Non-Account Holders
Our Services may be accessed by individuals without a Umopay account or profile. We will collect Personal Information from you even if you are a non-account holder when you use our Services, such as when you receive a payment through our Services from account holders. We may connect this information with your account, if you have one at the time you use the Service without logging in, or if you create an account later. With your consent, we may also save your credit card information for future use.
When you shop on Partner and Merchant sites, the partner or merchant may disclose Personal Information with Umopay that will be used in accordance with this Privacy Statement and the relevant Umopay user agreement.
Categories of Personal Information We Collect
Categories of Personal Data collected from you, including from your interactions with us and use of the Services:
- Personal Identifiers: Such as name, Business Name, Address, Phone Number, Email, IP address, Device Information, Information collected from cookies or other tracking technologies, other information necessary to establish an account
- Records and Financial Information: Such as, bank account and routing numbers, credit and debit card information, amount you send or request, other financial information
- Commercial Information: Such as online shopping cart information, shopping activity on merchant sites, purchase history, and order tracking and product information
- Geolocation: We may collect IP-based geolocation data and Global Positioning System (GPS) with your consent during your user experience or based on your mobile application settings.
- Internet or network activity: interactions with our Services, Information about response time for web pages, download errors, date and time when you used the service, Location Information, such as your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.
- Biometric: When you consent in the user experience, we collect voice identification or face scans to authenticate your account
- Audio, electronic, visual, or similar information: Call recordings when you talk to customer service
- Professional or employment information: including business information, contact emails, phone numbers and taxpayer ID numbers
- Imported Contact Information: including name, address, phone number, images, email address or usernames associated with the contacts
- Account Profile Information: username, profile picture, gender, or personal description which you add that may include sensitive Personal Information. You can set your profile to “Private” at any time
- Information you provide when you contact us: Your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account status, repayment history, voice identification, Information about others if you choose to share it with us
- Inferred data: We may infer information about you such as your preferences and shopping behavior, based on your transactions and interactions with our Services
- Characteristics of Protected Classifications: including age or date of birth, national origin, disability, citizenship, military status
- Sensitive Personal Information: Social Security number, government-issued identification, bank account and routing numbers, credit and debit card information, voice identification and Photo IDs or Precise Geolocation
- Information from your device: including, language settings, browser ID, cookie preferences, time zone, operating system, platform, screen resolution and similar information about your device settings, data collected from cookies or other tracking technologies
We may also obtain the above categories of Personal Information from the following categories of sources:
- Softmasters Company Limited, the owner of Umopay
- Third parties: including Service Providers, Partners and Merchants, Payment Partners, such as card networks and payment processors, Credit Reporting Agencies, Government Entities, Data Brokers, and Financial Institutions
- Connected Accounts: Non-financial or financial accounts you agree to link to Umopay, such as social network accounts, mail accounts or for open banking. You may change your mind about use of this feature and unlink your connected accounts at any time. If you choose to link these accounts or share such information with us, we will periodically collect and process it until you disconnect the account
- Third Party Applications: Applications that you choose to use for example, the Apple App Store, Google Play Store, or social networking sites
How is Personal Information used?
We may process your Personal Information for a variety of reasons, including to provide our Services, for security and fraud prevention and to comply with law. We may also use personal data with your consent to participate in certain features that while not necessary for use of the Services may be of interest to you, such as syncing your contact list to your account, targeted advertising, or connecting to a third-party platform.
We may collect Personal Information to:
- Provide our Services: such as to help you send or request money, initiate a payment, add monetary value to an account, pay a bill, administer your purchases, show you your account information, to assess your creditworthiness in connection with our Services, confirm your identity and your contact information, to authenticate your access to your account and to confirm your Account and financial information is accurate and up to date.
- Manage and improve our Services: for example, to develop new products and features, for customer analysis, to administer our Services, and for internal operations, for example troubleshooting, data analysis, testing, research, and statistical purposes.
- Manage fraud and risk: We conduct risk analysis, fraud prevention and risk management to protect our customers and business, including fraud that involves our Partners and Merchants and strategic ventures.
- Associate information about you: if you use our Services without a Umopay account (e.g., Pay without a Umopay account) or Unbranded Payment Services (e.g., such as Braintree) we may associate such transactions with your account, if you have one or later establish an account.
- Market our Services: We may use Personal Information to market our Services including where we partner with others to offer similar services to market about our Partners and Merchants. We use Personal Information to better understand and cater to your interests.
- Communicate with you: We may contact you when you need us, such as answering a question you sent to our customer service team.
- Comply with Laws: to comply with applicable laws and rules and enforce our agreements with you and other people who use our Services.
- Process information about your contacts: to make it easy for you to find and connect them, improve payment accuracy and suggest connections with people you may know. By providing us with information about your contacts you certify that you have permission to provide that information to Umopay for the purposes described in this Privacy Statement.
- Create an account connection between your Account and a third-party account or platform: such as with a social media account or a financial institution in connection with your participation in Open Banking.
- Send you locally relevant options: If you agree to let us track your location, we can enhance your security of our Services and customize our Services by using the right language and personalizing content such as providing location-specific options, functionality or offers, ads and search results.
- Remember your preferences: We may remember your preferences for the next time you use the Services, such as whether you choose to receive digital receipts via email or text when you checkout.
- Personalize your experience: When you use Umopay Services, as well as other third- party sites and services we might use tracking technologies like cookies.
Do We Disclose Personal Information, and why?
We do not sell Personal Information to third parties for money or share your Personal Information for cross context behavioral advertising, including any Sensitive Personal Information. However, we will disclose your Personal Information with third parties to help us provide Services, protect our customers from risk and fraud, market our products, and comply with legal obligations.
In addition, we may disclose Personal Information with:
- Softmasters companies to manage our business or partner companies to manage our Rewards program.
- Authorities including courts, governments, law enforcement, and regulators when accompanied by a subpoena or other legal documentation that requires Umopay or Umopay Companies to respond. We may also be required to provide other third parties information about your use of our Services, for example to comply with card association rules, to investigate or enforce violations of our user agreement or to prevent physical harm or illegal activity.
- Other financial institutions, to jointly offer a product, such as Umopay Credit, Umopay Savings, Umopay Cashback Mastercard and Umopay Extra Mastercard.
- Card networks and payment processors, to facilitate payment processing or to add cards to your electronic wallet.
- Fraud prevention and identity verification agencies, for example to assist us in detecting activities suggestive of fraud.
- Credit reporting and debt collection agencies, for example to collect unpaid overdue debts through a third party such as a debt collection agency.
- Service providers that operate at our direction and on our behalf to perform services we outsource to them, such as processing payments, marketing, research, compliance, audits, corporate governance, communications, IT development, maintenance, hosting and support and customer service operations.
- Other Users in accordance with your Account Settings. You may choose to display or make certain information available to other Users, such as your profile photo, first and last name, username, or city in accordance with your Account Settings.
- Connected accounts, for example any social media accounts you asked us to connect or when you initiate an Account connection with another bank or financial institutions, card account, or aggregator in connection with your participation in Open Banking, so we can check if you have sufficient funds or confirm your ownership of the account.
- Partners and Merchants, their service providers and others involved in a transaction, for example when you use the Services to initiate online purchases, pay other Users, or return goods we may disclose information about you and your Account with the other parties (or their service providers) involved in processing your transactions. Please note that Personal Information shared with Partners and Merchants (or their service providers) involved in a transaction is subject to the Partners and Merchants own privacy policy and procedures.
- Other third parties, for example we disclose Personal Information to advertising platforms at your direction, or security service providers to help prevent unauthorized access to our Services. Please be aware that these parties’ privacy notice applies to the Personal Information that you share directly with them. For example, we may use Google’s reCAPTCHA or similar products to prevent misuse of our Services, when you access our mobile application. We may also use Google Address Autofill to ensure accuracy of your address. Google’s Privacy Policy and Terms of use apply to the Personal Information you share with them.
- Buyers or in connection with business transfer, for example if we are involved in a merger, a purchase or sale of all or part of our business or assets, we may disclose your Personal Information to a buyer of those business or assets. If Umopay or a significant portion of Umopay’s assets are acquired by a third party, Personal Information may also be disclosed.
We may disclose your sensitive personal information as appropriate to carry out legitimate business activities allowed by law.
How long does Umopay store your Personal Information?
We retain Personal Information for as long as needed or permitted in context of the purpose for which it was collected and consistent with applicable law. The criteria used to determine our retention period is as follows:
- Personal Information used for the ongoing relationship between you and Umopay is stored for the duration of the relationship plus a period of 10 years, unless we need to keep it longer, such as:
- a legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under applicable bankruptcy laws and AML obligations
- litigation, investigations, audit and compliance practices, or to protect against legal claims.
How Do We Use Cookies and Tracking Technologies?
When you interact with our Services, open email we send you, or visit a third-party website for which we provide Services, we and our partners use cookies and other tracking technologies such as pixel tags, web beacons, and widgets (collectively, “Cookies”) to recognize you as a user, customize your online experiences and online content, including to serve you interest- based advertising, perform analytics; mitigate risk and prevent potential fraud, and promote trust and safety across our Services. We use Cookies to collect your device information, internet activity information, and inferences as described above. You can disable or decline some cookies for our Services. But, since some parts of our service rely on cookies to work, those services could become difficult or impossible to use. Some web browsers have an optional setting called “Do Not Track” (DNT) that lets you opt-out of being tracked by advertisers and some third parties. Because many of our services won’t function without tracking data, we do not respond to DNT settings.
Your Data Protection Rights Your rights to access, correction, deletion, and restriction to use or share your information.
Under applicable data protection law, you have certain rights to how your Personal Information is collected, stored, used and shared.
We recognize the importance of your ability to control the use of your Personal Information and provide several ways for you to exercise your rights to access (right to know), correction, deletion (erasure), and to restrict certain information (right to opt out of sharing and right to limit use and disclosure of sensitive personal information).
We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights. If you are a California resident, learn more about how we have handled your Privacy Rights.
How do you exercise your rights?
If you, or an authorized agent, want to exercise any of your rights relating to your Personal Information, contact us or submit your request from your Account. If you have an account, you can contact us in the Umopay app.
Even if you do not have an account (for example, where you use Payment without a Umopay account), you can submit a request for access, correction, or deletion of your information for your Payment without a Umopay account by contacting us from the umopay website of app. If you or an authorized agent submit a request, we’ll first need to verify who you are before we can respond to your request. We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will compare the information you submit against our internal business records to verify your identity. If we can’t verify your identity, we will not be able to fulfill your request. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process.
Your right to request a copy of the Personal Information. If you want to make a request to know about the data we’ve collected about you in the past 12 months, you have choices:
- Log in to your account and submit a request
- Call or contact us and request that we provide you with the data we’ve collected.
Your right to correct your Personal Information:
- Log in to your account and correct information you previously added. For example, you can edit your addresses in your settings
- Call or contact us and request that we correct specific information
Your right to delete your Personal Information:
- Log in to your account and delete information you previously added. For example, you can delete your profile picture and non-primary addresses in your settings
- Call us or contact us and request that we delete specific information
- Close your account
If you close your account or request that we delete Personal Information, we still need to keep some Personal Information as state in the How long does Umopay store your Personal Information section so we can:
- Complete a transaction, provide goods or services you requested, or comply with our promises to you in the user agreement or other contract you have with us
- Detect and prevent malicious, fraudulent, or illegal activity
- Protect your (or another person’s) legal rights, including the right to free speech
- Manage our internal business processes that are reasonably related to your expectations when using our Services
- Comply with laws and other legal or governmental processes
Understanding your choices
You can control how Personal Information is collected or disclosed, as well as how we communicate with you. Here are some of the ways you can customize your choices.
Choose how we collect Personal Information You may choose to limit the Personal Information you provide when our apps or Services request it. To help make choices that are right for you, it’s important to understand that Personal Information helps us provide a richer, more personalized experience for you. Also, some Personal Information is required for our Services to function at all. For example, sharing your contacts helps make it easier for you to find the people you want to send money to. If you choose not to share your contacts with us, you can still use our mobile apps, but some actions may not be as fast or easy as it would be if shared your contacts. Another example is creating an account with us. If you choose not to provide information that is required for an account to function, like your name and email address, we will not be able to create an account for you. Choose how connected accounts collect and use Personal Information If you connect your account to a third-party service, you may be able to manage how your Personal Information is collected, used, and shared by them. Read the third parties’ privacy policies to see the choices they offer you. You can control which third-party services you connect to your account and what Personal Information they can collect about you. For example, to manage the permissions, go to the Security settings in your Umopay account.
Choose how we communicate with you Your choices about how we communicate with you differ depending on the purpose of the message and how it is delivered. Some messages are considered optional, and some are necessary for you to manage your accounts with us. We use email, text messages, push notifications on your mobile device, and even phone or paper mail depending on the situation and your preferences.
You won’t be able to opt out of messages that are considered necessary for the Services, such as digital receipts and emails that alert you to changes in your account’s status. You may be able to decide how we send those messages, such as by email, phone, text message, or a notification on your mobile device.
How Do We Protect Your Personal Information? We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Information against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Information we maintain about you is accurate and current. We are not responsible for protecting any Personal Information that we share with a third-party based on an account connection that you have authorized.
Can Children Use Our Services?
We do not knowingly collect information, including Personal Information, from children under the age of 13 or other individuals who are not legally able to use our Services. If we obtain actual knowledge that we have collected Personal Information from someone not allowed to use our Services, we will promptly delete it, unless we are legally obligated to retain such data. Please contact if you believe that we have mistakenly or unintentionally collected information from someone not allowed to use our Services.
We do not sell to third parties for money or share Personal Information of anyone under 16 years of age for cross context behavioral advertising.
Contacting Umopay
If you have questions about this Privacy Statement or your Personal Information, contact us so we can help. Use the “Support” button on our web portal or mobile app to contact us.
Definitions
- Device Information means data that can be automatically collected from any device used to access the Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device IP address; information about your device’s web browser and internet connection you use to access the Services; Geolocation Information; information about apps downloaded to your device; and biometric data.
- Geolocation Information means information that identifies, with precise specificity, your location by using, for instance, longitude and latitude coordinates obtained through your GPS, or your device settings.
- Location Information means information that identifies, with reasonable specificity, your approximate location by using, for instance, longitude and latitude coordinates obtained through GPS or Wi-Fi or cell site triangulation.
- Partners and Merchants means our partners and the merchants, partners or businesses that our Users transact with for the purpose of obtaining goods or services.
- Pay without a Umopay account means our Services may be accessed by individuals without a Umopay account or profile.
- Personal Information in this Privacy Statement means information about you, including your identity, finances and online behavior.
- Services means any Umopay branded or Unbranded Payment Services, Pay without a Umopay account, Rewards, sending or receiving money, pay bill, content, features, technologies, or functions, and all related websites, applications and services offered to you by Umopay. Your use of the Services includes use of our websites or mobile app.
- Sharing under California law is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites.
- Sites means the websites, mobile apps, official social media platforms, or other online properties through which Umopay offers the Services and which has posted or linked to this Privacy Statement.
- Umopay means the payment service product of Softmasters Company Limited.
- User is any person who uses the Services as a consumer for personal or household use. For the purposes of this Notice, “User” includes “you” and “your.”