US Privacy Policy

Last Updated: May 2, 2022

Welcome to the CarbonPay Privacy Notice. CarbonPay Inc (referred to as “CarbonPay” or “we” or “our“) respects your privacy and is committed to protecting your Personal Data. This Privacy Notice will inform you as to how we look after your Personal Data when you visit https://carbonpay.io (“our Website”) regardless of where you visit it from and tell you about your privacy rights. Our Website is only intended for business customers, and is not intended for individual consumers.

This Privacy Notice, together with our terms and conditions and any other documents referred to in it, describes how we collect and process your Personal Data through your use of our Website, including any data you may provide through our Website as part of our online application process, by signing up for our communications or other marketing material, by submitting a query, or by using other online services. Please read the following carefully to understand our views and practices regarding how we handle Personal Data.

Our Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or their collection of your data. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Personal Data We Collect:

Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of Personal Data about you which may include the following categories:

• Identity and Background Data includes first name, last name, username, or similar identifier, title(e.g., Mr., Mrs., Miss, etc.), business title (e.g., President, etc.), and date of birth. In addition, we may as part of our legal obligations under anti-money laundering legislation, require information in respect of any criminal records, sanctions, or embargoes.
• Contact Data includes billing address, email address, and telephone numbers.
• Financial Data includes bank account and payment card details.
• Access Data includes username, log in, and password details for your Bank Account, Card Processor Account and other third party services, provided by you to us as part of the Online Application Process.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us, and may include information we receive about you when our payment service provider settles a payment on your behalf and /or from your bank in the event there is a failed payment.
• Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform information, and other technology on the devices you use to access our Website.
• Profile Data includes your username and password, service purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our Website; products, services or issues you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the site. This information is collected by using cookies and similar technologies.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

We do not collect details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic, and biometric data.

It is important that the personal data we hold about you is accurate and current so that we can provide you with services and important notices. If your Personal Data changes during your relationship with us, please contact us at [email protected].

How is your Personal Data collected?

We use different methods to collect Personal Data from and about you including through:

Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us by mail, phone, email, or otherwise. This includes Personal Data you provide when you:

• Create an account on our Website;
• Engage in the online application process;
• Subscribe to our communications or other marketing materials;
• Enter a promotion or survey;
• Apply for a job in our “Careers” section;
• Give us feedback; or
• Submit a query through the Contact Us form.

Automated technologies or interactions: As you interact with our Website, we may automatically collect Personal Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. Please see our cookie policy below for further details.

Third parties or publicly available sources: We may receive Personal Data from providers of technical, payment and delivery services, such as Plaid.

How we use your Personal Data

We may use your Personal Data for the following business or commercial purposes:

To measure the adequate performance of our contract with you, for:

• Managing such contractual relationship between you and us;
• Enabling you to access and use our Website, and
• Enabling you to use the CarbonPay card.
• Where this is necessary for purposes which are in our legitimate interests (or those of a third party). These interests are:
• Facilitating the creation, securing, and maintaining, of your account on our network; and
• Improving the quality of experience when you interact with our services.
• For purposes which are required by law, including responding to requests by government or law enforcement authorities conducting an investigation.
• Security and fraud detection, including detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
• Debugging, including identifying and correcting errors to our system and services.
• Audits, including reviewing current interactions with you and related transactions.
• As part of a merger, acquisition, bankruptcy or other transaction.

Disclosures of your Personal Data

We may share your Personal Data with our service providers, subsidiaries, and/or affiliates and also with trusted third parties including:

• Certain APIs to provide you with an improved customer journey including Plaid.
• Certain credit insurance companies for the purposes of making credit decisions and underwriting the transaction.
• Cloud data hosting service providers.
• Third party card processing and merchant acquiring companies that will process your debit card payments for us.
• Visa, for the purpose of facilitating partnerships of Carbon with certain brands in order to monitor spending and to provide subsequent offers to customers.
• Analytics and search engine providers that assist us in the improvement and optimization of our site.
• Debt collection companies we have appointed where you fail to make a payment to us despite several notifications to you.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

We do not share your Personal Data for marketing purposes or to marketing companies.

Cookies and Do Not Track Signals

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

We use necessary cookies that are required for the operation of our website and application, for example cookies that enable you to log into secure areas or make use of e-billing services.

We may also use cookies to collect information about your computer, including your IP address, operating system and browser type, for system administration and to report aggregated information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may collect information about your use of our website, such as pages visited, links clicked, non-sensitive text entered, and mouse movements.

Our purpose in collecting this information is to better understand how CarbonPay’s visitors use our website and to identify any usability problems, so that we may make the necessary improvements to enhance our visitors’ experience in the future. When we collect this information, your identity will remain anonymous and we do not use this information to identify you.

We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.

They help us to improve the Website and to deliver a better and more personalised service. They enable us:

• To estimate our audience size and usage pattern;
• To store information about your preferences, and so allow us to customise our site according to your individual interests;
• To speed up your searches; and
• To recognise you when you return to our site.

Most web browsers offer users controls, to give you the option to delete or disable cookies. You can usually find out how to do so by referring to the ‘Help’ option on the menu bar of your browser, or by visiting the browser developer’s website. This will usually tell you how to prevent your browser from accepting new cookies; notify you when you receive new cookies; and disable cookies altogether. Please note that disabling cookies will stop you accessing private areas of the website. Blocking all cookies (including essential cookies) will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

We use Google Analytics to analyse the use of our Website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our Website is used to create reports about the use of our Website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Except for essential cookies, all cookies will expire after a period of one (1) week.

At this time, CarbonPay does not (a) respond to automated signals regarding tracking mechanisms, including “do not track” instructions from your browser; or (b) allow third parties to install software to track users’ online activities over time and across different websites when a consumer uses our Website.

Data Security

We take reasonable steps to protect your Personal Data from loss or destruction. Where you have a username or password (or other identification information) which enables you to access certain services or parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our site; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.

In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Data Retention and Disposal

We will retain your Personal Data, whether or not your account is active, for as long as we believe it necessary or desirable to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Personal Data that we will not retain will be securely destroyed by shredding, erasing, or otherwise modifying the personal information in the records to make the information unreadable or indecipherable through any means.

Children’s Online Privacy Protection Act Compliance

The Website is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us at [email protected]. If we become aware that a child under 13 has provided us with personal information without parental consent, we take steps to remove such information and terminate the child’s account.

Changes to Privacy Notice

We reserve the right to change our Privacy Notice at any time. If we make changes, we will post them on this page and will indicate the Privacy Notice’s new effective date. Please check this page from time to time to take notice of any changes we make, as your continued use of the Website will serve as your consent to any changes to the Privacy Notice.

Contact

Please contact us at [email protected] if you would like further information on how we use your personal information.