Last updated 2024-04-12 12:14:34
References in this Privacy Policy to “Canapay”, “Service”, “Application”, “App” relate to the website, available at https://www.canapay.io, operated by Cana Pay D.O.O. (Canapay), registered at Ul. 7. Domobranske Pukovnije, 23000, Zadar, Croatia. Registration Number: 62022833985).
Canapay is the data controller regarding the Personal Data processed within the framework of this Privacy Policy.
An individual can only become a Client of Canapay and use its features if he/she is aged 18 or over or the age of majority in the country in which he/she resides if that happens to be greater than 18. Canapay does not knowingly collect any information (including Personal Data) or market its services to minors or users under the age of majority.
Canapay is committed to protecting and respecting the privacy of its Clients and ensures their security when using the Service. This Privacy Policy is intended to help the Client to understand what data and for which purposes Service collects, how collected data is processed and protected.
Canapay reserves the right to amend this Privacy Policy; therefore, it is recommended that the Client of the Service checks Privacy Policy on a regular basis. The service will send a notice or an email regarding such changes to the Client.
All the changes to this Privacy Policy are effective as of the “Last updated” date. The Client who continues to use the Service after the Last updated date is deemed to accept the changes made to it.
Canapay expressly states and declares that no personal data of the Client is operated when Additional Services are provided to the Client pursuant to the Terms (Special Terms on Fiat to Crypto Exchange Services). That Client may be required to provide personal data to the third-party rendering fiat to crypto exchange services and the operation by that third party of the Client personal data will by all means be regulated by that third-party terms and conditions, and privacy policy.
Canapay has designated a Data Protection Officer (DPO) who could be reached through www.canapay.io/contact
When using the Services, the Client agrees to the processing of the following Personal Data:
Personal Data that the Client provides to the Service: (a) When creating an address, the Client obliges to provide the Service with basic details necessary for the Service to work as it might be requested, such as the Client’s name, gender, date of birth and location; (b) Canapay reserves the right to monitor or record interactions between the Client and the Support Service for training purposes and to ensure high quality of service; (c) When participating in Client verification procedures: Client’s Personal Data, as requested by the Service for the Client identification purposes; (d) When participating in surveys or focus groups: insights and evaluation of Canapay's services, responses to the questions from the Service; (e) When proceeding with transactions: information required under AML/KYC applicable standards in order to ensure the security of transactions; (f) While ordering merchant Product through Canapay's website: Client’s Personal Data, as required for the Product’s delivery, such as Client’s full name, postal address, phone number.
Personal Data collected through the use of the Service: (a) When the Client is using Canapay's services, the Service may collect data regarding the device(s) the Client uses to access the Service (such as his/her IP address, device identifier (including unique advertising device identifiers, for example Google Advertiser ID and IDFA), technical and statistical data (including data about the Internet connection, cellular service provider and application usage data) and location data (upon a separate consent from the Client); (b) By providing Personal Data to Canapay, the Client warrants that such data is true, accurate and up to date; (c) In case the Client is entitled to create a Client’s account instead of Client’s address, the present Privacy Policies shall be applicable accordingly.
Canapay collects, process and uses Personal Data of Clients of the Service based on the following grounds: (a) When such processing is performed in order to fulfil the contract between the Service and the Client; (b) Based on legitimate interest of the Service; (c) Upon explicit prior consent from the Client.
Canapay collects and processes Personal Data of the Service’s Clients in order to maintain the functionality of the Service, Product delivery and to ensure compliance with legal and business-related requirements. The User’s/Client’s Personal Data is processed for the following purposes:
When processing of personal data is related to fulfilment of the contract between the Service and the Client: (a) To set up, operate and manage the Client’s address and, if necessary, to contact the respective Client through the means provided by the Client upon registration, in connection with the operation and management of the Client’s address; (b) To analyse the Client’s profile, activity on the Service, preferences and current location in order to improve the Services; (c) To proceed and respond to the requests and enquiries received from the Client; (d) For administrative purposes, such as password reminders, service messages (including but not limited to the Website’s maintenance messages, updates to the Service’s Privacy Policy and Terms of Service).
Under legitimate interests of the Service: (a) For Client verification purposes, conducted in relation to an ongoing or alleged misbehaviour, performed by the Client of the Service, in order to block addresses as part of the Services anti-spam procedures, to investigate possible fraud; (b) To evaluate the effectiveness of marketing and to perform market research and training.
Under an explicit consent from the Client: (a) To facilitate networking opportunities of the Client with the Service by way of allowing him/her to add additional information to the Client’s address; (b) To serve the Client with targeted Website advertisements; (c) For remarketing purposes, allowing the Service to identify the Client who has previously visited the Website and optimize advertising information according to the Client’s preferences. This feature is used by the Service through third-party services such as Google Advertising and myTarget; (d) To prepare statistics regarding the use of the Services by the Client; (e) To identify possible technical malfunctions in the work of the Service, to assist internal research and development and to make improvements to the Website.
When processing delivery of the Products ordered by the Client: (a) To facilitate the delivery of the Products ordered by the Client.
Canapay retains the Client’s Personal Data for the period of time necessary to carry out relevant activities, specified in section: ‘USE OF USER’S/CLIENT’S PERSONAL DATA’ of this Privacy Policy and as permitted by applicable law. Personal Data, that the Client has communicated to the Service upon registration and subsequently through the use of the Service, will be retained by the Service as long as the Client remains the Client of the Service.
To protect the safety and security of the Clients of the Service, Canapay implements a safety retention window of 30 days following a Client’s address deletion.
Canapay reserves the right to store the Client’s Personal Data for a longer period of time than provided in the above paragraph, when it is performed in order to fulfil the legal obligations of the Service (including law enforcement requests, dispute resolution), ensure compliance with applicable law or when the relevant Personal Data is stored on the basis of the Service’s legitimate interests (including security reasons, prevention of fraud).
Canapay may share the Client’s Personal Data with third parties in the following cases:
Other Clients of Canapay: The Client shares information with other Clients of Canapay by way of voluntarily disclosing information on the Service (including but not limited to information in his/her Client’s profile). It is in the Client’s discretion to choose the information to be disclosed with the Service rescinds from responsibility for the other Clients of the Service regarding the way they might use such information, disclosed by the Client.
Facilitation of Product’s delivery: Canapay may share Client’s Personal Data with courier service providers in order to fulfil Canapay's obligations in relation to the Product’s delivery.
Providing Client’s data by law: Canapay may disclose Client’s Personal Data when such disclosure is required by law and is reasonably necessary: in order to establish, exercise, defend or enforce legal rights of the Service; to comply with a legal process such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; to assist in the prevention or detection of crime (subject in each case to applicable law); to protect the safety or vital interests of an individual.
Canapay ensures appropriate contractual control over third parties assisting the Service in processing the Client’s Personal Data, securing that rights of Clients of the Service are upheld, their Personal Data is secure, appropriate security and privacy arrangements are in place.
In the event of change in the corporate structure of the Service, resulting in transfer of the Client’s Personal Data to a third party, all the Clients of the Service would be notified of such changes via email and through a notice posted on the Service’s website. Respective notice would explain the identity of the new data controller and the Client’s options regarding disposal of their Personal Data.
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing for your personal data where we are relying on a legitimate interest (or those of a third party) and you object to the processing of your personal data on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
Request for manual review. We may use automated decision making in processing your personal information while processing your transaction. If we made an automated decision about your transaction, you have the right to contest the decision, to express your point of view and to require a manual review of the decision. If you wish to exercise any of the rights set out above, please contact us through www.canapay.io/contact or use the postal address mentioned at the beginning of this privacy policy. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
The above-mentioned rights are not absolute. In order to exercise some of the rights, the Client should meet certain conditions and requirements, specified by the law.
For more information regarding his/her rights over Personal Data, the Client/User of the Service should go to www.canapay.io/contact
The Client/User of the Service should also be acknowledged of his/her right to complain to a data protection regulator in his/her jurisdiction.
When using the Website, Client’s personal data is transferred by the Service to the domain www.canapay.io.
Canapay works hard to protect its Clients from unauthorised access to or alteration, disclosure or destruction of their Personal Data. Yet, as any other technology companies, although Canapay takes steps to secure Clients’ information, it could not be promised or guaranteed, that unauthorised access, hacking, data loss, or other breaches will never occur.
Canapay reserves the right to suspend the Client’s address without notice if there is a reasonable suspicion of breach of security. If you believe that your address or information is no longer secure, please notify Canapay immediately through the web page www.canapay.io/contact
The Client should take reasonable steps in order to keep his/her Personal Data safe.
In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted services, Canapay uses cookies and similar technologies in order to track the interaction of Clients with the Website. This section explains the different types of cookies that may be set when the Client uses the Website, helping to understand and manage them as he/she wishes.
A cookie is a small file that is stored locally at the Client’s technical device as soon as the Website is being visited. Cookies function by saving particular sets of data, such as, for example, the Client’s language selection. Should the Client open the Website again later, a cookie will transmit this data back to the Website. The Website’s cookies don't store personal information like the Client’s name or address.
Canapay's Website uses different types of cookies: (a) Session cookies only last only while the Client is visiting the Website and help Canapay to learn more about Client’s use of the Website during a single session and to help the Client to use the Website more efficiently; (b) Persistent cookies have a longer lifespan and aren't automatically deleted when the Client closes the Website. These cookies are primarily used to help the Client to sign-in into the Website again quickly, for security and analytical purposes. Canapay does not use any information whilst the Client is logged off the Website; (c) Canapay uses first-party cookies that is when the cookies are placed on the Client’s device directly by the Service. For example, first-party cookies are used to adapt the Website to the language preferences and analyse user experience of the Client; (d) Third-party cookies are placed on the Client’s device by Canapay's partners and service providers.
The Client can at any time reset device identifiers by activating the appropriate setting on his/her mobile device. The procedure for managing device identifiers is slightly different for each device.
Necessary cookies: These cookies are strictly necessary to provide the Client Canapay's services.
Authentication cookies: These persistent cookies help the Service to identify the Clients so that the Client could log into the Website automatically.
Analytics cookies: These cookies help the Service to understand how the Website is being used, and help us customize and improve the Service.
Advertising cookies: These cookies are used to make advertising messages more relevant to the Client. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on the Client’s interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.
Disclosure of Canapay's Clients’ Personal Data, as provided in section 6 of these Terms of Service sometimes involves cross-border data transfers, for instance to Andorra, Argentina, Faroe Islands, Israel, New Zealand, Switzerland, Russian Federation and other jurisdictions. Canapay uses standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of Client’s Personal Data.
We do not process any exchanges for users or accounts registered in the following jurisdictions: Iran, Taiwan, Philippines, Latvia, Vietnam, Saudi Arabia, Nepal, Albania, Bahamas, Barbados, Botswana, Cambodia, Ghana, Iceland, Jamaica, Mauritius, Mongolia, Myanmar, Panama, Syria, Uganda, Yemen, Zimbabwe, Algeria, Columbia, China, Ecuador, Morocco, Jordan, Indonesia, Bolivia, Kyrgyzstan, Bangladesh, Nicaragua.
Data Collection & Declaration: Canapay is commitment to privacy as part of our GDPR (General Data Protection Regulation) agreement. This means that we will process any data provided by you on the exchange platform and any other data which you subsequently give us for the following purposes: (a) To provide, develop or improve our products and services, or otherwise for legitimate business reasons; (b) For internal assessment and analysis like automated profiling, market and product analysis; (c) If we are under a duty to disclose or share your data to comply with any legal or regulatory obligation; or to protect our rights, property, or safety of our employees, customers, or others. (This includes exchanging information with other companies and organizations for the purposes of fraud protection); (d) Canapay respects your privacy and will not share your personal data with third parties for marketing purposes; (e) Canapay may periodically request you to re-confirm your account information and you should inform us immediately if any such data has changed; (f) You have the right to ask about the personal data we hold about you and may request the correction or erasure of that data in accordance with this privacy policy; (g) Occasionally from time to time, we would like to inform you by electronic means, email, post or telephone about our future products and services.
We reserve the right to update this privacy policy at any time, and we will publish an updated privacy policy if we do so. We may also notify you in other ways from time to time about the processing of your personal information.