UPDATED ON March 1, 2019
Scope and Consent
This policy describes the ways GoodCoinPay, Inc. and its subsidiaries (GoodCoinPay B.V. and Stichting Client Funds BMSE, hereinafter, “GoodCoinPay”, “we”, “our” or “us”) collect, store, use and protect Personal Data. The purpose of this policy is to ensure that GoodCoinPay complies with applicable United States (US) federal and state regulations, and European Union (hereinafter, “EU”) data protection laws such as the General Data Protection Regulation (hereinafter, “GDPR”). GoodCoinPay’s Services include merchant processing services, products, or any other features, technologies or functionalities (hereinafter: “Services”) offered by GoodCoinPay, Inc.
This policy describes the ways GoodCoinPay, Inc. and its subsidiaries (hereinafter, “GoodCoinPay”, “we”, “our” or “us”) collect, store, use and protect Personal Data. The purpose of this policy is to ensure that GoodCoinPay complies with applicable United States (US) federal and state regulations, and European Union (hereinafter, “EU”) data protection laws such as the General Data Protection Regulation (hereinafter, “GDPR”). GoodCoinPay’s Services include merchant processing services, products, or any other features, technologies or functionalities (hereinafter: “Services”) offered by GoodCoinPay, Inc. Users accept this Policy by visiting our website and/or by using our Services.
There are six types of data subjects whose personal data we may process:
- Visitors of our websites (GoodCoinPay.com);
- Merchants that sign up for our Services;
- Shoppers who indirectly interface with GoodCoinPay when paying a merchant’s invoice that is forwarded by GoodCoinPay to merchants during checkout (refer to Section III.3 for more details);
- GoodCoinPay cardholders that have signed up for a GoodCoinPay Prepaid Visa® Debit Card;
- GoodCoinPay wallet users that have downloaded and installed either the GoodCoinPay or Copay app on their mobile device;
- Shoppers who indirectly interface with GoodCoinPay when requesting a cryptocurrency withdrawal via a Merchant that is using GoodCoinPay’s Services.
What is “personally identifiable information?”
“Personally Identifiable Information” (hereinafter: “Personal Data”) is any information that can be directly associated with a specific person and can be used to identify that person. A prime example of identifiable information is a person’s name.
What kind of personal data do we collect?
The Personal Data we collect depends on the type of user:
- Visitors: We may collect the following Personal Data for visitors of our websites (https://www.GoodCoinPay.com):
- IP address
- Email address (e.g. when you subscribe to our blog or opt in to receive other marketing materials)
- Phone number (e.g. when you contact our sales team or media team or opt in to our media list)
- Name (e.g. when you submit a support request)
- We may collect information about a visitor’s computer or other access devices for fraud prevention purposes.
- Merchants: When opening an account, we may collect the following types of Personal Data of the beneficial owner or any user that is added to the account:
- Email address
- Date of birth
- Identification documents (such as a passport or driver’s license)
- We may use this Personal Data for risk-management purposes (i.e. to verify merchant’s identity or address). We may also obtain information about our merchants from third parties such as credit bureaus and identity verification services. We ensure that such third parties adhere to the same data protection principles as GoodCoinPay.
- Shoppers of merchants: When a shopper is paying a GoodCoinPay invoice, the following Personal Data is captured:
- Email address
- IP addresses used to view the GoodCoinPay invoice
- The email address is either automatically provided by the merchant or manually entered by the shopper. This enables our system to send an email to Shoppers directly to obtain a cryptocurrency refund address in case of a payment exception (e.g. overpayments, underpayments, etc.). This creates a more seamless payment experience for both the merchant and the shopper.
- Additionally, only upon the merchant’s explicit request, we will collect and store Personal Data for the merchant’s benefit only and as a service through our invoicing service. Personal Data that merchants may request from the shoppers are:
- Phone number
- Additionally, for donations that are made through GoodCoinPay’s processing platform, the merchant might opt for GoodCoinPay to collect the following Personal Data as required by the US Federal Election Commission (FEC) or other applicable local regulations:
- Donor’s name
- Donor’s email address
- Donor’s address
- Donor’s phone number
- Donor’s employer
- Donor’s job title
- Donor’s city of employment
- In all cases mentioned above, Shoppers’ or Donors’ information is processed and stored according to the same principles as we process / store our merchant’s Personal Data.
- Cardholders: When a user signs up for a GoodCoinPay Visa® Prepaid Card, the following information is collected as part of the onboarding program:
- Date of birth
- IP address
- Phone number
- Email address
- Social Security Number
- Please note that our Card Program is currently only available to US residents. GoodCoinPay only stores date of birth and social security number until the time the card application is accepted or archived.
- Wallet holders: For wallet holders, GoodCoinPay collects the following Personal Data:
- Email address
- The email address collection is optional in case the user would like to receive email notifications and (if selected) GoodCoinPay news and product updates and can be removed at any point in time.
- Shoppers that use GoodCoinPay’s cryptocurrency withdrawal service: The following Personal Data is collected for shoppers that would like to process more than 3000 USD per day:
- Email address
- Identification documents (such as a passport or a driver’s license)
- Proof of address document (such as a bank statement or a utility bill)
Sensitive or special categories of personal data
GoodCoinPay does not process any sensitive personal information, such as religion, race, ethnicity and/or political views.
Why we collect personal information
Our primary purpose for collecting Personal Data is to provide you with a secure, smooth, efficient, and customized experience. We may use your Personal Data to:
- comply with applicable laws and regulations;
- provide the GoodCoinPay Services and customer support you request;
- process transactions and send notices about your transactions;
- resolve disputes, collect fees, and troubleshoot problems;
- customize, measure, and improve the GoodCoinPay Services and the content and layout of our website and applications;
- deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
- compare information for accuracy and verify it with third parties.
How we protect and store personal information
We take security of data very seriously. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to Personal Data only for those employees who require it to fulfill their job responsibilities.
- IT Security Policy: This policy describes how we store and process your Personal Data on our servers in the United States and elsewhere in the world where GoodCoinPay facilities are located. It also describes how we protect it by maintaining physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations, and EU data protection laws.
- Incident Response Policy: This policy describes our response to an information security incident.
- Data Breach Policy: This policy specifically describes what steps will be taken by us in case of a data breach. This includes notifying the supervisory authorities and the affected data subjects when required.
- Business Continuity and Disaster Recovery Policy: This policy describes how we recover from a disaster and what steps will be taken to continue or resume routine business operations.
We are a regulated Financial Institution in the United States and per the applicable Bank Secrecy Act provisions, we will retain Personal Data that has been obtained as a part of our Customer Identification Program for a period of 5 years after an account has been closed or became dormant.
How we share personal data with third parties
We may share your Personal Data with:
- Other GoodCoinPay entities, in order to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications;
- Service providers under contract who help with our business operations. We will make sure that these third parties have appropriate internal controls in place to protect any Personal Data that might be transferred;
- In cases of suspected fraud or in connection with an ongoing investigation, we may share certain shopper information with our merchants.
Please note that these third parties may be in other countries where the laws on processing Personal Data may be less stringent than in your country. We deploy the following safeguards if we transfer Personal Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law:
- E.U.-U.S. Privacy Shield: To comply with EU data protection laws, GoodCoinPay Inc. self-certified under the E.U.-U.S. Privacy Shield. These frameworks were developed to enable companies to comply with data protection requirements when transferring Personal Data from the European Union and Switzerland to the United States. For more information about the Privacy Shield Program, please visit www.privacyshield.gov/welcome.
- EU Model Clauses: GoodCoinPay offers EU Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our merchants or third parties that operate in the European Union. Please contact GoodCoinPay (dpo@GoodCoinPay.com) if you wish to use this option.
GoodCoinPay shall be liable for the acts and omissions of any third parties with whom we share Personal Data unless GoodCoinPay proves that it is not responsible for the event giving rise to the damage.
How data subjects can access or change their personal data
Individuals located in the European Union have statutory rights in relation to their Personal Data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete, correct, or restrict the processing of this Personal Data. If you are located in the European Union and would like to exercise the right of access, you can make a request via our support form which can be found here: https://help.GoodCoinPay.com/requestHelp.
Merchants can review and edit their information by logging in to their account and reviewing their Personal Data under the Settings tab on the Dashboard. If you wish to change information relating to your industry or company website, or if you wish delete your account, you can send an email to compliance@GoodCoinPay.com or submit a request at help.GoodCoinPay.com/requestHelp. If you choose to delete your GoodCoinPay account, we will mark your account in our database as “Closed”. We will retain the information on the account in line with the data retention principles as outlined in Section VII.
We do not sell your Personal Data to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize the GoodCoinPay Services, content and advertising. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, you can simply click the “unsubscribe” link at the bottom of the e-mail or you can send an email to marketing@GoodCoinPay.com.
To communicate with our Data Protection Officer, please email dpo@GoodCoinPay.com. Subject to applicable law, you also have the right to lodge a complaint with your local Data Protection Authority or the Dutch Data Protection Commissioner, which is GoodCoinPay’s lead supervisory authority in the EU. If you are residing within the European Union and believe we maintain your Personal Data within the scope of the GDPR, you may direct questions or complaints to our lead supervisory authority:
3550 Wilshire Blvd. #1020
Los Angeles, CA 90010
Phone (213) – 999 – 8778
In the United States, GoodCoinPay is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Complaints may be submitted by completing the form that can be found here: www.ftccomplaintassistant.gov.
What are cookies?
A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to “remember” your actions or preferences over time. Most browsers support cookies, but you can set your browser to decline them and can delete them whenever you like.
What type of cookies do we use?
We send a “session cookie” to your computer when you log in to your account or otherwise use the GoodCoinPay Services. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we do not need to ask you for your password on each page. Once you logout or close your browser, this cookie expires and no longer has any effect.
We also use longer-lasting cookies for other purposes such as to display your email address on our login page, so that you don’t need to retype the email address each time you login to your account.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website. We may also collect information about your computer or other access device to mitigate risk and for fraud prevention purposes.
You may encounter cookies from third parties when using the GoodCoinPay Services on websites that we do not control (for example, if you view a web page created by a third party or use an application developed by a third party, there may be a cookie placed by that web page or application.)
Managing your cookie settings
You can manage cookies through the settings of your Internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies. Please note that, if you choose to delete GoodCoinPay cookies, your access to some functionalities and areas of our website may be degraded or restricted.
For more information on cookies and how to opt-out of them, please visit the following third party website: Your Online Choices.
Changes to this policy
Questions about privacy? Please contact us.