Privacy Policy

Effective 30th September 2020

Captiva Cay Platforms and its partners offer services that enable platforms and business merchants to run businesses, and to safely conduct online payment transactions. This Privacy Policy describes the types of Personal Data we collect through our products and merchant services (“Services”) and via our online presence, which include our main website (our “Sites”). This policy also describes how we use Personal Data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third- parties carefully.

1. Overview

Captiva Cay Platforms may obtain Personal Data about you from various sources to provide our Services and to manage our Sites. If you are a member of the public, Captiva Cay Platforms will generally not collect your Personal Data directly from you. Your agreement with the relevant Captiva Cay Platforms Business Merchant should explain how they share your Personal Data with Captiva Cay Platforms, and if you have questions about this sharing, then you should direct those questions to the Captiva Cay Platforms Business Merchant.

2. Personal Data We Collect

3. How We Use Personal Data

4. How We Disclose Personal Data.

Captiva Cay Platforms does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.

5. Your Rights and Choices.

You have choices regarding our use and disclosure of your Personal Data:

6. Security and Retention.

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organisational, technical and administrative measures designed to protect Personal Data within our organisation against unauthorised access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately. If you are a Captiva Cay Platforms Business Merchant, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you, even if you close your Captiva Cay Platforms account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

7. International Data Transfers.

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.

8. Updates To this Privacy Policy and Notifications.

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a Business Merchant, by contacting you through your Captiva Cay Platforms Account Manager, email address and/or the physical address listed in your Captiva Cay Platforms account.

9. Links To Other Websites.

The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.

10. Contact Us

If You have any questions or complaints about this Privacy Policy, please contact us electronically or send physical mail to: Captiva Cay Platforms 1st Floor, 9 Exchange Place, I.F.S.C., Dublin 1, DO1X8H2, Ireland

[email protected]

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