Privacy Policy

This Privacy Policy applies solely to the information collected through the [please provide the final link] (referred to as the "Platform").

In this Privacy Policy, the terms "Platform," "we," and "us" refer to QUAILPAY LIMITED, a registered company in British Columbia, Canada with the company number BC1275630 and its registered office address at 308-8988 Fraserton Court, Burnaby, BC, Canada, postal code V5J5H8 ("Company").

Any information collected about visitors of the Platform by Quailpay is referred to as "User information".

The types of User information we collect:

We may collect and process the following categories of data, but this list is not exhaustive:

Personal data:

This includes personally identifiable information that can identify a User as an individual, such as first and last name, email address, telephone number, date of birth, ID number, tax number, billing address, registered address, nationality, and any other information that, alone or combined with other data, can identify a User.

Non-personal data:

Information about your visit to the Platform, including traffic data and location data. Demographic information such as age, gender, and country. Information submitted voluntarily through surveys on various topics, including events, experiences, media consumption preferences, and feedback to improve the Platform. Information about organizations, such as businesses. Anonymous information that cannot be linked back to an identifiable person. Information from the content of messages submitted through fillable forms on the Platform, such as feedback. Information from public postings, including comments or reviews submitted to be displayed on the publicly viewable area of the Platform.

Please note that there is no expectation of privacy or confidentiality regarding content submitted as comments or reviews, whether or not it contains personal information.

Quailpay does not collect or process sensitive personal data, including information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or union/community membership.

User information may be collected:

When a request for Account opening is submitted via the Platform. When information is provided by filling in forms on the Platform (e.g., registering for newsletters, subscribing to updates, etc.). When surveys are completed for research purposes. When communication is initiated through the "Contact Us" forms on the Platform or email.

This Policy only applies to information collected through the Platform and does not apply to information collected by Quailpay offline, through other means, or from any third-party sources, including applications or content accessible from or on the Platform.

The use of User information:

We process User information for the following purposes: Providing the Services available on the Platform that you voluntarily choose. Compliance with applicable laws related to the Services provided to and used by Users. Responding to inquiries or requests. Improving the contents and operation of the Platform. Analyzing information to enhance the service and user experience based on user preferences. Complying with regulatory obligations. Providing information related to newsletters or seeking feedback if you have subscribed or signed up. Other purposes permitted by law.

All information, regardless of category, is provided by Users with explicit consent voluntarily for the purpose of using the Services offered through the Platform.

Direct marketing communications:

We will only send updates and news if you have provided your consent and details for this purpose. You can opt out of direct marketing emails at any time by clicking the "unsubscribe" link in the email or by requesting to unsubscribe from a newsletter through the provided support email – [please provide].

Retention of User Information

User Information will be deleted:

• Once it is no longer necessary for the purpose for which it was collected.
• Upon your request for deletion of your Personal data, unless there is a legal obligation for Quailpay to retain such data.
  
  If you are a resident of the EU/EEA and provide this information while using the Platform, we will ensure that your Personal data submitted on the Platform is protected in accordance with the provisions of The General Data Protection Regulation.

Quailpay Profiling and Automated Decision Making

Profiling refers to the automated processing of personal data to analyze or predict specific personal characteristics such as economic situation, preferences, interests, and place of residence.

We utilize profiling based on the personal data we have about you to make individual or automated decisions for the following purposes:

Decisions without legal or similarly significant effect:

Quailpay makes the following decisions without legal or similarly significant effects for you:

Predicting marketing content that would be of interest to you. You can object to this and opt-out of the marketing and profiling by contacting us.
Deciding on the most suitable way to contact you regarding outstanding debt. Decisions with legal or similarly significant effect:

Automated decision making with legal effects, or automated decisions with similarly significant effect, means that certain decisions in our services are made solely based on automatic means, without any involvement of our employees, and have a significant impact on you as a consumer. By making such decisions in an automated manner, Quailpay enhances objectivity and transparency in the decision-making process.

We employ this type of automated decision making when we:

Decide whether to approve your application. Decide not to approve your application. Determine whether you pose a risk of fraud or money laundering based on our processing of data. This includes identifying behavior consistent with money laundering or fraudulent conduct, inconsistencies in your previous use of our services, or deliberate attempts to conceal your true identity. In relevant cases, Quailpay also checks if a customer is listed on a sanction list. Any fraud or money laundering risk will be retained by fraud prevention agencies and may result in other entities refusing to provide services, financing, or employment to you. You always have the right to challenge an automated decision that has a legal or similarly significant effect (along with the associated profiling) by contacting us using the email provided for support.

Sharing User Information with Third Parties

Quailpay may share your User Information with third parties under the following circumstances:

• When required by law.
• To ensure the provision of the Services you use.
• To facilitate the proper operation of the Platform (including customer service and marketing assistance, business and sales analysis, supporting Platform functionality, surveys, and other features offered through the Platform).
• When there is another legitimate interest.
  
  Any collected data may be shared, if necessary, with Quailpay's offices and third parties who provide services on our behalf, limited to the extent of the consent you have provided. User Information that we collect may be transferred within our offices in British Columbia, Canada (or outside the province and country).
  
  Quailpay does not sell or rent any collected information to third parties. When we share your personal data, we take reasonable contractual, legal, technical, and organizational measures to ensure adequate protection and compliance with applicable laws.
  
  To provide an idea of whom User data may be shared with (not an exhaustive list):
• Suppliers and vendors:
  We may share personal data with the suppliers and subcontractors we use to provide our Services to you. Suppliers and vendors are companies authorized to process the personal data they receive from Quailpay on our behalf. Examples include software providers, data storage providers, payment processing services, and business consultants.
• Payment service providers and financial institutions:
  Payment service providers assist Quailpay in accepting and managing electronic payments through various methods such as credit cards, direct debits, and bank transfers. These providers may collect and use your information independently according to their own privacy policies.
• Fraud prevention agencies and identity verification companies:
  To verify your identity, ensure data accuracy, and prevent criminal activities, your personal data may be shared with fraud prevention agencies and companies conducting identity checks. These agencies can retain your data for different periods if you are suspected of posing a fraud or money laundering risk. Quailpay and fraud prevention agencies may also cooperate with law enforcement agencies to detect, investigate, and prevent crime.
• Authorities:
  Quailpay may disclose relevant information to authorities, including the police, tax agencies, or other government entities, if mandated by law. This may occur for purposes related to anti-money laundering, counter-terrorist financing, your specific request, or tax administration requirements.
  
  While it is unlikely, Quailpay might be obligated to share User Information in response to a court order, subpoena, or government investigation. Additionally, in cases such as mergers, restructuring, dissolution, sale, or asset transfers involving Quailpay, User Information may be shared. In such instances, the information will only be used for the stated purposes and in compliance with your consent and data protection obligations.
  
  User Information will only be shared with employees, agents, and third-party providers on a need-to-know basis, and they will be bound by non-disclosure agreements.
  
  You have the right to request a list and categories of your Personal data shared with third parties by contacting Quailpay's support email - [please provide]. The Platform may contain links to other platforms operated by different companies that are not governed by this Privacy Policy. Quailpay does not hold responsibility for the privacy practices of third-party platforms, and it is advisable to directly contact them to learn about their privacy policies.

Use of Cookies:

Quailpay employs a web analytics service to analyze and track activity on the Platform. This service utilizes cookies, which are files placed on your computer's hard drive to monitor how visitors interact with the Platform.

We use first-party cookies to collect information such as language preferences and login details. Additionally, third-party cookies are employed by web analytics for marketing and advertising purposes.

Enabling cookies allows certain User Information to be collected, including browser type, operating system, network location, IP address, referrer data (identifying previously visited and subsequent web pages), and activity within the Platform. This information, referred to as Non-Personal Information, does not include personally identifiable details.

The aggregated User Information is utilized by Quailpay to analyze and enhance the design, functionality, and content of the Platform.

In addition to cookies, Quailpay may utilize other technologies such as web beacons and flash cookies to evaluate the effectiveness of communications and monitor Platform usage.

The Platform provides security measures that allow you to enable or disable cookies. You have the option to accept or decline cookies by adjusting your browser settings. However, disabling cookies may limit your access to certain interactive features of the Platform. Unless you have adjusted your browser settings to refuse cookies, our system will issue cookies when you visit the Platform.

Age Restrictions for Platform Visitors:

As per legal requirements, individuals under the age of 18 are prohibited from using the Platform. We do not knowingly collect User Information from individuals under 18 years old. If you are under 18, please refrain from providing any personal information on this Platform or utilizing its interactive or public comment features. If we become aware that we have collected User Information from someone under 18, we will promptly delete that information.

User Rights Regarding Personal Information

Right to be Informed about Collected and Disclosed Information:

You have the right to request Quailpay to disclose the User Information it collects, uses, and shares with third parties. There are two types of requests you can make:

Right to Know (Abbreviated Request):

Upon making this request, you will receive the following information:

1. Categories of personal data collected
2. Categories of sources from which the data was collected
3. The business or commercial purpose(s) for which the data was collected
4. The third parties to whom Quailpay disclosed the personal data category for a business purpose, along with the purpose for such disclosure.

Right to Know (Specific Pieces of Information Request):

With this request, you will receive specific personal data collected about you. It's important to note that Quailpay does not sell any personal data. This information will be provided to you at no cost, unless your request is deemed manifestly unfounded or excessive.

Right to Deletion:

You have the right to request Quailpay to delete any personal data about you, subject to certain exceptions, upon receiving a verifiable request.

Right to Restrict Processing or Object to Processing:

If you believe your information is incorrect or being unlawfully processed, you can request Quailpay to stop processing your data. You also have the right to object to processing in situations where you believe it would be unlawful. Additionally, you can object to the use of your data for direct marketing purposes.

Right to Challenge Automated Decisions:

If an automated decision made by Quailpay has legal or similarly significant effects, you have the right to challenge it.

Right to Withdraw Consent:

If your data is processed based on consent or explicit consent, you have the right to withdraw your consent at any time.

Right to Lodge a Complaint:

You have the right to lodge a complaint with your national supervisory data protection authority. If you are in Canada, you can use the following link to file a formal privacy complaint with the Office of the Privacy Commissioner of Canada: https://priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/file-a-complaint-about-a-business/.

We encourage you to contact Quailpay if you have any doubts regarding your privacy rights or if you wish to exercise any of the rights mentioned above. You can reach us via email at [provide support email].

Data Breach Notification

Quailpay is committed to safeguarding User Information, but in the event of a data privacy breach, Quailpay will promptly address the breach and notify affected individuals in writing.

Quailpay will not discriminate against you for exercising your rights related to personal data.

Modifications to Privacy Policy

Date Last Modified: June 26, 2023

To enhance the services we provide, Quailpay may expand its information collection capabilities in the future. If we make changes to this Privacy Policy, we will update the "Date Last Modified," and the revised policy will become effective upon posting.

Regardless of any modifications to our Privacy Policy, we will handle your User Information in accordance with the version of the policy in effect at the time you provided your information, unless you explicitly consent to other uses.

It is advisable to review this Privacy Policy regularly to stay informed about any updates.

Consent

By using this Platform, you consent to the collection and use of information as outlined above. If you believe that we are not adhering to this Privacy Policy, please contact us promptly at [provide the support email].

If you do not agree with this Privacy Policy, please discontinue using the Platform.