Banking Services Data Sharing Notice
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DRAFT — pending legal review.
This notice explains what data Niftipay Ltd ("Niftipay", "we") shares with Glacierpay Inc. ("GlacierPay") when you use the banking, payout and wallet services available through your Niftipay account, why we share it, and where it is processed. It should be read together with our Privacy Policy.
1. Who provides the banking services
GlacierPay is an Ontario corporation registered with the Financial Transactions and Reports Analysis Centre of Canada as a money services business under registration number C10001598, with an office at 320 Matheson Blvd West, Suite 211, Mississauga, Ontario L5R 0H2, Canada.
GlacierPay — not Niftipay — provides the account identifiers, wallets, payouts, settlement and currency conversion you use through these features. GlacierPay contracts with you directly for them, performs its own compliance checks, and decides whether to approve each customer and each transaction. Niftipay operates the interface and transmits your information and instructions. Niftipay does not hold your funds and does not make GlacierPay's regulatory decisions.
2. What we share
To let you apply for and use those services, we disclose to GlacierPay:
- Business and identity information — your company's legal name, legal form, registered address, registration and tax numbers, the directors and ultimate beneficial owners you have told us about, and the identity documents you or they have provided.
- Business activity information — what the business sells, the countries and currencies it trades in, the source of its funds, the purpose of the account and its expected activity.
- Device and session information — the IP address, device and session details recorded when you sign in and when you confirm a payout, a withdrawal or a change of payout destination, together with the time of that confirmation and the method used to authenticate it. This is the evidence GlacierPay requires that an instruction came from you.
- Financial, wallet and transaction information — your account identifiers and balances, the payout destinations you register, and the details of each payment, including the originator and beneficiary information that transfer-of-funds and travel rules require.
3. Why we share it
We share it to perform our contract with you — without it the banking features cannot be provided — and to allow GlacierPay and its providers to meet their own legal duties under anti-money-laundering, counter-terrorist-financing, sanctions and payment-services law. Some of those duties require GlacierPay to contact, verify or request information from you directly.
4. Who else may receive it
GlacierPay uses its own providers to deliver these services, and may disclose what we send to them: banks, payment and electronic-money institutions, payment schemes and correspondents, liquidity and execution providers, wallet technology and custody providers, blockchain analytics providers, and identity-verification providers. GlacierPay chooses these providers; we are told which services they support, not always which supplier performs them.
5. Where it is processed
GlacierPay is established in Canada, so this data is transferred outside the European Economic Area and the United Kingdom and processed there, and may be processed in other countries where GlacierPay's providers operate. Canada benefits from a partial adequacy decision of the European Commission for recipients subject to PIPEDA; where a transfer is not covered by that decision, it is made under the European Commission's Standard Contractual Clauses or another transfer mechanism permitted by applicable law.
6. How long it is kept
We keep the records of these instructions, confirmations and transactions, and the evidence of this notice, for at least seven years after the later of the transaction or the end of our relationship, because the financial-services rules that apply to these features require it. GlacierPay applies its own retention periods to what it holds.
7. Your rights, and what happens if you decline
You keep every right described in our Privacy Policy, including access, correction, erasure where the law allows it, restriction, objection and portability, and the right to complain to a supervisory authority. Some of those rights are limited where we or GlacierPay must keep records to comply with financial-services law.
Accepting this notice is not a condition of using Niftipay's payment-acceptance products. It is a condition of using the GlacierPay-provided banking, payout and wallet features: if you do not accept it, we will not submit your business to GlacierPay and those features stay unavailable.
8. Contact
Questions about this notice, or about data GlacierPay holds about you, can be sent to [email protected]. Requests that concern GlacierPay's own processing may have to be forwarded to GlacierPay, and we will tell you when that happens.