General

This policy is the Privacy Policy of RocaPay. RocaPay and its affiliates (“RocaPay”, “we”, “us”) are committed to protecting and respecting your privacy. "RocaPay" may also refer to the services, products, website, content or other materials (collectively, "Services") provided by RocaPay.

This Privacy Policy applies to the Personal Information RocaPay collects, processes and uses. We define “Personal Information” as information that identifies you as an individual, such as your name, address, e-mail address, transaction information and banking details.

This Privacy Policy aims to inform you of:

(i) the type of Personal Information we may collect about you and how it may be used;
(ii) use of information regarding IP addresses and our use of cookies;
(iii) disclosure of Personal Information to third parties;
(iv) the transfer of your Personal Information within and outside of the European Economic Area (“EEA”);
(v) your ability to correct, update and delete your Personal Information;
(vi) the security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control;
(vii) RocaPay’s retention of your Personal Information.

This privacy notice is aligned with the Personal Data Protection Act (Estonia) and the General Data Protection Regulation (EU).

Collection of information

Information provided by you

We collect information you provide to us directly. The types of information we may collect include:

Company information:

Personal information:

 

Information we automatically collect

When you access or use our Services, we automatically collect information about you. This information is used to provide statistical data about our users browsing actions and patterns, and does not personally identify individuals. This information may include:

(i) Log Information: the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services;
(ii) Device Information: information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information;
(iii) Transaction Information: information about the transactions you complete on the RocaPay website, including the amount of virtual currency associated with a transaction, the types of transactions you execute, and other relevant information.

IP Addresses

We may collect information about your computer, including your IP address, operating system and browser type, for the sake of system administration and reporting aggregate information to our advertisers. This is statistical data about our users browsing actions and patterns and does not identify any individual.

Usage of cookies

We use information collected from cookies to assess the effectiveness of our website, analyze trends, and administer the platform. The information collected from cookies allows us to determine the most visited parts of our site and the difficulties our visitors may experience in accessing our site. With this knowledge, we can improve the quality of your experience on the platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies, and/or a technology known as web bugs or clear gifs (these are typically stored in e-mails) to help us confirm your receipt of, and response to, our e-mails and to provide you with a more personalized experience when using our site.

We use third party service provider(s) to assist us in better understanding the use of our site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction Information. Our service provider(s) analyze(s) this information and provide(s) us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors interests in our site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the platform. Our service provider(s) is/are contractually restricted from using information they receive from our site other than to assist us.

Usage of information

We may use your personal information to:

(i) Verify your identity;
(ii) Process your transactions;
(iii) Inform you about financing features;
(iv) Personalize your RocaPay experience;
(v) Analyze RocaPay website usage, and improve our website and website offerings;
(vi) Contact you about RocaPay Services;
(vii) Respond to your questions and requests;
(viii) Provide you with information about other products or services related to those you already have purchased or about products or services we think are of interest to you;
(ix) Notify you about any changes;
(x) Provide you with news.

 

Disclosure of Information

Your Personal Information may be disclosed to third parties and/or legal authorities under the following circumstances/conditions:

Disclosure to third parties

We may disclose your Personal Information to third parties including:

(i) Business partners, suppliers, sub-contractors and other service providers;
(ii) Advertisers and/or advertising networks that require data in order to select and show you relevant advertisements;
(iii) Analytics and/or search engine providers that assist us in the optimization of our site.

All our third party service providers are bound by contract to protect and use our users’ Personal Information only for the purposes listed above, except as otherwise required by law.

Disclosure to legal authorities

We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities in the following cases:

(i) If we believe disclosure is in accordance to any law, regulation or legal procedure;
(ii) If we think disclosure is needed to prevent any harm or financial loss;
(iii) If disclosure is necessary to report certain illegal activity;
(iv) To protect the rights, property or safety of RocaPay;

(v) If we believe your actions are in violation of this Privacy Policy and/or our Terms of Service and KYC and AML/CTF policy.

International Transfer of Personal Information

We store and process your Personal Information in data centers around the world, wherever RocaPay’s facilities or service providers are located. As such, we may transfer your Personal Information outside of the EEA. Such transfers are undertaken in accordance with our legal and regulatory obligations.

Links

RocaPay may provide references and/or links to other websites. This Privacy Policy applies only to RocaPay’s website.

Correction/Updating/Deleting of Personal Information

You may access your Personal Information whenever you want by sending us an e-mail to [email protected] Please have in mind that there might be a small fee in order to cover our costs for granting you the desired access.

You have the right to correct, update or delete any inaccurate and/or incorrect data by contacting us at [email protected]

The deletion or destruction requests of both your Account and Personal Information will be reviewed and processed only if they do not contradict our legal and regulatory obligations.

Security of Personal Information

We use various security measures to ensure that our users’ Personal Information and accounts are protected. Part of these measures are:

(i) Password-protected directories and databases;
(ii) Authorized personnel with access to your Personal Information, who are required to treat the information as confidential;
(iii) Secure Sockets Layered (SSL) technology to encrypt and send your information across the Internet securely;
(iv) PCI Scanning to prevent your information from being hacked.

Retention of Personal Information

We retain Personal Information for as long as necessary to fulfill purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain Account and other Personal Information for at least five years after an account is closed.

Changes and Updates to this Privacy Policy

This Privacy Policy may be revised, modified, updated and/or supplemented at any time, without prior notice. When we make changes to this Privacy Policy, we will notify all users on our website, and publish the amended Privacy Policy on our website.