Last Updated: November, 2022
This Policy applies to all Platforms and LYOPAY Pro Operators. Please read this Policy along with the Terms of Service carefully, and note that by using LYOPAY Pro, you are consenting to the collection, storage, processing and transfer of your personal information as described in this Policy.
This Policy may be made available in several languages; all versions are legally binding, but in the event of inconsistency between the English version and a translated version, the English version prevails.
This Policy applies to all visitors and/or users who act in their own personal capacity as our user or as in their professional capacity, for instance;
▪ Users who access our Platforms or other services provided by us
▪ Our prospective clients identified as such by us or our third parties
▪ Our suppliers and business partners
▪ Anyone else who interacts with us via call, email or visit us or otherwise interact with us
2. PURPOSE OF THIS POLICY
We at LYOPAY Pro know and understand how important it is for you to understand how we collect, store, process, share and use your personal data. We respect and protect the privacy of our users’ personal data in our Platforms.
The purpose of this Policy is to describe how LYOPAY Pro collects, processes and manages users’ personal data through the Platforms, which is developed to offer LYOPAY Pro services.
a. “Personal data” means any data relating directly or indirectly to a living individual from which it is practicable for the individual to be directly or indirectly identified. Personal data must also be in a form in which access to, or processing of, the data is practicable.
(All information regarding legal entities are not considered as Personal data, however information about sole proprietors and partnerships may be treated as Personal data if such information satisfies the definition of Personal data.)
b. “User(s)” means any natural person or legal entity who visits, and creates an account in our Platforms and/or known as our customer.
c. “Document(s)” includes any medium in which data is recorded, whether printed, or on tape, or film or by electronic means, or otherwise; map, diagram, photograph, film, microfilm, video-tape, sound recording, or machine-readable record; any record which is capable of being produced from a machine-readable record by means of equipment or a programme, or a combination of both, or any equipment or a programme, or a combination of both, and is used for that purpose by the public body or private body which holds the record;
d. “Authorized Person” means any natural person appointed by the entity under a letter of authorization to (a)sign in, (b) open an account and (c) to carry out the business of that particular entity
e. “PEP” means a Politically Exposed Person refers to a natural person (and includes where relevant, a family member or close associate) who is or has been entrusted with a prominent public function, including but not limited to, a head of state or government, senior government or an important political party official.
By accessing and using our Platforms and services you are consenting and accepting the terms of this Policy. If you do not agree or consent with the details we require with any aspect of this Policy, you shall at any time withdraw your consent and discontinue access or use of our services.
5. THE PERSONAL DATA LYOPAY PRO COLLECTS FROM USERS
Your Personal data is collected and stored with LYOPAY Pro in order to provide, develop and to enhance our products and services including technical infrastructure, security, compliance, fraud prevention and customer support. We are committed to exercise due diligence when dealing with every User and in the course of conducting business, we ensure that it is able to comply with all the applicable Laws and regulations that require to prevent the facilitation of money laundering and terrorist financing.
The Personal data we collect from LYOPAY Pro Users are;
AUTHORIZED PERSON DETAILS
● Full name
● Date of Birth
● Email Address
● Residence Address
● Country Code
● Telephone number
● Employment Status
● Nature of the employment
● Employer details
● Government issued Identity or Driving License
● Passport details
● Proof of Residences
● Salary Certificate
● Source of Fund
● Audio or video recordings
● Personal Bank account details
● Company name
● Country of Incorporation
● Country of Operation
● Nature of the business
● Authorized Person’s details
● Ultimate Beneficial Owner details
● A copy of Certificate of Incorporation
● Source of Funds Verification documents
● UBO structure
● A letter of authorization issued to individual performing on behalf of entity
● Passport copies of all directors & Shareholders
● Valid Trade License
● Memorandum of Association
● Article of Association
● Registered Address
● Tax registration certificates
● Estimated transaction type and volume
● Audited financial Statement
● Completed customer information questionnaire
● Power of Attorney of Authorized person
● Corporate Bank account details
● IP Address
● Login information
● Browser type and version
● Time zone setting
● Operating System
● Transaction history
● Pages accessed and links clicked
● Public blockchain data
● Device- specific information
● System activity
● Uniform Resource Locators [URL]
● Data collected via Cookies
6. WHY USERS’ PERSONAL DATA IS USED?
6.1. To communicate with the User
6.2. To comply with legal and regulatory compliance
6.3. To detect and prevent frauds and credit risks
6.4. To provide, troubleshoot and improve our Services
6.5. To enforce our terms in our User agreement
6.6. To provide customer services
6.7. To ensure quality control
6.8. To ensure network and information security
6.9. To enhance and personalize User experience
6.10. To facilitate corporate acquisitions, mergers or transactions
6.11. To engage in marketing activities
6.12. For Transaction services
6.13. Purposes for which we seek User’s consent
7. DATA TRANSFER
Except as described in this Policy, we will not disclose any of your information and we shall only share information in the following circumstances:
7.1. With applicable regulatory bodies of England and Wales and if required by law or good-faith that such actions are necessary to comply with state laws, or in the need of a litigation process, judicial or other government warrant or to cooperate with applicable law enforcements or regulatory authorities.
7.2. We may share your Personal data with affiliates, selected third parties, including business suppliers, data processing partners, distributors and subcontractors, when it is necessary for the delivery of our services, or when there is a legal basis to do so. The aforementioned third parties only collect, use and disclose your information in the ways indicated by us in order to provide adequate services.
7.3. If necessary and/or applicable, we may share your Personal data with third party Know Your Client and/or Anti Money Laundering (KYC/AML) service providers of LYOPAY Pro to fulfill the identification requirements.
7.4. With service providers under contracts to operate the business. For instances;
7.4.1. Cloud storage
7.4.2. Payment process
7.4.3. Transaction Monitoring
7.4.4. Network Infrastructure
7.4.6. Customer Support
7.4.8. Data analytics
7.5. We transfer only the minimum amount of data necessary for a particular outsourced service provider(s) and we only cooperate with the outsourced service providers who can provide and ensure adequate level of Personal data protection.
7.6. With our affiliates/ business partners as a general part of conducting business to offer services
7.7. With financial Institution which we partner to process payments you have authorized
LYOPAY Pro ensures that the service providers and affiliates/ business partners who process personal information to acknowledge the confidentiality of this information and to protect the User’s right to privacy by complying with all applicable privacy and data protection laws
8. PROTECTION AND STORAGE OF PERSONAL DATA
8.1. LYOPAY Pro maintains physical, technical, administrative and procedural safeguards in connection with the collections, storage and disclosure of User’s Personal data. We use firewall barriers, encryption techniques and authentication procedures to maintain the security of User’s online sessions.
8.2. LYOPAY Pro Users are requested to protect their account password from unauthorized access to avoid unnecessary authentication issues. In order to circumvent loss, misuse, unauthorized acquisition or alteration of your data, Users are requested to choose the strongest password and to protect the account privacy data from any third-parties. In the event of unauthorized access, the LYOPAY Pro insists the Users contact us immediately.
8.3. Furthermore, LYOPAY Pro does not ensure the security or privacy of data transmitted via email, phone or SMS, till such data reaches the domain of our network, since we have no access to protect such data until it reaches our network domain.
9.1. Cookies are small text files that are placed on your device like computer, mobile or any other device by a website, containing details of your browsing history. In simple terms it is explained as that it contains information about your browsing activity. Whenever you visit our Platforms, the website sends a cookie to the device you are using to access our Platforms. Your device automatically stores the Cookie in a file that’s located within your website browser.
9.2. Cookies allow LYOPAY Pro to recognize your device such as; when you revisit a site, the website will respond in a more personalized way, remembering your preferences, and it will make your page load faster. Cookies set by our Platforms are called “First party cookies ”. Cookies set by parties other than LYOPAY Pro are called “Third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website for instance such as advertising, interactive content and analytics.
9.3. We use the following Cookies to operate LYOPAY Pro, such as;
9.3.1. Session Cookies are temporary and expire once you close your browser. It stores information for the time, or session when you are on our Platforms.
9.3.2. Persistent Cookies encompasses all Cookies that remain on your hard drive until you erase or your browser does it. It depends on the Cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary.
9.3.3. Third-party-cookies are placed on your device, not by our Platforms, but by a third party like an advertiser or an analytic system. Generally, the Third-Party Cookies consist of tracking Cookies used to identify online behavior, understand interests and then customize advertising the User on other websites. Any information obtained from Third-Party Cookies is processed by the respective Collaborative Partners.
9.3.4. Google Analytics Cookies to measure our User’s interactions with the content on our Platforms. These Cookies collect information about your interactions with our Platforms, such as unique visits, repeat visits, session duration and website activity;
9.3.5. Facebook Pixel to process information about a User’s activity on our Platforms, such as the website visited, Facebook identity, browser data, and more. The information processed from Facebook pixel is used to serve ads based on your interests through Facebook, as well as to measure cross-device conversions and User interactions on ourPlatforms.
9.3.6. Essential Cookies are known as strictly necessary Cookies for you to browse our Platforms and use the features of it, such as accessing secure areas of our Platforms. These Cookies are generally First-Party Session Cookies. These Cookies do not require consent from you. Essential Cookies helps to make our Platforms easy to use by providing basic functions such as page navigation, language selections, authorization and filling in forms. Our Platforms will not function without these Cookies and they cannot be disabled. These Cookies do not reveal the User’s identity or collect information. They are stored on the User’s device until the browser is closed.
9.3.8. Performance Cookies collect information about how you use our Platforms, like which page you visited and which link you clicked on. None of this type of information can be used to identify you. The sole purpose of performance cookies is to improve our Platforms functions. Analytics may collect information through log data, such as; (i) IP address, (ii) Type of browser and device, (iii) Operating system, (iv) Name of the Internet Service Provider, (v) Country information, (vi) Date and time of visit, (vii) Web page origin and exit.
9.3.9. Marketing Cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see and ad. These Cookies can share information with other organizations or advertisers. However, these are Persistent Cookies which are third-party-provenance. These cookies may be set through the website by our advertising partners. If you do not allow these cookies, you will experience less targeted advertising. These cookies are set on your device for up to two (2) years or deleted, if you erase your browser cookie data.
10. DATA RETENTION
LYOPAY Pro shall process your Personal data as long as any of the above-mentioned data processing purposes or legal basis are still valid. In the event you withdraw your consent, we will cease the processing of your Personal data, which has been on your prior consent. In certain circumstances, if an investigation into a suspicious User or a suspicious activity has been initiated and in the event of proceeding the investigation in respect of the User, LYOPAY Pro will not destroy any relevant records and we will retain it till the reporting authority closes the case, for the reason that we are subjected to certain anti-money laundering laws.
11. GENERAL DATA PROTECTIONS REGULATIONS OF EU
LYOPAY Pro is obliged and bound by the General Data Protection Regulation [GDPR]. This regulation came into effect on May 25, 2018 and LYOPAY Pro will be liable for any violation of its privacy and security standards, with penalties.
Under certain circumstances, you have rights under data protection laws in relation to your Personal data which are set out in more detail below;
a. Request access
This enables you to receive copies of your Personal data. We hold about you and to check that we are lawfully processing it. This is also commonly known as a "Data Subject access request". 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.
b. Request erasure
This enables you to request us to delete or remove Personal data where there is no good reason for us continuing to process it. Please note that there may be circumstances where we may be legally entitled to retain your Personal data.
c. Request to Restrict Processing
This enables you to object to the processing of your Personal data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your Personal data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
d. Request to Object Processing
You have the right to object to the processing of your Personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing 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.
e. Request to transfer
If you request us, we will provide 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 automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
f. Request to withdraw consent
Please note that, you may withdraw your consent any time you wish, however you shall be aware that the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. If you withdraw your consent, we may not be able to provide certain products or services to you.
To exercise these rights, please contact us using the e-mail address indicated in this Policy. We will process this request within 30 (thirty) calendar days and provide an answer.
12. PRIVACY TERMS IN USING VIRTUAL ASSETS AND BLOCKCHAIN
The Virtual assets are recorded on a public blockchain. It is a ledger which means a chain of blocks where each block contains the recording of any data transmission. Blockchains are decentralized or third-party networks which are not controlled or operated by any third-party service provider or affiliates or business partners of LYOPAY Pro, and we have no access or authority to erase, modify or alter any Personal data from such networks.
We reserve the right, at our sole discretion, to modify, amend, supplement or replace this Policy at any time and such update details shall be indicated at the top of this page. We will review and revise this Policy when there are any material circumstances arisen that may affect our ability to apply this Policy pursuant to the provisions of statutory and law requirements. What constitutes a material change will be determined at our sole discretion. We will inform our Users on all material amendments to this Policy by publishing the updated version of this Policy on our Platforms. When an updated version of the Policy is released, and if you continue to access our Platforms means that you agree to the updated content and agree to abide by the updated Policy.
14. CONTACT INFORMATION
In the event of any comments, questions, inquiries or complaints regarding this Policy, the User has the right to submit questions and/or concerns at [email protected]