Thank you for using Stripay!

Stripay is a global payments and financial platform company for modern businesses. We provide a broad range of financial services including payments, treasury, spend management and embedded finance to global businesses of all sizes. It is important that you are well informed as to how we process your personal information. This Privacy Policy (the “Policy”) describes the information we collect from you and how that information is used and shared by us. It also includes details about the choices we offer you in relation to your information. Please review it carefully.

Here is a summary of the information contained in this Policy (although it is not a substitute for reading the full Policy). We have included hyperlinks to help you jump to the relevant sections with more detail.

1. SCOPE OF POLICY

This Policy applies to you when you use or interact with our Services anywhere in the world, or our website, mobile app, or other channel (collectively, “Sites”). “Services” means any products, services, technologies or functionalities offered by Stripay. The Services we offer may vary by region.

Depending on the context, “you” may mean any of the End User, Business Customer, Representative or Visitor.

End User: an end user (individual) who uses our Service, regardless of whether the End User uses our Services for personal use or otherwise. We collect an End User’s personal information when provided by the Business Customer .

Representative: individual who is the owner of, or who acts on behalf of a Business Customer (e.g. employee, director or officer of Business Customer who has authority for managing Business Customer’s account with us).

Visitor: a visitor (individual) to our Sites or who otherwise communicates with us (e.g. if you send us a query on our Support Page) without being logged into an Stripay account.

“Business Customer” refers to a business entity who we provide Services to, whether directly or indirectly, or do business with and such Business Customer will provide us with an End User’s personal information in connection with Business Customer and that End User’s respective activities. When you (as an End User or Representative) interact with a Business Customer, your personal information will be collected, retained, shared and/or stored by the Business Customer in accordance with their own privacy policies and not this Policy.

2. DATA CONTROLLER

As used in this Policy, “we,” “us” “our” and “Stripay” refers to the Stripay group company that acts as the data controller with respect to your information. The data controller responsible for your information under this Policy varies depending on your country of residence and/or the entity used to enter into an agreement with Stripay to provide services to you and is listed below.

Our privacy team can be contacted at [email protected].

3. THE TYPES OF PERSONAL INFORMATION WE USE

“Personal information” means any information that identifies you (whether directly or indirectly), such as your name, address, telephone number, email address, date of birth, payment card information, bank account information and any other data that is associated with your identity. The specific categories of personal information which we process are listed in the section “How We Use Your Personal Information” below. This section describes the different types of personal information we collect from you and how we process it.

A. INFORMATION YOU PROVIDE DIRECTLY TO US

Account and Profile Information, Events participation, Newsletter or Content subscription: To use our Services or attend an event or receive content we publish, you must provide certain personal information to us, including contact details and other information required to establish an account profile, identity verification information, financial information and information regarding beneficiaries of payments. This information is necessary for us to perform the contracted services and also to allow us to comply with our legal obligations. If you are not able or willing to provide this information, we may not be able to provide you with all the requested Services.

Survey, feedback, and promotions: Some information you provide to us is voluntarily provided by you and not mandatory. Examples of such information include your opting to respond to our surveys, provide feedback to us about our products and services, participate in promotions or contests or otherwise communicate with us. This information allows us to provide incentives or additional features to you, evaluate our performance and to create a better user experience for you when using the Stripay platform. This additional information will be processed based on our reasonable discretion or when applicable, your consent.

B. INFORMATION AUTOMATICALLY COLLECTED FROM YOUR USE OF SERVICES

We automatically collect certain data from you when you use the Services or visit any of our Sites where we have a legitimate interest (such as to prevent fraud or misuse, or to understand your use of and improve our Services). This includes:

transaction data, beneficiary information, card related information;

usage data;

information about the devices you use to access the Services;

recordings;

log data; and

location information.

Our Cookie Policy provides additional information about the technologies we use to automatically collect your personal information mentioned above.

C. INFORMATION COLLECTED FROM THIRD PARTIES

We also obtain information about you from other external sources, including information obtained from our ecosystem and financial partners, payment service providers, service providers, credit bureaus, credit reference agencies or other providers of credit information, financial institutions, debt collection agencies, companies and other official registers and databases, fraud prevention agencies and partners, community forums used to post ratings or reviews, Stripay business partners or Business Customers through which you access our Services, or other sources of public records. The collection and sharing of such personal information with Stripay is also explained in such third parties’ own respective privacy policies. We may combine information collected from third parties with information we collect from you directly through the Stripay platform.

Regardless of the method of collection, the information we obtain from or about you is subject, at all times, to the privacy choices or rights exercised by you.

D. COOKIES

We use cookies and similar technologies (i.e. web beacons, pixels, ad tags and device identifiers) to recognize you and to customize your online experience. To learn more about cookies and the other tracking technologies we may utilize, please refer to our Cookie Policy, which includes a comprehensive overview of cookies and provides further details about how we use cookies and how to control our use of cookies.

4. HOW WE USE YOUR PERSONAL INFORMATION

This section provides more detail on the types of personal information we collect from you, and why. For users who are resident in the United Kingdom, the European Economic Area or Switzerland (each a “Relevant Jurisdiction”), it also identifies the legal basis under which we process your personal information.

5. TRANSFERS AND STORAGE

We primarily host your personal information in Singapore, Hong Kong, Belgium, the Netherlands, Japan, Australia, Malaysia, and the United States. As a global business we may also transfer your personal information to, and process your personal information in, countries outside your country of incorporation, business operations or residence, and where our affiliates, Ecosystem and Financial Partners and service providers are located. These countries may have data protection rules that are different from your country. In certain situations, we may be required to disclose your personal information pursuant to lawful requests from local law enforcement or government authorities. Stripay implements appropriate measures and safeguards to protect your personal information to meet the standards described in this Policy, including the use of mandated Standard Contractual Clauses (for the European Union) and International Data Transfer Agreement (for the United Kingdom) or any equivalent standard contracts issued by relevant authorities into its agreements (where applicable) and/or adopting alternative measures required for the lawful transfer of personal information in accordance with applicable data protection law.

6. DATA RETENTION

We will retain your personal information for the period of time required to comply with applicable law, for fulfilling any ongoing obligations to you or, where necessary and consistent with applicable law, for our internal business purposes.

We will retain your personal information even after you close your Stripay account or request deletion of your personal information. Examples of such cases include:

To process any transactions booked prior to closure or deactivation of an account.

To comply with anti-money laundering regulations or other laws and rules.

To detect or prevent fraud and other loss prevention activities.

To comply with legal process orders or law enforcement requests.

To collect any fees or other outstanding amount owed and payable to us by you.

To comply with our tax, accounting, and financial and regulatory reporting obligations.

Where required by our contractual commitments to our ecosystem or financial partners.

To resolve any disputes or enforce our User Agreement or other applicable agreements or policies.

To take any other action or exercise any other right in accordance with applicable law.

When a relevant retention period has passed, Stripay will destroy personal information or, where applicable, sufficiently anonymize the personal information.

7. YOUR RIGHTS AND CHOICES

You have certain rights relating to your personal information. The ability and extent to which you may exercise these rights will vary depending on your location. Only the data subject (an individual), account owner or the administrator may raise data subject rights to us.

The following rights (described in detail below) apply to users in a Relevant Jurisdiction.

If you are located outside of a Relevant Jurisdiction, please review the section on Jurisdiction- Specific Rights for more information about the privacy rights afforded to you in your country or state of residence. To exercise any of your rights, please contact us at [email protected].

A. ACCESS, CORRECTION, ERASURE

You may review, correct or update information you provided to us at any time by logging into your Stripay account. Prior to changing or correcting your information, we may be required to verify your identity. There may be circumstances which preclude us from providing access to some or all of your information, for example where the information contains references to personal information about an individual other than you or the information is subject to legal or proprietary protections. If there is any other personal information you believe we process that you would like to access, correct or erase, please contact us at [email protected].

B. PORTABILITY

You may have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., your name). You may have the right to receive this information in a structured, commonly used and machine-readable format. You may also have the right to request that we transfer or share that personal information to another party (e.g. a third party service provider or an ecosystem or financial partner), with certain exceptions. We will provide further information to you about this if you make such a request.

C. RESTRICTION OF PROCESSING

You may have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

D. OBJECTION

You may have the right to object to our processing of your personal information. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at [email protected]. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

8. DEVICE & MARKETING

Device Permissions

Most mobile devices allow you to disable the use of location services, or revoke consent to applications to access your camera and photo library or send you push notifications information. Please refer to your device settings to restrict collection of certain information.

Notifications

We may from time to time send you notifications when we consider it necessary to do so (for example, when we temporarily suspend access to the Services for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related notifications, which are not promotional in nature.

Marketing Opt-Out

As described in section 4, we only send you promotional communications with your consent. You can opt out of receiving such promotional communications from us by following the instructions included in those messages or by logging into your Stripay account and changing your preferences. Please note that if you opt out of marketing-related emails from us, we will continue to send you non-promotional messages that are required to provide our Services, such as transactional receipts and messages about your account or our relationship with you.

9. ADVERTISING AND ANALYTICS

We may partner with third parties to display advertisements to you on websites you visit. These third-party partners use cookies and other technologies to gather information about your activities on our Sites as well as other sites you visit in order to serve you advertising based upon your browsing history and interests. To learn more about behavioral advertising and online tracking, visit the Network Advertising Initiative. This website also provides information about how to opt out of interest-based online advertising delivered by member companies. You can learn more about Google’s practices here. For more information about the cookies that may be served through use of our services, please refer to our Cookie Policy.

10. SECURITY

We implement and update technical and physical security measures to safeguard your personal information against loss, misuse or unauthorized access on an ongoing basis. Safeguards used to protect your information include firewalls, data encryption, and access controls. Please keep in mind that the transmission of information over the Internet is never 100% secure and no data storage system can be guaranteed safe. Although we will do our best to protect your personal information, we cannot warrant the security of data transmitted to our Sites; any transmission is at your own risk. We encourage you to understand the integral role you play in keeping your own personal information secure and confidential. Please select passwords that are sufficiently complex and always keep our log-in details secure. If you suspect any unauthorized use or access to your account or information, please contact us immediately.

11. CHILDREN’S PRIVACY

The Sites and Services are not intended for or directed at children. By children we mean users under the age of 16 or in the case of a country where the minimum age for processing personal information differs, such different age.

We do not knowingly collect any information from children. If we obtain actual knowledge that we have collected personal information from a child, we will immediately delete it (unless we are legally obligated to retain such information). Please contact us if you believe that we inadvertently collected information from any child.

12. THIRD PARTY LINKS AND SERVICES

The Sites may include links to third party websites or services, such as third-party integrations, co-branded services, or third-party branded services (“Third-Party Sites”). Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not own or control these third-party websites and when you engage with these Third-Party Sites, you may be providing information directly to the Third-Party Site, Stripay, or both. Third-Party Sites will have their own policies about the collection, use and disclosure of your information. Please review those policies for more information.

13. UPDATES TO THIS POLICY

We reserve the right to make changes to this Policy at any time by posting a revised version to our Site and updating the “Last Updated” date at the top of this Policy. To the extent permitted by applicable law, your continued use of our services after such notice or posting constitutes your consent to our revisions of this Policy. If you disagree with any of our changes, you may deactivate your account with us at any time.

14. CONTACT

If you have questions or concerns about this Policy or a specific request related to your personal information, please contact us at [email protected].

If you wish to make an inquiry regarding how we process your personal information, please contact us at [email protected] and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

15. LANGUAGE

Except as otherwise set out by law, in the event of any inconsistency between the English version and local language version of this Policy (where applicable), the English version shall prevail.

JURISDICTION-SPECIFIC RIGHTS

Some jurisdictions’ laws contain additional terms for users of the Services, which are set out in this section. If you are a customer of Stripay entity located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Policy above.

For customer of Stripay Australia

Overseas Recipients

You consent to the transfer of personal information to third parties outside Australia, and acknowledge that while we take reasonable steps to ensure that such third parties handle your personal information in accordance with Australian privacy laws, we will not be liable for the acts and omissions of these overseas third party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at [email protected].

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at [email protected].

Transacting Anonymously

Where possible we will give you the option of not identifying yourself when using the Service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Services.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: [email protected]).

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

For customers of Stripay United States and resident in California

If you are a California resident, you have certain rights afforded by the California Consumer Protection Act as amended by the California Privacy Rights Act (CCPA) with respect to your personal information.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

Identifiers, such as your name, email address, residential address, date of birth, social security number, driver’s license number, passport number, tax identification number or other similar identifiers, government issued identification information, bank account details, credit card or debit card numbers and IP address. This information is collected directly from you and your device. We disclosed identifiers with third party service providers, our corporate affiliates, ecosystem and financial partners, regulatory authorities, and other authorised parties.

Internet or other electronic network activity information, such as your information regarding your use of the Services, including your user preferences and other settings selected by you, server logs, and other device information as described in the main Policy. This information is collected directly from you and your device. This may be disclosed to third party service providers, our corporate affiliates, ecosystem and financial partners, regulatory authorities, social media platforms and other authorised parties.

Commercial information about any transactions within the Services such transaction information when you collect or make payments. This information is collected directly from you and your device. This may be disclosed to third party service providers, our corporate affiliates, ecosystem and financial partners, regulatory authorities, and other authorised parties.

Location data such as your IP address or mobile device GPS. This information is collected directly from you. This may be disclosed to third party service providers, our corporate affiliates, ecosystem and financial partners, regulatory authorities, social media platforms and other authorised parties.

Professional or employment-related information such as your profession if you choose to provide it in a survey. This information is collected directly from you. This may be disclosed to our corporate affiliates.

Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer. This may be disclosed to third party service providers, our corporate affiliates and ecosystem and financial partners.

Over the past 12 months, we have collected and disclosed the following categories of sensitive personal information from or about you or your device:

Identifiers: such as your social security number, driver’s license number, passport number, tax identification number or other similar identifiers, government issued identification information. This information is collected directly from you.

Financial information: such as your bank account details, credit card or debit card numbers. This information is collected directly from you or from third party financial institutions who you may hold an account with.

We collect your personal information, including sensitive personal information, for the following business purposes:

To provide you with the Services, maintain your account, provide customer service and process payments.

To improve our services, including the functionality of the Services and Sites.

For security and verification purposes, including to prevent and detect fraudulent activity.

To address and remediate technical issues and bugs.

To communicate with you.

To market and promote our Services.

For additional information about what each type of personal information is used for, see this table in the main portion of the Policy. For information regarding how long we retain personal information, see section 6 in the main portion of the Policy.

Sharing/selling personal information:

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA. We do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age.

Rights to know:

If you are a California resident, you have the right to:

Request access to the following information covering the 12 months preceding your request:

the categories of personal information about you that we collected, sold, or shared;

the categories of sources from which the personal information was collected;

the business or commercial purpose for collecting, selling, and disclosing personal information about you;

the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the business or commercial purpose for disclosing the personal information about you; and

the specific pieces of personal information we collected about you;

Request that we correct inaccurate personal information that we maintain about you. Once we receive and confirm a verifiable rights request, we will correct your personal information maintained in our records, unless an exemption applies;

Request that we not to sell or share your personal information. To exercise this right, please use the following form: Do Not Sell or Share My Personal Information;

Request that we delete personal information we collected from you, unless CCPA recognises an exception; and

Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay. Any disclosures will cover only the 12-month period preceding the verifiable rights request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. To exercise any of the rights described in this section, please submit your request by contacting us at [email protected]. Your request must provide sufficient information (including pieces of identification) that allows us to reasonably verify you are the person about whom we collected personal information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

For customers of Stripay Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at [email protected]. We are able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Policy.

For customers of Stripay Hong Kong

If you are located in Hong Kong, you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject the use of your personal information for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

For customers of Stripay Malaysia

Parental and Guardian Consent

In the event you are agreeing to this Policy in order for a minor to access and use the Services, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Policy and you personally accept and agree to be bound by the terms in this Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Policy.

Rights of Data Subjects

Right of access: You have the right to request access to and obtain a copy of the personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts permitted by law. When handling a data access request, we are permitted to request certain information in order to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information.

Right to limit processing of your Personal Information: You may request limiting the processing of your personal information by using the contact details provided above. However this may affect our provision of the Services to you.

Contact

If you would like to make any inquiries, complaints, access or correction requests or request for us to limit the processing of your personal information, please contact us at:

Stripay privacy team

Contact Number: +61 13 32 99

Email to: [email protected]

For customers of Stripay New Zealand

Overseas Recipients

While we take reasonable steps to ensure that third parties outside New Zealand handle your personal information in accordance with New Zealand privacy laws, you acknowledge that we do not control, or accept liability for, the acts and omissions of these overseas third party recipients.

Access and Correction

You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access or correct your personal information by logging into your account. If you believe we hold any other personal information about you or that such information is inaccurate, please contact us at [email protected].

Complaints

If you would like to make a privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

For customers of Stripay Singapore

Access

You have the right to access your personal information, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at [email protected].

Correction

You have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact [email protected].

Our privacy team for the purposes of compliance with the Personal information Protection Act 2012 can be contacted at [email protected].