Privacy Notice

Introduction

We value your privacy and are committed to treating your data with respect. This privacy notice (“Privacy Notice”) explains what information we collect about you and how we use, store, share and safeguard it. In this document “we”, “us”, “our”, and “ours” refers to TerraPay. This Privacy Notice applies to you if you have consumed our products and services (directly or via third parties), and/or if you visit www.terrapay.com (the “Website”), which is owned and operated by Terra Payment Services (Netherlands) B.V.


Purpose

TerraPay respects your privacy and is committed to maintaining the confidentiality and security of the information of its existing, prospective and former customers and beneficiaries. This Privacy Notice sets out how we process your information, how we use it and the rights available to you with respect to your information. We encourage you to carefully read this Privacy Notice.


How do we collect your information?

We collect information about you mainly through our business partners/service providers, TerraPay’s Website, and third parties or publicly available sources. This information includes Personal Information as described in this Privacy Notice. To know more about these sources of Personal Information, please refer to the sections below.

Personal Information refers to any information relating to an identified or identifiable individual directly or indirectly, such as name, address, telephone number and email address.


What information do we collect?

TerraPay collects the following information to provide you services through our business partners.

  • Full Name (sender and recipient of the transaction)
  • Address (sender and recipient of the transaction)
  • Nationality (sender and recipient of the transaction)
  • Telephone, including mobile (sender and recipient of the transaction)
  • Relationship between sender and recipient of the transaction
  • E-mail
  • Age
  • Date of Birth
  • Gender
  • Birthplace
  • Labour details
  • Origin of the financial resources
  • Financial background
  • Identification document (e.g. National ID, Driving License, Passport)
  • Bank statements
  • Transaction amounts
  • Bank account details
  • Credit / Debit card numbers
  • Marketing & other contact preferences
  • Purpose of the transactions
  • Relationship

As a payment solutions provider, TerraPay has certain obligations with regards to identity verification, fraud prevention, KYC checks and other similar security purposes. To ensure compliance with these obligations, certain of the Personal Information described above may be collected from, or verified against, third party sources such as government agencies and global regulatory databases.


Why do we use your information?

We use your information for providing services which may include the following:

  • Authorising and processing transactions, including effecting and administering money transfers and ensuring proper payment to the designated recipient of funds.
  • Monitoring and improving our services including Website and its content.
  • Meeting legal, regulatory, self-regulatory, risk management, fraud prevention and security requirements, which may include (among other measures) verifying the identity of the sender and recipient of funds and checking identities against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies. For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.
  • Maintaining business and transaction records for reasonable periods, and generally managing and administering our business.
  • Meeting insurance, audit and processing requirements.
  • Otherwise as permitted or required by law.

Legal basis for processing your information

We will process your information only if and to the extent that at least one of the following applies:

Compliance with Legal Obligations

TerraPay may process Personal Information when necessary to comply with a legal obligation, e.g. Anti-Money Laundering screening and reporting requirements and where required to comply with court order or judicial proceedings.

Legitimate Interests

TerraPay may process Personal Information in pursuance of its legitimate business interests where such processing is necessary, and our interests are not overridden by your privacy rights. For instance, our legitimate business interests may include communication in relation to requested transactions, internal record keeping purposes and fraud prevention.

Contract

TerraPay may process your Personal Information as required to comply with our contractual obligations.


Why do we share your information?

To carry out the processing activities established in this Privacy Notice, TerraPay may disclose your Personal Information to:

  • Data Processors: TerraPay may share your Personal Information with third-party service providers (“Data Processors”), including subsidiaries and affiliates of TerraPay performing services on our behalf, for example, information technology, data hosting, marketing, customer care, fraud prevention, etc. We take steps to ensure that Personal Information processed by Data Processors is protected and not used or disclosed for purposes other than as directed by us.
  • Third-party data controllers/joint controllers: TerraPay may share Personal Information with third parties acting independently from TerraPay as may be required in connection with the services provided to you, for example, any intermediary banks or other financial institutions involved in the transaction of TerraPay services.
  • Successors: If TerraPay is purchased by/sold to a third party, Personal Information held by TerraPay will be transferred to the successor entity.
  • Relevant Authorities: TerraPay may disclose your Personal Information as necessary to meet legal and regulatory requirements. This may include disclosure of Personal Information to government authorities in compliance with suspicious activity reporting requirements under anti-terrorism, anti-money laundering, proliferation financing and similar laws and regulations depending upon the country.

Cross Border information Transfers

In connection with providing services to our customers, we may transfer your Personal Information to destinations outside of the European Economic Area (“EEA”). When transferring Personal Information outside the EEA, TerraPay tries to ensure that security measures and appropriate safeguards are put in place to protect the Personal Information.


How do we protect and store your information?

We respect your privacy and your information is important to us as it is to you. TerraPay takes all reasonable steps to ensure that all information collected through our services and business partners is treated securely and in accordance with this Privacy Notice following strict data protection standards. We limit access to your information to our employees who need to know the information and are bound by confidentiality obligations. We store your information in a secured infrastructure and adopt appropriate standards against its accidental loss or destruction. However, we do not guarantee complete security of your information transmitted over the internet to our Website, application and services. We constantly assess our organizational and technical security measures to protect your information.


How long do we retain your information?

At TerraPay, we retain the personal information as required or permitted by law. In all cases, TerraPay only retains the Personal Information for as long as it is necessary for the purposes described in this Privacy Notice and to be aligned with TerraPay’s data retention obligations. When determining the appropriate retention periods, we will consider different factors, including contractual obligations and rights, our legal obligations, statute of limitations under applicable law, potential disputes, guidelines issued by relevant data protection authorities, and TerraPay’s legitimate business interests.


Your information is your right

You have rights over your Personal Information. In summary, these are:

  • Right to know: You have the right to receive certain information about how your Personal Information is processed.
  • Right to access: You have the right to access and receive a copy of your Personal Information.
  • Right to rectify: You are the owner of your information and have the right to have inaccuracies related to your Personal Information corrected.
  • Right to erase: You have the right to request deletion of your Personal Information in certain circumstances.
  • Right to restrict: You have the right to restrict or limit the way we process your Personal Information in certain circumstances.
  • Right to object: You also have the right to object to TerraPay’s data processing activities.
  • Right to portability: You have the right to ask us for a copy of your Personal Information that you have provided us to be sent to you in a digital/machine readable format or to be sent to a third party/service provider appointed by you.

You are also entitled to lodge a complaint with a regulatory authority in the jurisdiction where you live or work or where you consider TerraPay is processing your Personal Information unlawfully. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please do contact us in the first instance. For more information on your rights, please contact us using the details below.


Changes to this Privacy Notice

We review and update our Privacy Notice from time to time. Therefore, we encourage you to periodically review this page to stay updated.


Contact us

If you wish to exercise any of your rights, or if you want to know about how we use or protect your information or if you have any queries about this Privacy Notice, please contact us at regulatory@terrapay.com