Privacy Policy

This Privacy Policy ("Policy") governs processing of information, including personal data, relating to the data subjects ("you", "User") of the https://www.onbilia.com website ("Site"), Onbilia mobile app ("App") and other services, including but not limited to wallet and prepaid card services (collectively hereinafter "Service").

The company that provides you the Service, as identified on the Onbilia Services Agreement page, is the company directly responsible for handling your personal data and is known as the controller of your personal data ("Onbilia", "we", or "us").

Information We May Process, Legal Basis and Purposes of Processing

Personal Information

We may process personal information of Users in a variety of ways, including, but not limited to, when users visit the Site, App, or use any of our Services; register on the Service; fill out any form; provide information for passing of anti-money laundering procedures or take any actions directly stipulated by the features of the Site or App.

We may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, and social media platforms for purposes of verifying your identity.

Categories of data involved in data processing include:

• Personal Identification Information: Name, e-mail, date of birth, citizenship, gender, utility bills, photographs, phone number, mailing address, ID or other documents' number and other details
• Payment Information: Bank information, card information, transaction history
• Employment Information: Employer details, job title
• Other data collected by cookies: See sections below regarding cookies

Information Collected Automatically

We may collect information about Users whenever they interact with our Service, for example, through the use of cookies. Such information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as IP address, location, date and time of connection, the operating system and the Internet service providers utilized and other similar information.

Web Browser Cookies

Our Site may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How We Use Information

We process aforementioned information relying on the following legal grounds:

• Where it is necessary to perform a contract with you for the provision of our Services
• Where it is necessary for compliance with our legal obligations across jurisdictions with regard to provision of financial services
• Where it is necessary for the purposes of our legitimate interests to prevent fraud, money laundering or unauthorized use of your account
• Where we have received your explicit consent as required by applicable law

And for the following purposes:

• To identify you as a client and distinguish you from other users of our Service
• To be able to continuously provide you with functional, secure, efficient, and customized service
• To operate and develop our Service
• To publish content and advertising on the Site and App
• To prevent losses and frauds
• To respond to you about any comment or enquiry you have submitted
• To comply with legal and regulatory requirements, including Know-Your-Customer (KYC) anti-money laundering (AML) requirements
• To provide you with customer and technical support
• To inform you about our and our partner's offers, products and to perform other marketing activity where we have received your consent

How Long We Retain Information

We store collected information for as long as it is necessary to perform our contractual obligations in order to provide products and services to you. If you decide to delete your account, do not use Services and choose to terminate contract with us, we keep your information and information on your transactions for up to 5 years after you delete your account for the compliance with the requirements of anti-money laundering laws and other legal acts.

In some cases, we can keep your information longer than 5 years: such exceeding can be used only in a case of arising of legal requirements that will oblige us to store your information for more than 5 years. Information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide products and services.

Please note that retention periods may be changed from time to time based on legal and regulatory requirements.

How We Share Collected Information

We sometimes need to share personal information we process with third parties. When necessary or required we may share information with authorities, other companies within the group of companies for internal administrative purposes, companies which the group cooperates with and to other third parties, such as third party service providers used in connection with our Services.

We may share collected information with:

• Credit reference agencies
• Identity verification, KYC and fraud prevention providers
• Debt collection and tracing agencies
• Banking and financial services partners and payments networks
• Suppliers and services providers (IT, payment, analytical, financial, etc.)
• Companies specializing in manufacturing, personalization, and delivery of Visa and Mastercard cards
• Government bodies and other recipients in order to comply with applicable law
• Courts and tribunals

Cross-border Transfers

We intend to transfer the collected information we obtain from you to recipients in countries other than the country in which the information has been originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.

The collected information may be transferred to a state outside Canada or the European Economic Area ("EEA"). For such transfers we use standard contract clauses or other suitable safeguard to permit data transfers from Canada the EEA to other countries. A copy of standard data protection clauses adopted by a supervisory authority may be obtained by request made to [email protected]

How We Store and Protect Collected Information

We adopt appropriate data collection, storage and processing practices and security measures to protect from unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. We use encryption to protect information and we grant access to information to our employees and third parties only when it is necessary for them to process said information.

However, the transmission of such data over the Internet using personal computers or mobile devices is not completely safe and therefore we cannot guarantee the security of documents submitted to our platform. Any transmission of such documents is at your own risk. As soon as we receive your information, we implement strict security measures and procedures to avoid unauthorized access from any third party.

Rights of Users

You have a right to request from us:

1. Access to information and update information
   You have a right to review information we keep about you and if you suppose that information is inaccurate or incomplete, you may contact us in order to update information.
2. Restriction of processing and erasure of your personal data
   If you believe that we are not entitled to use your information and you want to request its deletion or object to its processing, you may contact us.
3. Personal data in a structured, commonly used and machine-readable format

Please note that the above is subject to limitations by relevant data protection laws. You may exercise the aforementioned rights by sending a request to the e-mail address provided in the Contacts section.

Where the processing is based on consent, you have a right to withdraw such consent at any time. However, we might keep processing information if we have a legal basis for it.

Changes to the Policy

Onbilia has the discretion to update this privacy policy at any time. When we do, we revise the updated date at the top of the page. We may also post a notification on the main page of our Site and notify you by other means (for example, via email). We encourage Users to frequently check the page for any changes to stay informed about how we are helping to protect the personal information we collect.

What If I Do Not Want to Accept the Policy?

By using our Services, you acknowledge that we process information in the ways described by the Policy. If you do not agree to this policy, please do not use our Services. Your continued use of the Services following the posting of changes to this policy will be deemed as your acceptance of those changes.

If you already have registered an account on the Site, but you do not agree with the Policy, you shall terminate your account.

Contacts

If you have any questions about the Policy or would like to exercise any of your rights, please contact us at [email protected].