, mergers, or transactions.
Legal bases for processing your information
For individuals located in the European Economic Area, United Kingdom or Switzerland at the time their personal data is collected, we rely on legal bases for processing your information under the relevant data protection legislation. These bases mean we will only process your data where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business, to protect WonPay’s or your property rights, or where we have obtained your consent to do so. We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission.
Disclosing your personal information to third parties
We allow your personal information to be accessed only by those who require access to perform their work and share it only with third parties who have a legitimate purpose for accessing it. WonPay will never sell or rent your personal information to third parties without your explicit consent. We will only share your personal information with the following types of third parties:
● Identity verification services to prevent fraud. This allows WonPay to confirm your identity by comparing the information you provide us to public records and other third party databases.
● Financial institutions which we partner with to process payments you have authorized.
● Service providers and professional advisors under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us and prohibit them from sharing your information with anyone else.
● Companies or other third parties in connection with business transfers or bankruptcy proceedings.
● Companies or other entities that purchase WonPay assets.
● Law enforcement, regulators, or any other third parties when we are compelled to do so by applicable law or if we have a good faith belief that such use is reasonably necessary, including to: protect the rights, property, or safety of WonPay, WonPay customers, third party, or the public; comply with legal obligations or requests; enforce our terms and other agreements; or detect or otherwise address security, fraud, or technical issues.
Third-party sites and services
If you authorize one or more third-party applications to access your WonPay Services, then information you have provided to WonPay may be shared with those third parties. A connection you authorize or enable between your WonPay account and a non-WonPay account, payment instrument, or platform is considered an “account connection.” Unless you provide further permissions, WonPay will not authorize these third parties to use this information for any purpose other than to facilitate your transactions using WonPay Services. Please note that third parties you interact with, should have their own privacy policies and WonPay is not responsible for their operations or their use of data they collect.
How we protect and store personal information
WonPay implements and maintains reasonable measures to protect your information. Customer files are protected with safeguards according to the sensitivity of the relevant information. Reasonable controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.
We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the US and elsewhere in the world where our facilities or service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
As a condition of employment, WonPay’s employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive personal information is limited to those employees who need to it to perform their roles. Unauthorized use or disclosure of confidential customer information by a WonPay employee is prohibited and may result in disciplinary measures.
When you contact a WonPay employee about your file, you may be asked for some personal details. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file. You also play a vital role in protecting your own personal information. When registering with our Services, choose a password of sufficient length and complexity, don’t reveal it to any third-parties and immediately notify us if you become aware of any unauthorized access to or use of your account.
Retention of personal information
How long we hold your personal information for will vary. The retention period will be determined by the following criteria:
● the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for that purpose; and
● legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
If we anonymize your personal information so that it can no longer be associated with you, it will no longer be considered personal information, and we can use it without further notice to you.
Children's personal information
We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, WonPay will require the user to close his or her account and will not allow the user to continue using our Services. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.
Your privacy rights
Depending on applicable law of where you reside, you may be able to assert certain rights related to your personal information. These rights include:
● the right to obtain information regarding the processing of your personal information and access to the personal information which we hold about you;
● the right to withdraw your consent to the processing of your personal information at any time. Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason for doing so. For example, we may need to retain personal information to comply with a legal obligation;
● in some circumstances, the right to receive some personal information in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to WonPay;
● the right to request that we rectify your personal information if it is inaccurate or incomplete;
● the right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it;
● the right to object to, or request that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request; and
● the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
How to contact us
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us [email protected]
Consumer privacy notice
This Consumer Privacy Notice applies to you if you use WonPay services for your own personal, family or household purposes.
Wonpay is an open-source project supported by the Commons foundation, working together for a sustainable human community.
Wonpay is an open-source project supported by the Commons foundation, working together for a sustainable human community.