PRIVACY POLICY
Last updated August 29, 2023
This privacy notice for Banqr ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you
use our services ("Services"), such as when you:
-
Visit our website at banqr.app, or any website of ours that links to this privacy
notice
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Engage with us in other related ways, including any sales, marketing,
or events
Questions or concerns?Reading this privacy notice will
help you understand your privacy rights and choices. If you do not agree
with our policies and practices, please do not use our Services. If you
still have any questions or concerns, please contact us at contact@banqr.app.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can
find out more details about any of these topics by clicking the link
following each key point or by using our
table of contents below to find the section you are looking for.
What personal information do we process? When you visit,
use, or navigate our Services, we may process personal information
depending on how you interact with us and the Services, the choices you
make, and the products and features you use. Learn more about
personal information you disclose to us.
Do we process any sensitive personal information?
We may process sensitive personal
information when necessary with your consent or as otherwise permitted by
applicable law. Learn more about
sensitive information we process.
Do we receive any information from third parties?
We do not receive any information from
third parties.
How do we process your information? We process your
information to provide, improve, and administer our Services, communicate
with you, for security and fraud prevention, and to comply with law. We
may also process your information for other purposes with your consent. We
process your information only when we have a valid legal reason to do so.
Learn more about
how we process your information.
How do we keep your information safe? We have organizational and technical processes and
procedures in place to protect your personal information. However, no
electronic transmission over the internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able
to defeat our security and improperly collect, access, steal, or modify
your information. Learn more about
how we keep your information safe.
What are your rights? Depending on where you are located
geographically, the applicable privacy law may mean you have certain
rights regarding your personal information. Learn more about
your privacy rights.
How do you exercise your rights? The easiest way to
exercise your rights is by submitting a
data subject access request, or by contacting us. We will
consider and act upon any request in accordance with applicable data
protection laws.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when
you register on the Services,
express an interest in obtaining information about us or our products
and Services, when you participate in activities on the Services, or
otherwise when you contact us.
Personal Information Provided by You. The personal
information that we collect depends on the context of your interactions
with us and the Services, the choices you make, and the products and
features you use. The personal information we collect may include the
following:
Sensitive Information.
When necessary, with your consent or as
otherwise permitted by applicable law, we process the following categories
of sensitive information:
Payment Data. We may collect data necessary to process
your payment if you make purchases, such as your payment instrument
number, and the security code associated with your payment instrument.
All payment data is stored by
Stripe. You may find their privacy notice link(s) here:
https://stripe.com/en/privacy.
Social Media Login Data.We may provide you
with the option to register with us using your existing
social media account details, like your Facebook, Twitter,
or other social media account. If you choose to register in
this way, we will collect the information described in the
section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
All personal information that you provide to us must be true,
complete, and accurate, and you must notify us of any changes to
such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol
(IP) address and/or browser and device characteristics
— is collected automatically when you visit our
Services.
We automatically collect certain information when you visit,
use, or navigate the Services. This information does not reveal
your specific identity (like your name or contact information)
but may include device and usage information, such as your IP
address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country,
location, information about how and when you use our Services,
and other technical information. This information is primarily
needed to maintain the security and operation of our Services,
and for our internal analytics and reporting purposes.
The information we collect includes:
-
Log and Usage Data. Log and usage data is
service-related, diagnostic, usage, and performance information
our servers automatically collect when you access or use our
Services and which we record in log files. Depending on how you
interact with us, this log data may include your IP address,
device information, browser type, and settings and information
about your activity in the Services
(such as the date/time stamps associated with your usage,
pages and files viewed, searches, and other actions you take
such as which features you use), device event information (such
as system activity, error reports (sometimes called "crash dumps" ), and hardware
settings).
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short:We process your information to provide, improve, and
administer our Services, communicate with you, for security
and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of reasons,
depending on how you interact with our Services, including:
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To facilitate account creation and authentication and otherwise
manage user accounts.
We may process your information so you can create and log in
to your account, as well as keep your account in working order.
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To deliver and facilitate delivery of services to the user.
We may process your information to provide you with the
requested service.
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To enable user-to-user communications.We may
process your information if you choose to use any of our offerings
that allow for communication with another user.
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To save or protect an individual's vital interest. We
may process your information when necessary to save or protect an
individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short:We only process your personal information
when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into
or fulfill our contractual obligations,
to protect your rights, or to fulfill our
legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases to process
your personal information:
-
Consent.We may process your information if you have
given us permission (i.e., consent) to use your
personal information for a specific purpose. You can withdraw your
consent at any time. Learn more about
withdrawing your consent.
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Performance of a Contract. We may process your
personal information when we believe it is necessary to fulfill our contractual obligations
to you, including providing our Services or at your request prior to
entering into a contract with you.
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Legal Obligations. We may process your information
where we believe it is necessary for compliance with our legal
obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your
information as evidence in litigation in which we are involved.
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Vital Interests. We may process your information where
we believe it is necessary to protect your vital interests or the vital
interests of a third party, such as situations involving potential
threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission
(i.e., express consent) to use your
personal information for a specific purpose, or in situations where your
permission can be inferred (i.e., implied consent). You can
withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable
law to process your information without your consent, including, for
example:
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If collection is clearly in the interests of an individual and consent
cannot be obtained in a timely way
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For investigations and fraud detection and prevention
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For business transactions provided certain conditions are met
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If it is contained in a witness statement and the collection is
necessary to assess, process, or settle an insurance claim
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For identifying injured, ill, or deceased persons and communicating
with next of kin
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If we have reasonable grounds to believe an individual has been, is, or
may be victim of financial abuse
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If it is reasonable to expect collection and use with consent would
compromise the availability or the accuracy of the information and the
collection is reasonable for purposes related to investigating a breach
of an agreement or a contravention of the laws of Canada or a province
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If disclosure is required to comply with a subpoena, warrant, court
order, or rules of the court relating to the production of records
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If it was produced by an individual in the course of their employment,
business, or profession and the collection is consistent with the
purposes for which the information was produced
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If the collection is solely for journalistic, artistic, or literary
purposes
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If the information is publicly available and is specified by the
regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short:
We may share information in specific situations described in this
section and/or with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers,
contractors, or agents ("third parties") who perform services for
us or on our behalf and require access to such information to do that
work. We have contracts in place with
our third parties, which are designed to help safeguard your personal
information. This means that they cannot do anything with your personal
information unless we have instructed them to do it. They will also not
share your personal information with any organization apart
from us. They also commit to protect the data they hold on our behalf and
to retain it for the period we instruct. The third parties we may share personal
information with are as follows:
Supabase
We also may need to share your personal
information in the following situations:
-
Business Transfers. We may share or transfer your
information in connection with, or during negotiations of, any merger,
sale of company assets, financing, or acquisition of all or a portion of
our business to another company.
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short:If you choose to register or log in to our Services using a social
media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your
third-party social media account details (like your Facebook or Twitter
logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile
information we receive may vary depending on the social media provider
concerned, but will often include your name, email address, friends
list, and profile picture, as well as other information you choose to
make public on such a social media platform.
We will use the information we receive only for the purposes that are
described in this privacy notice or that are otherwise made clear to you
on the relevant Services. Please note that we do not control, and are
not responsible for, other uses of your personal information by your
third-party social media provider. We recommend that you review their
privacy notice to understand how they collect, use, and share your
personal information, and how you can set your privacy preferences on
their sites and apps.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short:We keep your information for as long as necessary to fulfill the purposes outlined in
this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is
necessary for the purposes set out in this privacy notice, unless a
longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in this notice will require us keeping your personal
information for longer than one (1)
months past the termination of the user's account.
When we have no ongoing legitimate business need to process your
personal information, we will either delete or anonymize such information, or, if
this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until
deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short:We aim to protect your personal information through a system of organizational and technical security
measures.
We have implemented appropriate and reasonable technical and organizational security measures designed
to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third parties will not be
able to defeat our security and improperly collect, access, steal, or
modify your information. Although we will do our best to protect your
personal information, transmission of personal information to and from
our Services is at your own risk. You should only access the Services
within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short:
We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18
years of age. By using the Services, you represent that you are at least
18 or that you are the parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we
will deactivate the account and take reasonable measures to promptly
delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at contact@banqr.app.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:
In some regions, such as the
European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you
greater access to and control over your personal information.
You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK,
and Canada), you have certain rights
under applicable data protection laws. These may include the right (i)
to request access and obtain a copy of your personal information, (ii)
to request rectification or erasure; (iii) to restrict the processing of
your personal information; and (iv) if applicable, to data portability.
In certain circumstances, you may also have the right to object to the
processing of your personal information. You can make such a request by
contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable
data protection laws.
Withdrawing your consent: If we are relying on
your consent to process your personal information, which may be express and/or implied
consent depending on the applicable law, you have the right to
withdraw your consent at any time. You can withdraw your consent at any
time by contacting us by using the contact details provided in the
section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.
However, please note that this will not affect the lawfulness of the
processing before its withdrawal nor,
when applicable law allows,
will it affect the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and
promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the
details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be
removed from the marketing lists. However, we may still communicate with
you — for example, to send you service-related messages that are necessary
for the administration and use of your account, to respond to service
requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your
account or terminate your account, you can:
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Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may
retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our legal terms and/or
comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may
email us at contact@banqr.app.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature or
setting you can activate to signal your privacy preference not to have
data about your online browsing activities monitored and collected. At
this stage no uniform technology standard for recognizing and implementing DNT signals
has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the
future, we will inform you about that practice in a revised version of
this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short:Yes, if you are a resident of California, you are granted specific
rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who
are California residents to request and obtain from us, once a year and
free of charge, information about categories of personal information (if
any) we disclosed to third parties for direct marketing purposes and the
names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit
your request in writing to us using the contact information provided
below.
If you are under 18 years of age, reside in California, and have a
registered account with Services, you have the right to request removal
of unwanted data that you publicly post on the Services. To request
removal of such data, please contact us using the contact information
provided below and include the email address associated with your
account and a statement that you reside in California. We will make sure
the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all
our systems (e.g., backups, etc.).
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short:Yes, we will update this notice as
necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated
version will be indicated by an updated "Revised" date and
the updated version will be effective as soon as it is accessible. If we
make material changes to this privacy notice, we may notify you either
by prominently posting a notice of such changes or by directly sending
you a notification. We encourage you to review this privacy notice
frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at contact@banqr.app
or contact us by post at:
Banqr
45 Rue de la Chine
Paris
75020
France
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE
DATA WE COLLECT FROM YOU?
You have the right to request access to the personal
information we collect from you, change that information,
or delete it. To request to review, update, or delete your
personal information, please fill out and submit a
data subject access request.
