Privacy Policy

1. Data Controller

The Data Controllers for the collection, processing, and use of personal information are listed in the table below. If you have any questions about how we protect or use your data, please email us at privacy@vpay.life

2. Data we collect about you

Examples of Communications include:
* You may give us information about yourself when you sign up to use our Services,
e.g., when you provide us with personal details, including your name and email
address. This also includes information you provide through your continued use of
our Services, your participation in discussion boards or other social media functions
on our Website or App, through entering a competition, promotion, or survey, and
by reporting problems with our Services. The additional information you give us for
security, identification, and verification purposes may include your address, phone
number, financial information (including credit card, debit card, or bank account
information), payment reason, geographical location, social security/insurance
number, national identification number, personal description, photograph,
passport and/or National ID. If you fail to provide any of this information, it might
affect our ability to provide our Services to you.
* The content of your communications with us, which we collect via telephone call
recordings, online chat, emails, direct messaging, and other means.
* In some cases, including when you send or receive high-value or high-volume
transactions or where we need to comply with anti-money laundering regulations,
we may also need more identification information from you, including a copy of
your bank account statements.
* In providing the personal data of any individuals other than yourself, including
connected persons, you confirm that you have obtained consent from such
individuals to disclose their personal data to us or our other vPay.Life entitled to
provide this information to us. You also confirm that you have brought this Policy
to their attention if legally necessary and have received their consent to our
collection, use, and disclosure of such personal data for the purposes set out in this
Policy. The term ‘connected person’ means an individual connected to vPay.Life
through the use of our Services and could be an account holder, payment
beneficiary, recipient of a designated payment, guarantor, director, shareholder,
partners or members of a partnership, trustee, authorized signatory of a
designated account, a friend you have recommended, individuals in your contact
list or any other person who has a relevant relationship with vPay.Life.
* Please ensure that your personal data is current, complete, and accurate by logging
onto your account and updating it whenever necessary.
* Details of the transactions you carry out when using our Services, including the
geographic location from which the transaction originates;

3. How we protect your personal information

We restrict access to your personal information to those employees of vPay.Life who
have a business reason for knowing such information and third-party service providers
processing data on our behalf. All vPay.Life employees who have access to your personal
data are required to adhere to this Policy, and all third-party service providers are
requested by vPay.Life to ensure appropriate safeguards are in place. In addition, contracts
are in place with third-party service providers that have access to your personal data to
ensure that the level of security and protective measures required in your jurisdiction are
in place and that your personal data is processed only as instructed by vPay.Life.

4. Ways we use your information

* Lawful basis for processing, including basis of legitimate interest: Legal obligation
Necessary to fulfill our obligations under a contract Legitimate interest (to be efficient
about how we meet our legal obligations and to comply with regulations that apply to us)
Credit protection, including the provisions of the relevant legislation
* The regular exercising of rights in judicial, administrative or arbitral proceedings
* We collect basic details, like your name and contact info, as well as data on how
you use our services. This information is gathered directly from you or automatically
through cookies on our website. We use it solely to provide and improve our services,
keep you updated, and support your experience. We do not share or receive your
information from third parties or affiliates for marketing. Additionally, any SMS opt-in
information or phone numbers provided for SMS communication will never be shared,
under any circumstances.

5. Hardware and Software Requirements

Examples of Communications include:
* affiliates, business partners, suppliers, and sub-contractors for the performance
and execution of any contract we enter into with them or you and to help them
improve the services they provide to us or for any service we are required to
perform by banks partner or regulations ;
* advertisers and advertising networks to select and serve relevant adverts to you
and others;
* analytics and search engine providers that assist us in the improvement and
optimization of our site;
* limited information is sent to payment beneficiaries when you initiate a payment
transaction;
* if we are under a duty to disclose or share your personal data in order to comply
with any legal obligation, or in order to enforce or apply our Customer Agreement
and other applicable agreements, or to protect the rights, property, or safety of
vPay.Life, our customers, our employees or others;
* to prevent and detect fraud or crime and to assist us in conducting or cooperating
with investigations of fraud or other illegal activity where we believe it is
reasonable and appropriate to do so. Please note that if we, or a fraud prevention
agency, determine that a fraud or money laundering risk is posed, we may refuse
to provide the services requested, or we may stop providing existing products and
services to a customer. A record of any fraud or money laundering risk will be
retained by the fraud prevention agencies and may result in others refusing to
provide services.

6. Sharing and storing your personal data

* In the above cases, we ensure that appropriate safeguards, including Standard
Contractual Clauses and/or International Data Transfer Agreements, are in place. A
copy of these documents can be provided by sending a request to privacy@vpay.life

7. Cookies

vPay.Life Website uses cookies to track traffic coming to our site. We do not collect
personal data such as name, age, telephone number, e-mail, or mailing address. Cookies
will also be used to identify a person who chooses to register on our site. If you choose to
register on our site and are given a password, choose to give gifts online, or choose to
enroll in our e-mail subscription services, we will identify you with cookies. You will always
have a chance to opt out at any time.

8. Data retention

We will retain your personal data only for as long as is necessary to fulfil the
purposes for which we collected it. As a regulated financial institution, vPay.Life is required
by law to store some of your personal and transactional data beyond the closure of your
account with us. We only access your data internally on a need-to-know basis, and we’ll
only access or process it if absolutely necessary.

9. Your rights

Laws applicable in your jurisdiction may grant you certain rights regarding the
information we hold about you. If you have any questions in relation to our use of your
personal information, contact us at privacy@vpay.life.

10. Managing communications

Marketing communications: Depending on the nature of our relationship and the
Services being used, we may send you marketing and other promotional communications
for new or existing Services that we think you might be interested in. These marketing
communications may include marketing text messages if you have opted in to receiving
them. You can opt out of or unsubscribe from any marketing communications by
following the instructions in those messages, by changing your communications
preferences within your account or through your device. You can also opt out by
contacting us at privacy@vpay.life. Opting out of one communication will not
necessarily opt you out of all marketing communications. Please note that you may still
receive certain non-marketing communications after opting out. These messages may
include transaction-specific communications, messages as part of a loyalty program or
account-specific communications. If you are located outside the United States, we will not
send you direct marketing communications without your opt-in consent or as otherwise
permitted under the applicable law.

Data Controllers

Country or
Region

USA

Entity

ITSP HUB LLC
(DBA vPay.Life)

Registered Office
and Details

2590 Hollywood Blvd.
Hollywood, Florida 33020
privacy@vpay.life

Country or
Region

Federal Trade
Commission (FTC)
www.ftc.org