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    Privacy policy

    Privacy policy#

    This privacy policy (“Policy”) describes how FBPay, a.k.a. FB CRYPTO TECH CO., LIMITED(“FBPay” “Company”, “we”, “our”, “us”) collects, uses, shares, and
    stores personal information of users of this website, www.FBPay.com (the “Site”) and
    users of the FBPay widget and API (together, the “Software”), which can be used to
    interact with various third parties that offer fiat-to-cryptocurrency conversion services
    (“Fiat Gateways”). Use of the FBPay widget, API, or any of the software components
    built by FBPay shall be further referred to as usage of the Software. By using the
    Software, you (the “End User” / “You”) accept the terms of this Privacy Policy and our
    Terms of Use, and consent to our processing, use, disclosure, and retention of your
    information as described in this Policy.

    What Personal Information do we collect?#

    We do not currently collect any personally identifiable information from you directly. However, we still collect data that, while it doesn’t qualify as personally identifiable
    information, is treated with the highest standard of care. The (categories of) data we may, now, or in the future, process are:
    Transactional Data: information about your transaction history with Fiat Gateways,
    incl. the type of virtual financial assets involved, the order volume, price, value, and
    information on which bank is used for a transaction identified through the processing
    of a part of your credit card number. This does not include any Personally
    Identifiable Information.
    Information we collect automatically about how you use our Site and/or Software,
    (“Product Usage Data”), including information on the device(s) you may use (“Device
    Information”) and information on when, where and how you use our Site and/or
    Software, including your IP address and info such as your browser type (“Log Data”). For a more specific overview of what information is collected automatically, see the
    section named ‘Cookie Policy’ below.
    The processing of any other data inserted by End-users when making use of services
    provided by Fiat Gateways is governed by the privacy policies of the individual Fiat
    Gateway(s) used by the End User. With regards to this data, FBPay does not act as a
    data controller.
    While FBPay does not collect any personal information from you, the Fiat Gateways do, as covered by their privacy policies. Those Fiat Gateways may share data with FBPay. This can include your phone number, country, your email address and your name, but
    does not include credit card numbers or any other PAN or CVC data.

    What do we use your data for?#

    We may process Usage Data, Transactional Data, Device Data, and Log Data for us
    to:
    perform user analytics to keep track of usage and better understand our users; carry out research and development to improve our Site and/or Software,
    identify IT or network issues,
    identify mal-intended usage of our Site and/or Software,
    manage our Site and/or Software, system administration, and security,
    provide actionable data insights to Business Users,
    improve the way Fiat Gateways are selected and shown to the users,
    prevent fraud, money laundering or unauthorized use of our Software, and to customize the content and layout of the Websites.

    What is the legal basis for the processing of your data?#

    The processing of your Product Usage Data, Transactional Data, Device Information, and
    Log Data occurs for the purposes described above, based on our legitimate interests. These interests include improving, maintaining, providing and enhancing our Site and
    Software, our marketing interests, our need to contact Business Users with regards to
    use of our API/widget, our interests concerning ensuring the security of the Software and
    our Site, as well as our legitimate interest in being able to provide data insights to
    Business Users. We limit our collection of processing of data to what is necessary for
    these purposes, and this processing of personal information for our legitimate interests is
    not disproportionate to your data-protection interests, fundamental rights, and/or
    freedoms.
    The processing of personally identifiable information, and any other information filled in
    by the End-User, as well as some transactional data, is covered by the privacy policies of
    the various Fiat Gateways. FBPay might process information as a data processor on
    behalf of the Fiat Gateway (the data controller).

    Do we share or transfer personal information with or to third parties?#

    In alignment with the purposes of processing, we share or transfer data with the following
    third-parties:
    Google Analytics Data (Product Usage Data) gathered because of your usage of our Site might be stored on Google Analytics’ servers.
    We may provide Business Users with access to Transactional Data to provide them with actionable data insights.
    All other data is stored using Amazon Web Services, Snowflake and Thoughtspot.
    Again, note that all data processing regarding personal information inputted by
    End-Users to make use of services provided by Fiat Gateways is governed by the privacy
    policies of those individual Fiat Gateway(s) used by the End User. As such, even though
    FBPay may act as a data processor for those Fiat Gateways, all information regarding
    that processing of data is determined and provided by those Fiat Gateways in their
    privacy policies.

    How is your personal information retained and secured?#

    FBPay does not itself store any cardholder information and does not qualify as a
    processor, merchant, or service provider as described under Payment Card Industry
    Data Security Standards (PCI DSS). While FBPay does not come under the scope of
    PCI-DSS, our existing security program already addresses many of its concerns. As we
    evolve our security program and processes, we will continue to assess the benefits of
    obtaining compliance.
    We employ industry-standard security measures designed to protect the security of all
    information submitted through the Software. Information gathered to use Google
    Analytics as described in this privacy policy, is stored by Google Analytics, which has
    earned the independent security standard ISO 27001 certification.
    Any information processed on, or through, Amazon Web Services are similarly secure by
    way of compliance with applicable industry-standard certifications and best practices. AWS has achieved numerous internationally-recognized certifications and accreditations, demonstrating compliance with rigorous international standards, such as ISO 27017 for
    cloud security, ISO 27701 for privacy information management, and ISO 27018 for cloud
    privacy, as well as SOC 2 and SOC 3 compliance.
    Snowflake ’ s government deployments have achieved Federal Risk & Authorization
    Management Program (FedRAMP) Authorization to Operate (ATO) at the Moderate level.
    In addition, support for ITAR compliance, SOC 2 Type 2, PCI DSS compliance, and
    support for HITRUST compliance all validate the level of Snowflake security required by
    industries, and state and federal government.
    ThoughtSpot has successfully completed the Service Organization Control (SOC) 2 Type
    II audit. The SOC 2 report verifies the suitability of the design and operating effectiveness
    of ThoughtSpot’s information security practices, policies, procedures, and operations to
    meet the standards for security, availability, and confidentiality. The ISO/IEC 27001:2013
    certification specifies security management best practices and controls for establishing,
    implementing, maintaining and continually improving an information security
    management system (ISMS) – the aim of which is to help organizations make the
    information assets they hold more secure. It ensures that our ISMS is fine-tuned to keep
    pace with changes to security threats, essential in the fast-paced world of IT security. ThoughtSpot submits to a re-certification audit every third year, inclusive of an annual
    surveillance audit.
    We are not responsible for any interception or interruption of any communications
    through the internet or for changes to or losses of data. Users of the Software are
    responsible for maintaining the security of any password or another form of
    authentication involved in obtaining access to password protected. To protect you and
    your data, we may suspend your use of any of the Software, without notice, pending an
    investigation, if any breach of security is suspected.

    For how long is my data retained?#

    There’s no personally identifiable data collected by FBPay itself. All personal data that is
    shared with FBPay by Fiat Gateways will be retained for a maximum of 24 months, or
    shorter where such data are no longer required for the purposes for which they are
    processed.

    What are my rights relating to my data?#

    Under the European General Data Protection Regulation, you have certain rights
    regarding your personal information. You may ask us to take the following actions
    concerning your personal information that we hold:
    Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you important Service-related and other non-marketing communications.
    Access. Provide you with information about our processing of your personal information and give you access to your personal information.
    Correct. Update or correct inaccuracies in your personal information.
    Delete. Delete your personal information.
    Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
    Restrict. Restrict the processing of your personal information.
    Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
    You can submit these requests by email to support@FBPay.cc. We may request specific
    information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your
    request, we will tell you why subject to legal restrictions. If you would like to submit a
    complaint about our use of your personal information or response to your requests
    regarding your personal information, you may contact us at support@FBPay.cc or submit
    a complaint to the data protection regulator in your jurisdiction.

    Cross-Border Data Transfer#

    Please be aware that your data might be transferred to, processed, and stored in the
    United States or other non-EEA jurisdictions. Whenever we transfer your personal
    information out of the EEA to the U.S. or countries not deemed by the European
    Commission to provide an adequate level of personal information protection, the transfer
    will be based on a data transfer mechanism recognized by the European Commission as
    providing adequate protection for personal information.

    Cookie policy#

    For the processing of Product Usage Data, Device Data and Log Data, and the use
    thereof as described above, we may use cookies. Cookies are small files that are stored
    on a user’s computer. They are designed to hold a modest amount of data specific to a
    particular client or website and can potentially be accessed by us, as well as your
    personal computer.
    Cookies could allow us to collect data automatically (some of which might be considered
    personal information. Cookies are either“session”cookies which are deleted when you
    end your browser session, or “persistent” cookies, which remain until their deletion by
    you (discussed below) or the party who served the cookie. Some Cookies are necessary
    for certain uses of the Site, and without such Cookies, we would not be able to provide
    you with functional access to the Site and/or Service. These ‘Necessary Cookies’
    could, for example, enable us to remember your previous actions within the same
    browsing session and secure our Sites. They could also allow us to, for instance, deliver
    a page tailored to a user, based on the device you are using and the location you are in. Specifically, they allow us to save your cookie preferences!
    Aside from this functional purpose, we mainly use cookies for the analytical purposes
    described in the section on ‘How we use your personal information above’. These ‘Analytical Cookies’, which allow us to use Google Analytics, may process and store
    information such as a user’s Internet Protocol (IP) address, internet service provider, device and browser type, browser version and settings, language preference, cache
    preferences, operating system, platform, device identifier, device type and manufacturer,
    location information, demographics, the pages or features of our Site and/or Service to
    which a user browsed and the time spent on those pages or features, the frequency with
    which the Site and/or Service is used by a user, search terms, the links on our Site that a
    user clicked on or used, timestamps and other statistics.
    We may also use Google Analytics to help us offer you a better-optimized user
    experience. You can find more information about Google Analytics’ use of your data
    here.
    Necessary cookies are crucial for the basic functions of the website and the website will
    not work in its intended way without them. These cookies do not store any personally
    identifiable data.
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    Analytical cookies are used to understand how visitors interact with the Site or Software. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc. and help us optimize the Site or Software.
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    How to disable Cookies?#

    Most internet browsers are initially set up to automatically accept cookies. If you do not
    want our websites to store cookies on your device, you can change your browser
    settings so that you receive a warning before certain cookies are stored. You can also
    adjust your settings so that your browser refuses most of our cookies or only certain
    cookies from third parties. You can also withdraw your consent to cookies by deleting
    the cookies that have already been stored.
    If you disable the cookies that we use, this may impact your experience while on the
    Unilever website, for example, you may not be able to visit certain areas of a website or
    you may not receive personalized information when you visit a website.
    If you use different devices to view and access the Site and/or Software (e.g., your
    computer, smartphone, tablet) you will need to ensure that each browser on each device
    is adjusted to suit your cookie preferences.
    The procedures for changing your settings and cookies differ from browser to browser. If
    necessary, use the help function on your browser or click on one of the links below to go
    directly to the user manual for your browser.
    To find out more about cookies, including how to see what cookies have been set on
    your PC and how to manage and delete them, visit www.allaboutcookies.org.

    Contact info#

    Email address: support@FBPay.cc
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