California Consumer Privacy Act Disclosure
Effective: January 1, 2020
Rights for California Residents
To exercise one or more of your rights, you or someone you authorize, may email us at privacy@wepay.com or visit https://visit.wepay.com/ccpa-inquiry.html and follow the instructions provided.
If you are a California resident you may have certain rights under the California Consumer Privacy Act (Cal. Civ. Code §1798.100 et seq.) regarding your personal information, including:
- the right to request the specific pieces of personal information we collected about you; the categories of personal information we collected; the categories of sources used to collect the personal information; the business or commercial purposes for collecting your personal information; and the categories of third parties with whom we share your personal information each as it pertains to our activities in the preceding twelve (12) months
- the right to request, on legitimate grounds, deletion of your personal information that we collected;
- the right to have someone you authorize make a request on your behalf; and
- the right not to be discriminated against for exercising any of these rights.
We also must provide in this online disclosure certain details about our collection and handling of categories of personal information. The tables that follow show the types of personal information we may collect about California residents who are subject to the CCPA, the sources from which we collect it, and the ways in which we use and disclose it.
Personal Information
Categories of Personal Information |
Personal identifiers, including those listed in other California statutes: Real name; alias; Social Security number; passport number; other government issued number; Green Card number; driving license number; telephone number; email address; postal address; account name; online identifier; device identifier; IP address |
Characteristics of protected classifications: date of birth/age; gender; military or veteran status; marital status; nationality; citizenship; request for family care leave; request for leave for employee’s own serious health condition; request for pregnancy leave |
Biometric information: fingerprint; voice recordings; keystroke patterns and rhythms |
Professional or Employment: title; salary; employment files; references |
Education information: details of your education and qualifications |
Financial details: bank account numbers; debit/credit card numbers; cardholder or accountholder name and details; transaction details |
Commercial Information: records of personal property; products and service purchased, obtained or considered; purchasing or consuming histories or tendencies |
Internet or other electronic network activity information: browsing history, search history, information regarding your interaction with a website, application or advertisement |
Geolocation data: any information used to identify your physical location |
Communications, recordings, images: audio, electronic, visual |
Inferences: Any derivation of information, data, assumptions, or conclusions drawn from any of the above categories used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
Our Sources of Personal Information
Category of Sources from which we Collect Personal Information |
We obtain your personal information when you provide it to us (e.g., where you contact us via email or telephone, or by any other means) |
We collect your personal information in the ordinary course of our relationship with you (e.g., in the course of managing your transactions) |
We collect personal information that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible) |
We receive your personal information from third parties who provide it to us (e.g., our customers; credit reference agencies; and law enforcement authorities) |
We receive your personal information from third parties, where you purchase any of our products or services through such third parties |
We collect or obtain personal information when you visit any of our websites (“Website”) or use any features or resources available on or through our Website. When you visit our Website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our Website and other technical communications information), some of which may constitute Personal Data |
Use of Information
Business and Commercial Purposes for Use of Personal Information |
AML/KYC: fulfilling our regulatory compliance obligations, including ‘Know Your Client’ checks; and confirming and verifying your identity (including by using credit reference agencies); and screening against government, supranational bodies and/or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions |
Client on-boarding: on-boarding new clients; and compliance with our internal compliance requirements, policies and procedures |
Provision of products and services to you: administering relationships and related services; performance of tasks necessary for the provision of the requested services; communicating with you in relation to those services |
Marketing / Prospecting: communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate |
Operation of our Website: operation and management of our Website; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Website |
IT operations: management of our communications systems; operation of IT security; and IT security audits |
Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations |
Financial management: sales; finance; corporate audit; and vendor management |
Research: conducting market or customer satisfaction research; and engaging with you for the purposes of obtaining your views on our products and services |
Security: physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems) |
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law |
Legal compliance: compliance with our legal and regulatory obligations under applicable law |
Legal proceedings: establishing, exercising and defending legal rights |
Improving our products and services: identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services |
Risk Management: Audit, compliance, controls and other risk management |
Fraud prevention: Detecting, preventing and investigating fraud |
Disclosure of Information
Categories of Third Parties to Whom Personal Information is Disclosed |
You and, where appropriate, your family, your associates and your representatives |
Anti-fraud services |
Accountants, auditors, financial advisors, lawyers and other outside professional advisors to WePay, subject to confidentiality |
Debt-collection agencies and tracing agencies |
Data aggregation services |
Accreditation bodies |
Third party service providers (such as payment services providers; etc.) |
Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required |
Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties |
Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation) |
Sale of Personal Information
WePay does not offer an opt-out from the sale of personal information because WePay does not engage in the sale of personal information as contemplated by the CCPA. As noted elsewhere in this disclosure, we share personal information with other businesses for a variety of reasons. While we often benefit from such exchanges, we do not share personal information for the sole purpose of receiving compensation for that information.
Changes to this Disclosure
We may change this disclosure from time to time. When we do, we will let you know by appropriate means such as by posting the revised disclosure on our CCPA website with a new “Last Updated” date. Any changes to this disclosure will become effective when posted unless indicated otherwise.