Privacy Policy

1. INTRODUCTION

1.1 This Privacy Policy explains how UPAY (the "Company") uses the Personal Data (defined below) of the Customer ("you", "yourself").

1.2 Company provides access and utility through our digital asset exchange platform via software, API (application program interface), technologies, products and/or functionalities ("Service"). In the course of providing Service, to abide by the laws in the jurisdictions that Company operates, and to improve services, Company needs to collect and maintain personal information about the Customer. As a rule, Company never discloses any personal information about our Customers to any non-affiliated third parties, except as described below.

1.3 Company may update this Privacy Policy at any time by posting the amended version on this site including the effective date of the amended version. Company communicates any material changes to this Policy via email.

2. DEFINITIONS

2.1 Financial Asset As used herein, "Financial Asset", also called or "digital asset", such as a currency like USD, $CAD, EUR etc.

2.2 Personal Data As used herein, "Personal Data" means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, economic, cultural, or social identity of you as a natural person.

3. COLLECTION OF PERSONAL DATA

Company collects, processes, and stores Personal Data collected from you via Customer's use of the Service or where Customer has given consent. This Personal Data may include contact details, copies of identification documentation provided by Customer or derived from publicly accessible databases, government identification number as well as information relating to devices or internet service (such as an IP address and a MAC number). Company collects information provided during the onboarding process, which may be a completed, incomplete, or abandoned process.

Operating within the European Economic Area ("EEA")

Company collects, stores, and processes personal information in accordance with the Best Practices of Data Collection in the EU, in addition to GDPR [General Data Protection Regulation-(EU) REGULATION 679/2016].

And the types of Customers are defined in UPAY's Customer Type and Jurisdiction Acceptance Policy.

4. COLLECTION AND STORING OF DATA OUTSIDE CANADA

As outlined above, Company may collect Personal Data from Customers located in the EEA. To facilitate the services Company provides to Customers located in the EEA, Company requests explicit consent for the transfer of Personal Data from the EEA to outside of the area. If Customer is an individual located in the EEA and declines to consent to such transfer, Customer will no longer be able to use Company's Services.

Customer will have the ability to withdraw digital assets; however, all other functionalities will be disabled.

5. PERSONAL DATA

Company uses Personal Data to communicate with the Customer and to administer, deliver, improve, and personalize the Service. Company might also generate generic data out of any Personal Data collected and use it for company purposes.

Company may also use such data to communicate with you in relation to other products or services offered by company and/or its partners. Company does not share Personal Data with third parties except as described in this Privacy Policy or with your explicit consent.