Privacy Policy

INTRODUCTION

At BUSINESSBANK PAY INC., our customers are the foundation of our business. As such, we understand the importance of transparently handling and protecting personal data and privacy. Our practices and policies regarding this are outlined in our Privacy Policy. This policy pertains to individuals who are current, past, or prospective customers of BUSINESSBANK PAY INC.

BUSINESSBANK PAY INC. is a business corporation with OCN 1000305267, registered in Canada, at the address: 800 Steeles W Ave, Unit B10182, Thornhill, Ontario, Canada, L4J7L2.

BUSINESSBANK PAY INC. is registered with FINTRAC in Canada with MSB registration number M22260248 for the provision of specified services as money transferring, issuing or redeeming money orders and foreign exchange dealing.

BUSINESSBANK PAY INC. is the “data controller” for any personal data you provide to us through email, telephone, social media, post or through our Services, Website, or any other communication channels we offer. This means that we are responsible for determining how we collect, use and manage personal data about you.

BUSINESSBANK PAY INC. is committed to protecting the security and confidentiality of information under its control and adheres to responsible use and protection of personal data, with transparency and respect to individual rights in accordance with applicable data protection laws, including EU Regulation 2016/679 (GDPR) as applicable.

It is important that you thoroughly read and understand the information provided below regarding our handling of your personal data. If you have any inquiries, please send us an email at privacy@neobusinessbank.com.

TYPE OF PERSONAL DATA WE MAY COLLECT AND HANDLE

PERSONAL DATA

We collect and handle various types of personal data that are supplied by you or your representatives while utilizing our products and services.

Additionally, we may acquire and process personal data that we legally obtain from other members of our organization, public authorities, client introducers, or publicly accessible sources such as online databases (i.e. Registrars of Companies, Screening databases (i.e. sanctions/AML), websites, security searches, and social media.

We gather information you provide when you:

Complete any of our forms available on our website
Communicate with us, whether by telephone or email, or social media or post
Register for an account or use any of our services
Perform transactions
Reach out to us for any other reason.

When applying to become a BUSINESSBANKPAY INC. customer, we will request certain personal information to verify your identity and manage your account. The specific information required may vary depending on the product you apply for, but typically includes:

Personal details such as your name, address, and birth information to confirm your identity
Contact information, including your telephone number and email address
Your photograph or video (when necessary for our Know Your Customer (KYC) verification process)
Employment and occupation details, including but not limited to your curriculum vitae, professional affiliations, job title, responsibilities, and professional certifications.
Information regarding any prominent public positions you currently hold or have held, known as politically exposed persons (PEPs)

If you are representing or owning a legal entity that is our customer, we may also collect and process additional personal data such as financial information, property ownership, personal debts, and banking relationship details.

If you furnish us with personal information belonging to others (such as your representative, secretary, or employee), or request that we share their personal information with third parties, you confirm that you have previously informed them of this policy.

OTHER DATA

We may also gather non-identifying information about You. This non-personal information may include:

Browser and device data such as IP address, operating system, and browser type, which is used for statistical analysis of Website usage and does not identify any individual user.
Cookie data, such as time spent on the Website, pages viewed, language preferences, and other anonymous traffic data (please refer to the Cookies Policy available on our website).
Information about your company such as its name, products and services offered, and jurisdiction.

Some links on BUSINESSBANKPAY INC. website (www.neobusinessbank.com) may contain links to other non-BUSINESSBANKPAY INC. websites or areas with their own data protection policies, which may differ from our Privacy Policy.

Before accessing other websites or areas, it’s important to make sure that you agree with the policies of those entities. BUSINESSBANKPAY INC is not responsible for any issues arising from third-party websites.

If you are not the intended recipient of this Privacy Policy, please review the privacy practices of the entity responsible for controlling your personal data. BUSINESSBANKPAY INC may also be involved in the handling of your information in certain cases as outlined in this policy.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA:

We process your data with the principle of data minimization in mind, aiming to limit the amount of data processed and the types of data processed to only what is necessary for a lawful purpose. BUSINESSBANKPAY INC. uses the data, among other things, for the following purposes:

Fulfillment of our contract: We use the data we collect to establish your customer record and manage your account. We will use your personal information to verify your identity, which may involve sharing some or all of your data with third parties such as fraud prevention agencies, anti-money laundering organizations, credit reference agencies, law enforcement, regulatory bodies, government departments, and providers of our sales or servicing platforms.

Protection of legitimate interests: We process personal information to protect our legitimate interests, as long as these interests do not unduly compromise your rights and freedoms. Examples of these interests include improving our services, protecting our and your data as part of our IT and security systems, and initiating or preparing for litigation procedures.

Compliance with legal obligations: The data will allow us to comply with our legal and regulatory requirements, such as the Electronic Money Regulation, Money Laundering Law, Tax laws, etc. We are also regulated by FINTRAC in Canada and must abide by its requirements. We also use your personal information to prevent fraud and money laundering.

Communication: We use your personal data to communicate with you regarding your account and provide service-related updates and notifications. When possible, we will use our e-banking platform for communication, but there may be situations where regulations require us to contact you in a specific way.

Troubleshooting, analysis, testing, research and statistical/survey purposes: We use your data to complete troubleshooting, data analysis, testing, research, and for statistical and survey purposes.

Marketing: We may use your information for marketing purposes, but only if you have given us permission to do so. This might include using your data to identify products and services that may be of interest to you.

RETENTION PERIOD

Retention of personal data is based on different purposes and is subject to different standards and regulations. In general, personal data is kept as long as necessary to provide the services you requested, comply with relevant legal, accounting or reporting requirements, as well as to investigate any potential fraud and to comply with anti-money laundering, counter-terrorism financing laws and ensure that you have a reasonable opportunity to access the personal data.

The personal information you give us for marketing purposes will be kept until you ask us to opt-out or until we become aware that the data it’s not accurate.

WHO WE DISCLOSE YOUR PERSONAL DATA TO

BUSINESSBANK PAY INC. collects your personal information in order to carry out requests and offer services, as well as to meet contractual and legal obligations.

Your personal data will not be shared with outside parties unless it is essential for our business operations, to fulfill requests or provide services, or as required or permitted by law. Examples of such third parties may include:

Service providers who assist us in providing requested services, such as IT and system management, cloud computing and cloud storage providers, fraud detection, customer support, remote ID verification, customer authentication, e-signature providers.

Companies that facilitate payment transactions like financial institutions, payment service providers, international payment organizations such as SWIFT, SEPA, Visa, Mastercard etc.

Business partners that are relevant to our operations, like banking partners, intermediaries, international payment service providers, card manufacturing and personalization companies, fraud and risk mitigation providers.

Professional advisers, including attorneys, auditors, and insurers who provide necessary services.

Government agencies or entities, regulatory bodies, or other parties as required or permitted by applicable law, in accordance with rules, orders, subpoenas, official requests, or similar processes.

In situations involving the transfer of business, third parties may be involved. For example, if we were to sell any aspect of our business or assets or merge with another company, it may be necessary to share personal data with potential buyers or partners.

Third-party service providers who assist us with client insight analytics, such as Google Analytics.

Advertising networks that assist in organizing competitions and promotions, and displaying advertisements on our website, apps, and other social media platforms.

COUNTRIES WE MAY TRANSFER YOUR DATA

We are a company with global reach. Your personal data may be processed in the local country of our operations or in other countries where we or our partners operate worldwide as permitted by law. Your personal data may be transferred from the European Union/European Economic Area (EU/EEA) or from another country that restricts transfers of personal information to third countries or to international organizations if the transfer is necessary and has a legal basis as described in this document. Such transfers can occur for example:

We may transfer data to a jurisdiction that has been recognized by the European Commission as having adequate data protection standards
The recipient of the data has signed an agreement based on the Standard Contractual Clauses, or if the recipient is a group company, the binding corporate rules are in effect, along with any necessary additional safeguarding measures
The transfer is necessary for the performance of a contract between the data subject and NEOBUSINESSBANK PAY INC.
The transfer is necessary for the establishment exercise or defense of legal claims
Any other legally recognized grounds at EU level for transferring data to third countries.

AUTOMATED DECISION-MAKING & PROFILING

We do not make decisions solely through automated processing. However, certain aspects of your personal data may be processed using automation in the following situations:

Conducting data evaluations, such as payment transactions, for the purpose of preventing fraud, money laundering, and terrorist financing.
Promoting our services and products, if you have given your consent.

COOKIES

Our website uses cookies in order to improve your experience. To find out more details about how we use cookies please refer to our Cookies Policy available on our website.

YOUR RIGHTS

You have the following rights related to the personal information we possess about you.

However, it’s important to note that some of these rights will only apply in certain conditions, and some of them may be limited if we have a compelling interest or legal requirement to continue processing the data, or if data may be exempt from disclosure for reasons of confidentiality.

Right to access.

You can request a copy of the personal data retained and a confirmation from us whether personal data is processed or not.

Right to correction.

You have the right to request correction of inaccurate or incomplete personal data that pertains to you. You have the right to have any incorrect personal data about you corrected and, in relation to the purpose of processing, to have any incomplete personal data about you completed.

Right to erasure.

You can request erasure of your personal data (depending on the circumstances and agreements in place) if:

The data is no longer needed for the reasons it was collected or processed
You withdraw your consent on which the processing is based and where there is no other legal ground for the processing
You have objected to the processing of the data
The data has been processed illegally (i.e. a violation of the legal basis requirement)
Personal data must be erased for compliance with a legal obligation

The above rights to to erasure shall not apply if the processing is necessary (a) for the exercise of the right to freedom of expression and information; (b) for compliance with a legal obligation that we are subject to; and (c) for reasons of public interest; or for initiating, pursuing or defending legal claims.

Right to restriction of processing.

You have the right to request that we temporarily suspend the processing of certain personal data related to you, where one of the following applies

You may contest the accuracy of your personal data for a sufficient amount of time for us to verify its accuracy.
If the processing of your data is deemed unlawful, you may request that its use be restricted rather than erased.
We may no longer require the processing or retention of certain data, however, you can request that we keep it as it is necessary for you to establish, assert, or defend a legal claim.
You have raised objection to the processing of your data and are awaiting confirmation of whether our legitimate interest in processing the data outweighs your rights and freedoms.

Right to data transfer.

You have the right to receive the personal data you have provided to us in a structured, widely used, and machine-readable format. Additionally, you have the right to transfer this data to another organization or to request that we do so on your behalf. In instances where the processing is carried out due to a legal obligation of BUSINESSBANKPAY INC., this right may not be fully applicable.

Right to object.

When we process your personal data based on our or a third party’s legitimate interests, you have the right to contest it. However, we may still have the right to continue processing your information. Additionally, you have the right to object to our processing of your personal data for direct marketing purposes. If you object to the processing of certain personal data, we may not be able to provide you services and may have to end the provision of services.

Right to withdraw consent. If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. However, please note that if there is another lawful basis for processing your personal data, we may continue to do so. If the withdrawal of your consent results in our inability to provide you with services, we will inform you of this.

However, we may continue to keep your data if there is another valid reason for doing so.

Our obligations to comply with legal requirements (such as record-keeping) to process and retain certain data will take precedence over any requests for erasure, and we may also continue to retain/use your data if there is another valid reason for doing so (such as for the exercise of legal claims or serving the public interest).

Right to file a complaint.

If you have any complaints about the use of your data or the exercise of your rights, please contact our Data Protection Officer at the below contact details. We will promptly investigate and respond to your complaint.

BUSINESSBANK PAY INC.

(Data Protection Officer)

Address: 800 Steeles W Ave, Unit B10182, Thornhill, Ontario, Canada, L4J7L2

Email: dpo@neobusinessbank.com

CHANGES TO THIS PRIVACY POLICY

We may periodically update this Privacy Policy by uploading a new version on our website. It is recommended that you check this page occasionally to ensure that you are aware of any changes. Whenever it is feasible, we will notify you of any significant changes via email.