This Privacy Policy explains how CT Pay ("we", "us" or "our") handles personal information in connection with our white-label wallet and payments platform and the websites, applications and services that make up it (together, the "Platform"). It is provided as a generic, illustrative template and should be adapted to your jurisdiction and reviewed by a qualified adviser before use.
CT Pay provides the underlying technology that operators use to run their own branded payments businesses. Where an operator uses the Platform to serve its own members, merchants and end-users, that operator is the data controller for those individuals and CT Pay generally acts as a data processor on the operator's behalf. This policy describes our own practices; an operator's own privacy notice governs its relationship with its end-users.
We collect information needed to provide, secure and improve the Platform. The categories vary by role and how the Platform is configured by each operator.
We use information to operate the Platform, authenticate users, process transactions, provide support and keep the service secure and reliable.
We do not sell personal information. We share information only as needed to run the Platform or where required by law.
Security is built into the core of the Platform rather than added afterwards. We apply administrative, technical and organisational measures designed to protect information against unauthorised access, alteration, disclosure or loss.
No method of transmission or storage is completely secure, so we cannot guarantee absolute security; we work continuously to strengthen our safeguards.
We retain personal information for as long as needed to provide the Platform and for legitimate business and legal purposes, such as meeting regulatory, accounting and audit obligations. Where we act as a processor, retention periods for end-user data are generally determined by the relevant operator. When information is no longer required, we take steps to delete or anonymise it.
Depending on your location and role, you may have rights over your personal information, such as the right to access, correct, delete, restrict or object to certain processing, and to data portability.
Where CT Pay acts as a processor on an operator's behalf, requests relating to end-user data should usually be directed to the relevant operator, who is the controller. We will support operators in responding to such requests. To exercise rights in relation to information we control, please contact us using the details below.
The Platform may be operated and supported from, and information may be processed in, countries other than where you are located. Where information is transferred across borders, we put appropriate safeguards in place, such as recognised contractual mechanisms, to help ensure a consistent level of protection.
We may update this Privacy Policy from time to time to reflect changes to the Platform, our practices or legal requirements. When we do, we will revise the "Last updated" date above and, where appropriate, provide additional notice. We encourage you to review this policy periodically.
If you have questions about this Privacy Policy or our handling of personal information, you can reach us at [email protected]. If you are an end-user of an operator's branded service, please contact that operator directly, as they are the data controller for your information.