Our Privacy Policy

Pesapeer Inc., doing business as Pesa (“Pesa”, “we”, “us”, “our”), is committed to protecting the privacy and Personal Information (as defined herein) of all users and visitors to its website (“Users”), and individuals using its products and services (“Customers”). This Privacy Policy explains how we collect, use and share the Personal Information of our Customers and Users (collectively, “you” and “your”), and outlines the rights and obligations of parties with respect to Personal Information disclosed in the use of our Services, mobile application, and visiting the website (collectively, the “Services”).
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This Privacy Policy is incorporated by reference, is part of and subject to the Terms of Use. Any capitalized term used herein but not defined will have the meaning ascribed to it in the Terms of Use.

COLLECTION OF PERSONAL INFORMATION

In this Privacy Policy, “Personal Information” means any information that can identify or is capable of being associated with a particular identifiable individual.

Personal Information we may collect

We collect Personal Information when you access and interact with us through the Services or through online or other communication channels, including for example, when you create a Pesa Wallet, interact with our customer support, or provide feedback. We may collect the following Personal Information directly from you:

• Contact details: your name, email address, postal address, and phone number;
• Personal details: date of birth, passport number or other form of identification information;
• Financial information: your bank account number and financial history;
• Your image in photo form: we may collect facial scan data extracted from your photo (known as ‘biometric data’);
• The content of your communications with us: emails and online chat messages;
• Online identifiers: IP address, advertising ID, unique device ID, and other information about your device, and internal and third-party IDs that have been assigned to you;
• Source of Funds: information regarding the source of funds or source of wealth, which may include a copy of your bank account statements; and
• Other information we may collect and use with your prior consent for the appropriate provision of our Services.

You may refuse to provide us with your Personal Information. However, some Personal Information is necessary to provide you with our Services.

Personal Information we may collect automatically

Like many other websites, we use technologies to automatically collect technical data from Users and Customers of our Services. In particular, we may send a small text file to your computer called a “cookie” that identifies your browser to our server when you visit various pages of the website. Cookies are used to better serve you when you return to our website, and in some cases, these allow our Website to function. Many web browsers automatically accept cookies, but as part of the privacy settings of your browser, you can usually choose to decline to accept certain cookies as well as prevent third-party websites from accessing our Cookies. Any cookie sent to your computer by us in connection with your use of the Website does not give us access to your computer or to any Personal Information. Please be aware that disabling your browser’s ability to collect cookies from us may limit your ability to use all of the features provided on the Services.

We also use third-party analytics services to help us to better understand and improve the functionality of our website on your computer or other device. Analytics may record data such as the frequency of use of our website, which features are used and not used, aggregated usage and performance data. This data is generally unidentifiable and cannot connect to you.

We are not liable for or with respect to misuse of the Services by any Customer or User, nor third party risks beyond our control that may affect Personal Information.

Our Services might include links to third-party websites. When clicking on those links, these third-parties may collect your Personal Information. If any part of the Services links to other websites, this Privacy Policy does not apply, and you are solely responsible for understanding the privacy policies related to such other websites.  Please refer to the third-party’s Privacy Policy for information on the type of Personal Information it collects, and how it uses or discloses it and for information on its privacy practices. Any links to third party websites are for informational purposes only, and we do not endorse and are not responsible for any linked website.

USE OF PERSONAL INFORMATION

We may collect, use and disclose Personal Information for purposes of:

• providing you with the money transfer and Pesa Wallet services that you’ve requested;
• improving the usability, performance and effectiveness of the Services;
• establishing your identity and protecting you and us from error and fraud;
• troubleshooting and resolving problems;
• sending marketing communications to you about offers, products, services, and updates;
• monitoring your use of Services and enforcing the Terms of Use;
• detecting, preventing or investigating security breaches or fraud;
• complying with legal and regulatory requirements, such as complying with “Know Your Customer” obligations under anti-money laundering laws; and
• as otherwise may be described to you at the time of collection;

We may collect, process, store, analyze and use aggregate data for purposes of:

• monitoring and analyzing use of Services generally, and for the improvement, enhancement and  technical administration of the Services;
• increasing functionality and user-friendliness of the Services to provide a more relevant and useful Site experience for Users, and better tailoring the Services to needs of Customers; and
• performing statistical analyses and generating useful data and information concerning the interests, characteristics and use behaviour and characteristics, in order to measure interest in and use of the Services.

We may publish and make available to the general public any feedback you submit.

DISCLOSURE AND SHARING OF PERSONAL INFORMATION

We will not disclose your Personal Information to third parties without your prior consent, except: i) in accordance with the terms of this Privacy Policy, or ii) to comply with legal requirements such as a law, regulation, warrant, subpoena or court order, and/or iii) if you are reporting an adverse event, in which case we may be required to disclose such information to bodies such as, but not limited to, Canadian and/or international regulatory authorities.

We may share Personal Information:

• to our affiliates, third party service providers and business partners to provide and support the Services. Service providers include those:
  • that help us operate our Services;
  • that offer services such as payment processing and fraud prevention providers;
  • that assist us with data processing, document management or storage; and
  • that assist us with marketing campaigns, data analytics and digital and other marketing; and
• to competent government, law enforcement or other authorities (i) if required as a matter of applicable law or regulation, or as a result of legislative, judicial or administrative requirements or changes; or (ii) if we determine in good faith that disclosure is necessary to exercise or defend its legal rights or those of its Users or Customers;
• to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger, restructuring, consolidation, change in control, liquidation, reorganization, transfer or acquisition of any part of our business, provided that the buyer agrees to use such Personal Information only for purposes outlined in this Privacy Policy.

Where we share your Personal Information with third-parties, these parties are under legal and contractual obligations to comply with applicable privacy and data protection legislation, to protect your Personal Information, to only use the Personal Information for the purposes in which it was transferred.

PROTECTION AND RETENTION OF PERSONAL INFORMATION

While we cannot guarantee absolute security of all Personal Information, we have implemented various physical, technical and administrative security procedures to protect your Personal Information and prevent unauthorized access. Access to Personal Information is restricted to select authorized employees and representatives on a need-to-know basis, and who are trained to handle Personal Information, and third party suppliers who are contractually bound to protect Personal Information and use only for purposes related to the Services, according to applicable legislation. Notwithstanding the foregoing, you acknowledge, agree and accept that no transmission of information or data via the internet is completely secure, no matter what steps are taken, and Pesa does not guarantee or warrant the security of any information that you provide to us.

We take reasonable steps to ensure that the Personal Information in our custody is accurate and up-to-date for the purposes for which the information was collected. While we rely on you to provide us with accurate Personal Information, we will make every reasonable effort to keep your Personal Information accurate and up to date, for the purposes for which the information was collected.

As a licensed and regulated Money Services Business, Pesa is required by law to store some of your personal and transactional data beyond the closure of your account with us. Typically we are required to retain Personal Information for between seven and ten years following account closure, depending on applicable laws. Personal Information is retained during the period that the Customer’s account for the Services is active, and may be kept following termination of Services in accordance with our policies in order to comply with laws, prevent fraud, resolve disputes, assist with any investigations, troubleshoot problems, and take other actions otherwise permitted by law. Thereafter, at our discretion, we may delete or anonymize Personal Information.

LOCATION OF PERSONAL INFORMATION

We are based in Canada and the Personal Information we collect through our Services is processed in accordance with Canadian data protection laws. Our servers are hosted with Google Cloud, and your Personal Information may be stored and processed on servers located in the United States. As a provider of money transfer services and multi-currency accounts, it is sometimes necessary to transfer your Personal Information to countries other than your country of residence. Whenever we transfer your Personal Information outside of Canada, we take all reasonable steps to ensure that such information will not be used for purposes not relevant nor communicated to you, except in cases where permitted under applicable laws.

If you are accessing the Services from the EEA, the UK or other regions with laws governing data collection and use, please note that in connection with our business and for administrative, management and legal purposes, we may transfer your Personal Information from the country where you reside to the servers indicated above. Where we transfer your Personal Information as described above, we will take steps to ensure that your Personal Information receives adequate security protection where it is processed and your rights continue to be protected pursuant to the applicable data protection law. In some cases, transfers of your personal data to us is necessary to perform the agreement we have entered into, or are about to enter into, with you. If you would like to receive more information on the safeguards that we implement as described above, please contact us as indicated below.

YOUR RIGHTS; OPTING OUT

You may at any time contact us for further information regarding this Privacy Policy and our practices regarding the handling of Personal Information.

At any time, you also have the opportunity to request information on the types of Personal Information we hold about you, what it is being used for, and with whom it has been shared. You may also request access to your Personal Information currently held by us. We will provide you with access to your Personal Information, subject to certain exceptions such as: any personal information about another individual that cannot be separated from yours, any information subject to solicitor-client privilege, commercially confidential information, information that may threaten life or security of an individual, or information collected for purposes related to an investigation of a breach of an agreement or contravention of law.

If you notice any inaccuracies or wish to update or complete any part of your Personal Information, you may request the correction or update of that information. When appropriate, the amended information will be transmitted to any third-parties having access to the Personal Information in question.

The way in which we will give you access to your Personal Information may vary, depending on the format in which we hold it and the amount of information. We may provide your information in physical or electronic format. In the case of an exceptionally large file, we may provide you a summary of the information.

At any time, you may withdraw your consent to the collection, use, of your Personal Information, subject to contractual or legal restrictions. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We do not sell Personal Information, and we do not discriminate against anyone who chooses to opt-out of data collection. In addition, you may at any time opt-out of any communications received from us by clicking on the “unsubscribe” link in the e-mails, or email us at support@pesapeer.com.

If you wish to exercise any of these rights, please contact us as per the below. We may require you to verify your identity and provide such other details before responding to such requests, as may be required by law. In the event that we are unable to provide certain Personal Information (for example where the information contains references to other’s Personal Information that is not easily severable, or which cannot be disclosed for legal, security or other commercial proprietary reasons), we will provide a justification.

CHILDREN’S PRIVACY

We do not knowingly collect or solicit Personal Information from children under the age of 18, nor allow them to use or request information through the Services. If you believe we have collected information from a minor in error or have questions or concerns about our practices relating to children, please notify us and we will promptly respond.

UPDATES TO PRIVACY POLICY

This Privacy Policy may be updated or modified at any time to reflect changes to our privacy and data management practices, products and Services, and/or feedback as may be required by law or determined by us, and any changes will be a posted on the Site.

If we change the way we handle your Personal Information, we will update this Privacy Policy and notify you or seek your consent as and when appropriate.

CONTACT US

We welcome any comments, requests and questions regarding this Privacy Policy and any of its practices regarding Personal Information. Any questions or concerns regarding our use of Personal Information, to obtain access to or request changes to Personal Information, or to amend or withdraw your consent to the collection or use of Personal Information by us, may be addressed to privacy@pesapeer.com.