Last Updated: May 24th, 2018
Bank is in the business of providing banking services to individuals and entities (collectively the “Customers”).
Bank, or one of its affiliates, also maintains a relationship with a principal member of MasterCard International (the “Member Bank”) under which the Member Bank maintains, operates and administers a co-branded prepaid debit card program to facilitate the Bank’s payments.
For the purpose of the relevant data protection regulations, Paxum Bank Limited is the “data controller” of your information. We are located Centre Cross Lane, Roseau, Commonwealth of Dominica. If you have any questions about how we protect or use your data, please email us at firstname.lastname@example.org.
How and What Non-Public Personal Information the Bank Collects
If you visit the Bank’s website (“Site”) for informational purposes only, the Bank will not require you to provide any personal information. You will remain anonymous unless you register for any of our services or otherwise elect to disclose your identity. However, the Bank may collect and store certain visitor data including, but not limited to, browser type, Internet Protocol (“IP”) address, and geo-location information.
At other times, the Bank may collect certain Customer-related personal information, such as:
- If an individual registers for an account with the Bank, the Bank will request information which includes the individual’s name, email address, physical address, country of residence, contact phone numbers, date of birth, tax identification number, employment information, and the Bank may request bank account details and credit and/or debit card details;
- If an entity registers for an account with the Bank, the Bank will request information from certain owners, directors and authorized individuals for the entity which includes those individuals’ names, email addresses, physical addresses, contact phone numbers, dates of birth, and government issued identification numbers;
- Before a Customer utilizes any of the Bank’s services and throughout our relationship with a Customer, the Bank may require a Customer to provide additional information to verify an individual’s identity, address or other data to manage risk and compliance. We may also obtain information from third parties providing services such as identity verification, fraud prevention and similar services;
- If you choose to participate in a customer survey, the Bank may ask for your name, email address and other information required by the particular survey; and
- If you report a problem or submit a customer review, the Bank will ask you to provide information such as your name, email address, and account number.
Additionally, when a Customer has registered for an account with the Bank and logs into the account, the Bank may collect the IP address, standard log-in information and certain geo-location information.
The Bank does not knowingly collect information about any person under the age of 18.
How the Bank Uses the Data It Collects
The Bank will use personal information to conduct certain activities related to a Customer’s use of the Site and to service any account a Customer maintains with the Bank. Such use will include:
- Evaluating a Customer for the Bank services a Customer requests;
- Registering a Customer as a client and opening an account;
- Contacting a Customer to verify or reconfirm the accuracy of the information provided;
- Facilitating payments and transactions as directed by a Customer;
- Verifying the existence and availability of funds;
- Administering a Customer’s account;
- Assisting in the provision of other services or products requested by a Customer;
- Resolving disputes and troubleshooting problems;
- Preventing potentially fraudulent, prohibited or illegal activities and enforcing our contracts with a Customer;
- Complying with legal process such as subpoenas and court orders and performing other duties as required by law;
- Researching the demographics and behaviors of the Bank’s Customers; and
- Reporting to law enforcement authorities if the Bank believes a crime has been committed.
Profiling and Automated Decision Making
We may use some instances of your data in order customize our Services and the information we provide to you, and to address your needs - such as your country of address and transaction history. For example, if you frequently send funds from one particular currency to another, we may use this information to inform you of new product updates or features that may be useful for you. When we do this, we take all necessary measures to ensure that your privacy and security are protected - and we only use pseudonymised data where ever possible. This activity has no legal effect on you.
As part of being a highly technical and innovative Bank, we may use Automated Decision Making (ADM) in order to improve your experience, or to help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.
- The Bank may attempt to place cookies on a computer to track a visitor’s use of the Site;
Most web browsers accept cookies, but the person can change the browser settings so that cookies would not be accepted. However, in this case, some functions may not work.
Sharing Data Outside EEA
In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties such as:
- Business Partners;
- Our Group of Entities or Subsidiaries;
For the performance and execution of any contract we enter into with them or you that are based outside of the European Economic Area. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical and organizational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.
How the Bank Protects the Security of Your Personal Information
The Bank has implemented technical and managerial procedures to maintain accurate, current and complete information as well as to protect personal information from loss, misuse or alteration when it is under the Bank’s control.
Personally identifiable information will be stored on the Bank’s secure servers or stored on third party servers located in secure data centers. The Bank has ensured that or has ensured that third parties maintaining the servers have appropriate safeguards such as firewalls and data encryption and that appropriate physical access controls to the files is enforced. The Bank authorizes access to personal information only for those employees who require it to fulfill their job responsibilities.
Personal information is also password protected so that access is limited to Customers and those with whom a Customer shares their password, the Bank, as well as third party access facilitated by the Bank in relation to performance of the services offered by the Bank.
The Bank has also taken steps to protect the integrity of its Customers’ personal financial information when they initiate a transaction on the Bank’s Site.\
Despite the Bank’s reasonable efforts to protect personal information, the Bank cannot guaranty the personal information will not be accessed, disclosed, altered or destroyed.
How the Bank Shares Your Personal Information with Others
How You Can Update Your Personal Information
You may review and edit your personal information by logging into your account at the Site and/or contacting the Bank directly by visiting our Contact Us page.
Because we're a regulated financial institution, Paxum is obliged to store some of your personal and transactional data for up to 7 years. Only a small number of our employees can see that data, and they'll only look at it if they absolutely need to. We always delete information that we no longer need. And everything we need to keep is subject to the highest levels of security.
Please note: Retention periods could be subject to change, depending on where you live, changes to regulatory requirements, or other legal obligations that we need to adhere to.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to email@example.com or send a letter to The Data Protection Officer, (Centre Cross Lane, Roseau, Commonwealth of Dominica.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to Paxum changes, for example if you change your email address or name, please let us know the correct details by sending an email to firstname.lastname@example.org details above. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent. To opt out of marketing, please send an email to email@example.com
You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances; it is not a guaranteed or absolute right.
You have the right allows you to obtain your personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that personal data to another organization. You may have the right to have your personal data transferred by us directly to the other organization, if this is technically feasible.
You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.
You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make automated decisions of this nature.
By submitting your personal information you consent to the use of that information as set out in this policy.
Where We Store Your Information (Applies to EEA Clients)
How To Contact Paxum