PRIVACY POLICY

This Privacy Policy governs the manner in which Piccopay collects, processes, retains, shares, and removes information collected from data subjects.

COLLECTION OF INFORMATION

Piccopay collects data in variety of ways, including, but not limited to:

● Online, when using the online systems, web and mobile applications, registration is required in order to proceed to place an order, respond to a survey, and in connection with other activities, services, features or resources

● Offline, submission of information filled-form document format in offline means like storing in USBs, hard drive, DVD/CD and other related storage intended to receive information

● Manual/paper-based forms, when printed forms intended to collect information for documentation requirements, tracking, and monitoring.

CATEGORIES OF DATA SUBJECTS

● Customers, business partners, prospects, vendors, suppliers, vendor or customer of customers

● Applicants and Employees of Piccopay, emergency contact persons and references of employees

● Employees or designated contact persons of Customers, business partners, prospects, vendors, suppliers, vendor or customer of customers

● Customer’s Users authorized by Customer to use the applications and services of Piccopay

● User’s of online systems, web portals, and mobile applications

● Visitors and guests of different Piccopay’s office locations

Piccopay may also collect information about how Users utilize our services. Information may include the browser name, the type of computer and technical information about User’s means of connection, such as the operating system, IP addresses, device information, and the internet service providers utilized and other similar information.

PRIVACY POLICY DEFINITIONS

“Piccopay” is the company to be referred to for and in behalf of legal representations in Singapore. ( Piccopay PTE. LTD ).

“we” (or “our”’ or “us”) means or being referred to as Piccopay.

“Controller” means the entity which alone or jointly with others determines the purposes and means of processing of personal data.

“Customer” means clients with legal signed contracts and agreements with Piccopay.

“Customer Data” or “User Data” contains the personal identifiable information collected and processed by Piccopay.

“Data Protection Laws and Regulations” means all laws and regulations, including laws and regulations of the European Union (GDPR – General Data Protection Regulation), the European Economic Area and member states, Switzerland and the United Kingdom, Philippine Data Privacy Act of 2012, Personal Data (Privacy Law) in Hongkong.

“Data Subject” means the identified person relates to Customer Data or Personal Data or User Data.

“Personal Data” means any information relating to (i) an identified or identifiable natural person or (ii) an identified and identifiable legal entity (where such information is protected similarly as personal data or personally identifiable information under applicable Data Protection Laws and Regulations).

“Processing” means any operation or set of operations which is performed upon personal data or whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction and “process” and “processes” shall have a corresponding meaning.

“Processor” means the entity which Processes Personal Data in behalf of the Controller.

“Privacy Shield” means EU-US and Swiss-US Privacy Shield Frameworks to provide a mechanism when transferring personal data from the European Union and Switzerland (respectively) to the United States in support of transatlantic commerce.

“Sub-processor” means any entity which processes customer data on behalf of Piccopay.

“Merchant Solutions” means products and services defined by Piccopay.

WEB BROWSER COOKIES

Piccopay use "cookies" to enhance Users’ experience and log monitoring. For website and web applications, User's web browser places cookies on their hard drive for record- keeping purposes, faster access due to cached information, and tracking purposes. Users may choose to set their web browser to refuse cookies, delete or clear browser history. Users may opt-out but note that some parts of the website and web applications may not function properly. There is a Cookie Policy covering all about "cookies".

HOW PICCOPAY USES AND PROCESSES COLLECTED INFORMATION?

Piccopay can have a role as Controller when processing user and customer data when it provides merchant solutions, online systems, web portals, and mobile applications.

Piccopay can have a role as a Processor when processing customer data for and in behalf of the customer.

Piccopay can have a role as a Sub-processor when processing customer data for and in behalf of the Customer’s customer.

Customer or Customer’s customer Processing of Customer data upon using the products and services of Piccopay process customer data in accordance with the requirements of the Data Protection Laws and Regulations. Instructions for processing to Piccopay shall comply with Data Protection Laws and Regulations. Customer (as Controller of Customer Data) shall have the sole responsibility for the accuracy, quality, and legality of the Customer Data and the means by which Customer acquired the Customer Data and ensuring that disclosure of the Customer Data to and the Processing of the Customer Data in order to provide the Services in accordance to the agreements and the Data Protection Laws and Regulations. The customer shall be responsible for the acts of its Users or Customers.

Piccopay’s Processing of Customer Data in accordance to the Data Protection Laws and Regulations.

Piccopay use information for the following purposes:

● To run and operate the online systems, web and mobile applications, and website

● To improve customer service in response to customer service requests and support needs more efficiently

● To personalize user experience in the aggregate to understand how Users as a group use the services and resources

● To improve the online systems, web and mobile applications, and website through feedback provided

● To run a promotion, contest, survey or other features the Users have agreed to receive about topics we think will be of interest to them

● To send periodic emails for updates pertaining to the services, orders, and transactions availed or processed. It may also be used to respond to their inquiries, questions, and/or other requests

● To process a valid transaction (payments, exchanges, finance related) requested from and in behalf of a client (merchants, payment institutions, networks, or banks)

Piccopay processes these information on our servers located in different parts of world or contracted third-party processors (as to payment institutions, networks, or banks) and it may or may not in the country where the data subject or user lived.

Piccopay respectively may engage third-party Sub-processors in connection with the provision of the Services provided that Piccopay or data protection obligations no less protective than those in the agreement with respect to the protection of customer data to the extent applicable to the nature of the services provided by such Sub-processor.

HOW PICCOPAY GRANTS CHOICES OVER THE COLLECTED INFORMATION?

Piccopay collects the data subject’s personal information to efficiently carry out and administer its services with zeal. Thus, the data subject’s personal information is required in any of the following Piccopay transactions:

● Check the identity of the data subject to prevent money laundering or other unauthorized transactions

● Outsource limited operational assignments to an authorized third party

● Exercise terms and conditions as stated in the contract and agreed by both data subject and Piccopay

● Assist other financial institutions to conduct the data subject’s request of transactions or inquiries about failed transactions

● Introduce new services and products of Piccopay to the data subject by direct mailing, e-mail, questionnaires, or other marketing methods

● Improve the relationship between Piccopay and data subject

Before collecting the required information, Piccopay asks for consent that certain information will be collected from the data subject or User with the clear purpose made known to the data subject why Piccopay would like to collect such information. There will be notifications if Piccopay is processing the collected information, for instance, in a financial transaction and in cases where the purpose of processing has changes and amendments.

The collected information can be accessed using a web or mobile applications especially those who created a user account to avail the products and services of Piccopay. Login or sign-in using the credentials provided and do the following:

● Update these information

● Review and display the details

● Download these information in readable format

● Request these information for permanent deletion

● Withhold or revoke consent to process the personal data with basis as specified Data Protection Laws and Regulations

For information Piccopay collected through offline and manual means, access, update, and remove should be requested through email at support@piccopay.sg.

Piccopay being a Processor of the Customer, should notify the Customer of any related Data Subject Requests to Piccopay pertaining to its rights as defined by Data Protection Laws and Regulations and assist the Customer to its fulfillment. In cases that Piccopay incurred costs in the assisting the Customer, the Customer shall responsible of the costs. In the event of regulatory requests, Piccopay shall notify its Customer or Users of any legally binding request for disclosure of Customer or User Data by law enforcement authority unless otherwise prohibited, such as prohibition under criminal law to preserve the confidentiality of a law enforcement investigation.

HOW WE PROTECT YOUR INFORMATION?

We adopt appropriate data collection, storage and processing practices, and security measures to protect against unauthorized access, alteration, disclosure, or destruction of User’s personal information, username, password, transaction information, and data stored in using Piccopay's online systems, web and mobile applications, and website.

Piccopay ensures that any person that it authorizes to process Customer Data or User Data including its employees, agents, and subcontractors shall subject to a duty of confidentiality that shall to the extent permitted by law survive for 5 years after the termination of their employment, contractual, and agreement.

Piccopay obtains third-party certifications and audits applicable in processing Customer Data and User Data. If requested and applicable, Piccopay provides the most recent third-party certifications and audits.

Piccopay maintains security incident management policies and procedures and shall notify Customers and Users without undue delay after being aware of accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to Customer or User Data transmitted, stored, or otherwise processed by Piccopay or Piccopay’s Sub- processors. Piccopay shall do reasonable efforts to identify cause and remediate to the extent the remediation is within Piccopay’s control. This obligation is not applicable if the incident is caused by Customers or Users.

SHARING PERSONAL INFORMATION

Piccopay does not sell, trade, or rent Customer Data and User’s personal identification information to others. Piccopay may share generic aggregated demographic information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes of business intelligence on how we can improve as a company and our products and services.

In the event of regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure.

If an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business.

ELECTRONIC NEWSLETTERS

If Users decide to opt-in to a mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, Piccopay includes detailed unsubscribe instructions at the bottom of each email or the User may contact us via company's product and service official communication channels or contact details published through website and publications.

COMPLIANCE WITH CHILDREN'S ONLINE PRIVACY PROTECTION ACT

Protecting the privacy of the very young is especially important. For that reason, Piccopay never collects or maintains information from those actually know are under 13, and no part of our website is structured to attract anyone under 13.

Piccopay has the discretion to update this privacy policy at any time. Whenever there are updates, a notification on the main pages of our websites and web applications and on the main screens of our mobile applications will be shown. Also, Piccopay shall send an email to all relevant parties. Piccopay encourages Users to frequently check this page for any changes to stay informed about how Piccopay is helping to protect the personal information collected. Users acknowledge and agree that it is their responsibility to review this privacy policy periodically and become aware of modifications.

ACCEPTANCE OF THE PRIVACY POLICY AND TERMS AND CONDITIONS

By clicking the checkbox or tick-box which indicates as a User have read the Privacy Policy and Terms and Conditions of the service, Users signify acceptance and consent bound by Data Privacy Policy. If the User does not agree with this policy, he/she could not proceed to use the online systems, web and mobile applications, and websites provided by Piccopay.

Piccopay asks for acceptance and consent when the Privacy Policies and Terms and Conditions changes.

CONTACTING PICCOPAY

If there are questions about this Privacy Policy, the practices and dealings with any of Piccopay's data processing, online systems, web, and mobile applications, and websites, please contact us at support@piccopay.sg

This document was last updated on June 23, 2020.