Privacy Policy

This Privacy Policy was last amended on: November 19, 2018

This privacy policy describes how FibbPay (“us,” “we”, “our”, “FibbPay”) uses and protects the personal data it collects about its merchants (“you,” “your”).

The term “personal data” refers to information that can be used to identify, contact, or locate a single person or that can be used with other information to uniquely identify a single individual.

FibbPay manages and utilizes merchants’ and customers' personal data in an appropriate way adhering to the concerned rules and regulations. We promise to make reasonable efforts to safeguard the confidentiality of all personal data including merchants’ and customers’ names, addresses, phone numbers and e-mail addresses, etc.

Merchants who use our payment services are also data controllers. If the merchant’s customers want to exercise their rights on the personal data the merchant holds; they have to contact the merchant directly.

Please read the following carefully to understand our practices on how we treat your personal data. If you cannot accept this policy, you can abandon the services provided by us and terminate the contractual relationship.

A. Our Role

FibbPay acts as the processor to process the personal data (including but not limited to financial information and transaction details) that you and your customers have provided and you shall act as the controller of the Personal Data. We will process the Personal Data to perform its service obligation.

FibbPay collects the personal data that you and your customers have provided to carry out and administer our services for improving your service satisfaction.

You warrant and approve the collection of the personal data that you and your customers have provided, and you have agreed on all terms and conditions of this Privacy policy. We have the legal right to collect and operate it. You shall be responsible for all losses and damages caused by the authorization.

B. Purpose of Collection of Data

For data protection, we practice the principle of data minimization which requires us to process only the personal data that are necessary, relevant and adequate in relation to the purpose of its use.

We collect personal data when you use our website, make an inquiry or communicate with us.

We collect personal data when you inquire about our set up, administer, and make use of the services we provide. This may include information about your company’s employees, directors, or beneficial owners.

We collect personal data when you set up and make or have a payment collected using our services.

The Data submitted to FibbPay including, but not limited to name, address, phone number, and e-mail address are collected to obtain products/services. If you provide any Data to us, you are deemed to have authorized us to collect, retain and use that data for the following purposes:

Exercise terms and conditions as stated in the merchant service agreement and agreed upon by you and us. To deliver the key features of the services, we use the identification, contact information, and transaction data that you and your customers have provided.

We use personal data to communicate with you or provide customer support.

We use personal data for our legitimate business interests. When we do, we make sure we understand and work with its privacy impact.

We limit the data to what is necessary, control access to the data, and where we can, aggregate or re-identify the data.

We use personal data to develop and improve our products and services.

We use personal data to comply with the requirements of law and the payment schemes we operate under, and as required in other exceptional circumstances.

Verifying the identity of you and your customers to prevent money laundering or other unauthorized transactions.

Verifying the eligibility of you and your customers to gain our service/products.

Outsource limited operational assignments to an authorized third party who has been disclosed to you and your customers.

Assist other financial institutions to conduct your request for transactions or investigates about failed transactions.

Introduce our new services and products to you by direct mailing, e-mail, questionnaires or other marketing methods.

Maintain and manage your data; providing you with customer service and responding to your queries, feedback, claims or disputes.

Improve the relationship between you and us.

C. Security

FibbPay will take appropriate security measures to protect personal data. FibbPay will ensure that personal data are adequately protected against unauthorized or accidental access, processing, erasure, or use by other people without authority for effectively preventing unauthorized access and fully safeguarding the information that you and your customers have provided from data theft.

FibbPay uses reliable platform that meets the security standards to store the personal data of you and your customers. Fully aware of the importance of Personal data, only authorized staff within FibbPay’ permission have access to the personal data of you and your customers. The security measures include SSL, firewalls, data encryption, and information access authorization controls.

Technical and organizational which aimed to ensure a level of security appropriate to the risk including inter alia as appropriate: the pseudonymization and encryption of personal data, the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services, the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident, a process for regular testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

D. Data Retention

You agree that under the applicable money laundering legislation and applicable laws, the personal data of you and your customers cannot be deleted and transmitted. It will be stored in our designated platform for as long as necessary to provide our services and process payments for our merchants. We also keep personal data for other legitimate business purposes, such as complying with our legal obligations, resolving disputes, preventing fraud, and enforcing our agreements. These needs can vary for different data types used for different purposes as well as the retention period.

E. Data Disclosure

You agree that FibbPay may disclose and transfer the Personal Data that you and your customers have provided to Service Providers ("Service Providers") who is a third-party subcontractor engaged by FibbPay which, as part of the subcontractor’s role of delivering the services, processes Personal Data to assist in providing you with FibbPays’ services (including but not limited to Merchant service, data entry, database management, promotions, products and services alerts and delivery services)

FibbPay share Personal Data within FibbPay entities in order to provide our Services and for internal administration purposes. These Service Providers will undertake data protection and confidentiality obligations consistent with applicable data protection laws.

You agree that when necessary FibbPay may also disclose and transfer the Personal Data that you and your customers have provided, to the law enforcement agencies, government and regulatory bodies and other organizations when required by the law or where disclosure is necessary to comply with applicable laws, legal processes or queries from the relevant authorities.

You agree and warrant that you will disclose all the operational details about Personal Data to your customers on your agreement. If any loss and / damage arise due to non-disclosure, you shall take its full responsibility.

F. Notice

Our business and our services may change from time to time. As a result, at times, it may be necessary for FibbPay to make changes to this Privacy Policy. FibbPay reserves the right to update or modify this Privacy Policy at any given time. If we do this, we will post the changes and indicate the date the update was made at the top of this page. Please review this policy periodically, especially before you provide any Personal Data. Your continued use of the Service after such changes become effective, constitutes your acceptance of the new Privacy Policy.

G. Applicable regulations and law

We conduct personal data protection under the United Kingdom laws and General Data Protection Regulation (GDPR) which is the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

Whenever we transfer personal data to countries outside of the European Economic Area, in the course of sharing information as set out above, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.

By using our Sites and Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Sites and Services are appropriate or available in any particular jurisdiction.

H. Disclaimer

In case of any discrepancy among other language versions (if any), the English version shall apply and prevail.

The privacy policy is applicable to all personal data that we collect, use, share and store when you build a business relationship with us, when you visit our website or when you are in contact with us.

I. Cookies

You agree that we may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you and customize your online experiences and other content and advertising; to administer the Sites, to analyze trends, to track the movements of you and your customers around the Site; Cookies measure the effectiveness of promotions; and mitigate risk, prevent potential fraud, and promote trust and safety across the FibbPay Services. Certain aspects and features of our services are only available through the use of Cookies, so if you choose to disable or decline Cookies, some uses may be limited or not possible. The information collected permits us to analyze traffic patterns and target you and your customers’ interests. This helps us provide you with a better experience by improving the content and making our website easier to use.