Digital Wallet Privacy Policy

This Privacy Statement governs the manner in which IslandPay Group Ltd (Island Pay) collects, uses, and maintains information collected from its customers. This privacy statement applies to the Island Pay website, software applications and all products and services offered by Island Pay.

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Overview of Island Pay

Island Pay is an electronic money mobile payment service provider licensed by the Central Bank under the Payment Instruments (Oversight) Act and Regulations.

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Definitions

“Personal information ” means information relating to an identifiable living individual and may include name, address, age, gender, contact information, mobile payment transaction records and related payment or transfer records, and any related financial records.

“Services” means the provision of electronic money mobile payments via the Island Pay website or software applications.

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Collection and Use of Personal Information

When you download, operate, interact or use Island Pay Services, you provide your personal information to Island Pay. In the course of providing its Services to you, Island Pay may acquire, store and transmit such personal information.

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Island Pay may also utilize the personal information collected to provide its customers with communications on Island Pay’s system and new or upgraded products and may store customers’ electronic mail and other communications as a necessary incident to the transmission and delivery of the communications.

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Non-disclosure of Personal Information

Island Pay will not share, sell, rent, or trade personal information with third parties for any promotional or marketing purpose. Any personal information collected by Island Pay will be used solely in the carrying out and effecting of the Services and/or the transmission of communications.

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Subject to the exclusions as described in Sections V and VI below, Island Pay will not share customer’s personal information with its partners, suppliers, or affiliates (local or foreign), law enforcement agencies or regulatory authorities.

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Exclusions to Non-disclosure

Island Pay may disclose a customer’s personal information to any law enforcement agency, Supreme Court or regulatory authority of which Island Pay is a licensee in the following circumstances:

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(i) where customers are proven to be involved in fraud and/or money laundering, Island Pay may be compelled to comply with certain local laws and provide selected information to local authorities, the Attorney General or Supreme Court;

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(ii) where Island Pay has reason to believe that disclosing such information is necessary to identify, make contact with, or bring legal action against any person who may be causing harm or interfering with the rights or property of Island Pay, Island Pay’s customers, or others, or where Island Pay has a good faith belief that the law requires such disclosure;

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(iii) where Island Pay has reasonable grounds to suspect that a customer transaction involves the proceeds of criminal conduct as defined in the Proceeds of Crime Act (POCA)or is related to an offence under POCA, is an attempt to avoid the enforcement of a provision of POCA or is an identified risk as defined in the Financial Transaction Reporting Act (FTRA);

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(iv) in fulfilment of any of Island Pay’s obligations under the FTRA and Financial Transaction Reporting Regulations (FTRR).

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(v) it is necessary to protect the legitimate interests of Island Pay and its customers;

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(vi) it is required to cooperate with interception orders, warrants, or other legal process that Island Pay determines in its sole discretion to be valid and enforceable; and

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(vii) it is necessary to provide to a law enforcement agency when the contents are inadvertently obtained by Island Pay and appear to pertain to the commission of an offence.

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NB. It is important to note, in the fulfilment of consolidated supervision, oversight and regulation of the financial services sector, any regulator of which Island Pay is a licensee, may be required to share the personal information of an Island Pay customer with corresponding regulators in other jurisdictions. This means that your personal information may be disclosed to such regulatory authorities. You understand and agree that in such circumstances your personal information may be disclosed to regulators in jurisdictions outside of the Bahamas.

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Third Party Service Providers

Island Pay may contract with third party service providers (including affiliates) to process or handle customer’s personal information on our behalf and assist with various services such as electronic mail distribution, data processing and analytics, and customer support. By using Island Pay Services you acknowledge and agree Island Pay may share and release your personal information with its third party service providers. Island Pay will take such steps to protect such personal information shared and released to our third party service providers in a manner consistent with this policy.

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Protection of Personal Information

Island Pay adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information.

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Island Pay uses appropriate physical, electronic, and managerial procedures to ensure the protection of its customer’s personal information.

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Right of Access to Personal Information

Every customer of Island Pay has a right of access to their personal information. Customers may access and modify their personal information via the Island Pay application on their mobile device or the Island Pay website.

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Customers may access a physical copy of their personal information by submitting a written request to Island Pay’s head office, Templeton Building, Lyford Cay, Nassau, The Bahamas or [ info@IslandPay.com] Upon the receipt of a valid request Island Pay shall provide a copy of the requested personal data within [ ] days.

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Changes in this Privacy Statement

You agree that Island Pay can amend, modify, change or replace this Privacy Statement at any time to take into consideration any changes in laws and regulations, Island Pay’s policies or to address other issues.

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In the event Island Pay amends, modifies, changes or replaces this Privacy Statement Island Pay will notify you by email, text message or by means of a notice prominently displayed on our website or application.

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Island Pay considers you to have received the written notice on the day it is posted, or sent by electronic communication.
Your continued use of the Services (including maintenance of funds in your account) following notice of such change indicates your agreement to and acceptance of the new terms and conditions of the Privacy Statement as amended.

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In the event Island Pay goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email or prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.

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Refusing or Withdrawing Consent

Subject to legal, regulatory and contractual requirements, you can refuse to consent to Island Pay’s collection, use or disclosure of your personal information, or you may withdraw your consent to the further collection, use or disclosure of your personal information at any time in the future by giving us reasonable notice. However, withdrawal of your consent may prevent Island Pay from providing you, or continuing to provide you, with its Services, and/or means of access to its Services.

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Disclaimer

Island Pay disclaims any intention to censor, edit or engage in ongoing review or surveillance of communications stored on or transmitted through its facilities by customers or others. Island Pay will, however, review, delete or block access to communications that may harm, Island Pay, its customers or third parties. The grounds on which Island Pay may take such action include, but are not limited to, actual or potential violations of Island Pay’s policies.

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If you have any questions about this Privacy Statement please contact us at the following:

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IslandPay Group Ltd.
Templeton Building
Lyford Cay
Nassau, The Bahamas

1-242-502-8777

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