Effective as of March 30th, 2019

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of PayMaster Services.

If you see an undefined term in this Privacy Policy (such as “Custody Account” or “PayMaster Card”), it has the same definition as in our Agreement for Custody Account, Agreement for PayMaster Card, Agreement for Escrow Services and all the Terms and Conditions agreed and mentioned in our Website or Secure Area or other legal documents regulating PayMaster Service to all of which this Privacy Policy is inseparable part.

When this policy mentions “we,” “us,” or “our,” it refers to the respective company, proving PayMaster Services to the Client, under the above mentioned Legal Agreements, that is responsible for your information under this Privacy Policy (the “Data Controller”).

For the purposes of this documents PayMaster Services consist of products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us or mobile apps, online platform, official social media platforms, or other online properties through which we provide custody and escrow services.

We give utmost importance to the protection of personal data of our customers. In the following Privacy Policy, we inform the Client about the collection, use and processing of your personal data when you apply, register or use our PayMaster Service and all functionalities, included in the Service, including our website https://PayMasterllc.com (hereinafter: “Website”), our PayMaster Mobile App, Custody and Escrow accounts and Cards.

  • For the purposes of providing PayMaster Custody Account under the Agreement for PayMaster Custody Account the responsible Data Controller is PayMaster LLC, Company number 1906036, Registered office at Office 10, Level 1, Sharjah Media City, Sharjah, P.O. Box: 414167-Dubai UAE;
  • For the purposes of providing PayMaster Escrow Account under the Agreement for PayMaster Escrow Account, the responsible Data Controller is PayMaster LLC, Company number 1906036, Registered office at Office 10, Level 1, Sharjah Media City, Sharjah, P.O. Box: 414167-Dubai, UAE;
  • For the purpose of providing PayMaster Card under the Legal Agreement for PayMaster Card the responsible Data Controller is PayMaster LLC, Company number 1906036, Registered office at Office 10, Level 1, Sharjah Media City, Sharjah, P.O. Box: 414167-Dubai, UAE;
  • For the purposes of providing online access to the Website secure area for Custody and Escrow Account on PayMaster Platform under the User Agreement for PayMaster Service the responsible Data Controller is PayMaster LLC, Company number 1906036, Registered office at Office 10, Level 1, Sharjah Media City, Sharjah, P.O. Box: 414167-Dubai, UAE;

Where one of the abovementioned entities is specified as responsible Data Controller we inform you that the other entities specified above are acting as Data Processors of the Date Controller and vice-versa. The ultimate liability lies with the respective Data Controller and you should address all your questions to the respective Data Controller via the contact details specified below.

In case you are using PayMaster Service for your business needs (in example you are opening accounts for trading transactions with other persons), you certify that where you have provided information regarding any person beside yourself you have received prior consent to provide their personal information to us and that you have informed the person for the present Privacy policy, to which the person has agreed.

PayMaster Service is designed for both business purposes and personal use and may be used by individuals or entities. In case you are registering for and/or using PayMaster Services on behalf of an entity we will treat you as authorized person and you may be obliged to disclose to us personal data of the legal representatives, the employees, the agents, the beneficial owners or any other third-party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person beside yourself you have received prior consent from that other person to provide their personal information to us.

Not a Framework Contract: For the avoidance of doubt, this Privacy Policy does not constitute a “framework contract” for the purpose of the EU Payment Services Directive 2 (EU) 2015/2366 or any implementation of that directive in the European Union or EEA (including, without limitation any national laws implementing the EU PSD).

  1. WHAT INFORMATION WE COLLECT

You are informed that there are three general categories of information that is collected from you differentiated on grounds.

1.1 Information That We Collect In Order To Perform Our Legal Obligations and In Order To Provide PayMaster Service As Part Of Our Contract With You

We ask for and collect from you the following personal information when you use the PayMaster Service.

This information is necessary for us to comply with our regulatory obligations and for the adequate performance of the contract between you and us. Without it, we may not be able to provide you effectively with PayMaster Service for which you enrol.

  • Registration and Use of Account Information. When you sign up for PayMaster Service, we require certain personal information such as:
    • First name and surname
    • Date of birth
    • Place of birth
    • Email address
    • Nationality
    • Registered address
    • Mobile telephone number
    • Identification document and all data from the identification document
    • Type of identification document
    • Issue date
    • ID number
    • Issuing authority

And other data which we may choose to collect in our enrol forms, which is necessary for your identification and verification.

  • Identity Verification Information. In accordance with our legal obligations under the relevant Anti-money laundering and anti-terrorism financing regulations, we are obliged to verify your identity or the identity of the authorized user who is opening the Account (in case of company or other entity, referred to as “user opening the Account”).

We comply with this legal obligation by means of certified documents validation and other procedures for verification in compliance with applicable AML laws. During the enrolment phase, in order to fully comply with the relevant Anti-money laundering and anti-terrorism financing regulations, we must take:

– IDs of the user registering for PayMaster Service; and

– all the documents necessary to understand the signatory powers and the final beneficial owner of the funds.

For the same purposes you or user opening the Account you might have to allow us to download and read the chip embedder in the Passport/digital copy of the Passport (referred to as ePassport) if applicable. The personal data stored in the ePassport or other official ID document will be read and encrypted via NFC technology.

  • Tax information. In order to comply with CRS/FATCA regulations, we are required to collect your Tax Identification Number (“TIN”), Country of Tax Residence and status (active or passive business). We might be required to disclose this information to its supervising tax authorities.
  • Risk and Fraud related information. In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations we collect personal data regarding you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you.

For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off PayMaster Service through partnerships, or about your experiences and interactions from our partner and networks.

  • Source of income, annual estimate over the account, business activity details. In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations we collect personal data regarding you related to your sources of income and any other similar financial information about you which would help us prevent money laundering and/or terrorism financing.
  • Payment Card-related information. We collect information about your payment cards, which we have issued to you or which are issued to you by third-party issuers and are linked to your account. The information may be as follows: address of delivery of card, card number (PAN), issue date, expiry date, IBAN or other payment account identifier to which card is linked to, currency, card transaction data, spending limits, expired cards’ details, SMS or other communication which the cardholder has received or has initiated with us, card status history, date of activation, linked cards or duplicates.
  • Log data and device information. We automatically collect log data and device information when you access and use the PayMaster Service, even if you have not created a PayMaster Account or logged in. That information includes, among other things: details about how you’ve used the PayMaster Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the PayMaster Platform. We collect this information in relation to our legal obligation to provide you with secure methods of controlling your financial assets and your personal data.
  • Payment Transaction Information. We collect information related to your payment transactions under PayMaster Service for example when you process payments related to the Escrow Account, or you credit your Custody Account, or we process payments related to your Escrow Account, or you withdraw your assets.

The payment transaction information may include the payment instrument’s details used, date and time of transactions performed by you, amount of payment transaction, payment instrument expiration date and billing postcode, email address, IBAN or other account identifier information, your address and other related transaction details.

This information is necessary for the adequate performance of the contract between you and us and to allow us to provide you effectively the custody and escrow services.

  • Participant information – When you use our PayMaster Service, we collect Personal Data you provide us about the other participants associated with the transaction. Particular payment transaction information may include:
    • Send money: When you send money through our escrow service, we collect Personal Data such as name, postal address, e-mail, telephone number, and financial account information about the person who is receiving money from you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send money.
    • Add value to your accounts: If you use PayMaster functionalities to add value to your Account or any other account you may have, or if you ask a third party to add value to any of these accounts, we may collect personal data from you about the other party, or from the other party about you to facilitate the request.
    • Money transfers to or from other Financial institutions: If you use PayMaster functionalities to transfer money to accounts held with other Financial institutions we may collect personal data from you about the other party, or from the other party about you to facilitate the payment transaction, or provide the other Financial institutions with your Identity verification information. This is our obligation under AML regulation.

1.2 Information That We Collect With Your Consent

You may choose to provide us with additional personal information in order to obtain a better user experience when using PayMaster. This additional information will be processed based on your consent.

  • Other Information. You may choose to provide us information when you fill in a form, conduct a search, update or add information to your PayMaster Account, respond to surveys, participate in promotions, or use other features of the PayMaster Service.