Privacy

A. Overview

In order to operate the Nuapay service and to reduce the risk of fraud, Nuapay(« Nuapay or « we ») must ask you to provide us information about yourself. This Privacy Policy describes the information we collect and how we use that information. Nuapay takes the privacy of your personal information extremely seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict controls, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the Nuapay website, whether the services are offered by Nuapay or by its sister companies.

Any information which is provided by you will be treated with the highest standards of security and confidentiality and in accordance with the terms of the Data Protection Acts 1988 and 2003, Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the Protection of Individuals with regard to the Processing of Personal Data and on the Free Movement of Such Data, and any implementing and/or amending legislation as may be adopted by the European Union from time to time.
If at any time after giving us personal information you decide that you no longer wish us to hold or use this information, or in the case that the information becomes out of date, you are free to notify us, and we will remove or rectify the information within a reasonable time and in accordance with legislative requirements.
Your privacy is important to us. By accepting the Privacy Policy and User Agreement in registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Nuapay Client Agreement.
Please note that some of your personally identifiable information will be stored and processed on our computers in the United Kingdom and Ireland. We will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for the Nuapay service.
A Special Note About Children. Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.

B. Information We Collect

Required Information:
To open a Nuapay account, you must provide your name, address, phone number, and email address. We also ask you to choose a security questions to answer (such as your city of birth or your pet’s name) This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against fraud, and to contact you should the need arise in administering your account.

Transaction Information:
When you use Nuapay to send money to or collect from someone we ask you to provide information related to each transaction, including the amount of the transaction and the type of transaction. We retain this information for each of your transactions through Nuapay. We also collect the Internet address (IP address) of the computer or device you use to access your Nuapay account, in order to help detect possible instances of unauthorised transactions.

Information About You From Third Parties:
In order to protect all our customers against potential fraud, we may verify with third parties, including credit agencies, the information you provide. In the course of such verification, we receive personally identifiable information about you from such services.
If you send or receive high overall payment volumes through Nuapay, in some circumstances we will conduct a background check on your business by obtaining information about you and your business from a credit bureau or a business information service . If you incur a debt to Nuapay, we will generally conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. Nuapay, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to close an account based on information obtained during this credit review process.

Telephone:
Calls may be monitored or recorded to ensure that we carry out your instructions correctly and to help improve the quality of our service and in the interests of security.

Website Traffic Information:
Because of the way that World Wide Web communication standards work, when you arrive at or leave the Nuapay website, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Website you visit while you are on the Nuapay site, the type of browser you use and the times you access our Website. We use this information only to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve our service and your experience with Nuapay. We do not track the Websites that you visit after you leave the Nuapay site.

Customer Service Correspondence:
If you send us correspondence, including emails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Nuapay to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

Questionnaires, Surveys and Profile Data:
From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users’ interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

C. Our Use and Disclosure of Information

Internal Uses
We collect, store and process your personal information on servers wholly located in the European Union. We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to receive offers for special features or products, and 4) to improve our products and services.
We give access to individually identifiable information about our Clients only to those employees who require it to fulfil customer service requests.

Disclosure to Third Parties
Nuapay will not sell or rent any of your personally identifiable information to third parties. Nuapay will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.

1. We share information with companies that help us process the transactions you request and protect our Clients’ transactions from fraud, Additionally, if you create a negative balance and owe us money, we may share information with processing companies including collection agencies.
2. We disclose the information we collect, as described in Section B above, to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements. These companies are subject to confidentiality agreements with us and other legal restrictions that prohibit using the information except to market the specified Nuapay-related products or services, unless you have affirmatively agreed or given your prior permission for other uses.
3. We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement.
4. We disclose information in response to requirements of civil or criminal legal process.
5. We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
6. We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in Meath. However, this aggregated information is not tied to nor will expose personal information.
7. As with any other business, it is possible that Nuapay in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by Nuapay, including client account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section A above.
8. We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.

Our Contacts with Sentenial Clients
We communicate with users on a regular basis via email, SMS & regular mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your email address to confirm your opening of a Nuapay account, to send you certain notice of payments that you send or receive through Nuapay, to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

We also use your email address and/or mobile phone number to send you other types of communications that you can control, including the Nuapay periodical newsletter, customer surveys and notice of special third-party promotions. You can choose whether to receive some of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the  website and changing your preferences in the Profile page of the My Account tab. You can also change your choices at any time through the same procedure.
In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

Internet Address Information
We use IP addresses, browser types and access times to analyse trends, administer the site, improve site performance and gather broad demographic information for aggregate use. By entering into our User Agreement, you agree that, with respect to other users’ personally identifiable information that you obtain through the site or through a Nuapay-related communication or Nuapay-facilitated transaction, you will only use this information for: (a) Nuapay-related communications that are not unsolicited commercial messages, (b) using services offered through Nuapay (e.g. insurance, delivery and fraud complaints), and (c) any other purpose that such user expressly agrees to after adequate disclosure of the purpose(s).

D. Information Security

Information Security
Nuapay is committed to handling your customer information with high standards of information security. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with regulations to guard your non-public personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes.
The security of your Nuapay account also relies on your protection of your Nuapay password. You may not share your Nuapay password with anyone. Nuapay representatives will never ask you for your password, so any email or other communication requesting your password should be treated as unauthorised and suspicious. If you do share your Nuapay password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at (www.Nuapay.com) and changing your Profile settings, and also contact us right away as described in Section F below.

E. Accessing and Changing Your Information

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your Nuapay account, at any time by logging in to your account on the Nuapay website and changing your preferences in the Profile page of the « My Account » tab. You can also close your account through the Nuapay website. If you close your Nuapay account, we will mark your account in our database as « Inactive » but will keep your account information in our database to meet legal requirements.

F. Accountability

If you have any questions about this privacy statement, Nuapay’s information practices, or your dealings with Nuuapay, you can contact us by calling +353 1 6292141, or write us at Nuapay, 23 Austin Friars, London EC2N 2QP.

G. Disclaimer

Nuapay, its directors, employees, servants and agents, affiliates or other representatives and their respective parent and subsidiary companies, shall not be liable in respect of any claims, emergencies, demands, causes of action, damages, losses, expenses, including without limitation, reasonable legal fees and costs of proceedings arising out of or in connection with the use and/or dissemination of personal information relating to you in accordance with this privacy policy and your consents.

H. Other Websites

You should be aware that where you link to another website from any of the Nuapay websites, that Nuapay has no control over that other website. Nuapay has no responsibility for the privacy practices of other websites.

Privacy Policy

Nuapay reserves the right in its sole discretion to amend this privacy statement at any time, and you should regularly check this privacy statement for any amendments.

We will post the amended Privacy Policy prominently on our Website so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Nuapay website (www.nuapay.com) at any time for the most current version of our Privacy Policy.