This Privacy Policy (Policy) applies to the Users of PathoPay, the mobile wallet service of Digital Payments Limited (DPL)
Unless otherwise indicated or the context requires otherwise, reference to “you” or “your” are intended to refer to a User, and reference to “PathoPay”, “we”, “us” or “our” in this Policy include Digital Payments Limited (the Company) and its Affiliates and Subsidiary Companies.
We collect and use personal information from and about you, including when you interact with us, register for or open a Pathao Pay User Wallet Account, conduct any financial transactions using Pathao Pay, or otherwise visit or use Pathao Pay Wallet Services. The personal information that we collect includes:
Registration Information: your basic personal details including first and last name, date of birth, and NID, contact information including your address, phone number, email, or other information that permits us to contact you and other registration details;
Financial information: including bank account details, billing and delivery information, transaction data, credit/debit card numbers and cardholder names, expiration dates and bank statements;
Payment Transaction details: including name, account number, contact information and/or other information relating to you or another recipient of a payment, remittance or fund transfer;
Technical information: including any information obtained from the device you use to interact with us that includes IP address, geographical location, device identification codes and other features/data that can be used to identify a device;
Information from your visits to our websites or mobile app: including browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/usage, page views and any search term you use, device logs in the event of a crash or error report;
Cookies: when you access Pathao Pay through a browser, we send one or more cookies - a small file containing a string of characters - to your computer to uniquely identify your browser. We use cookies to improve the quality of our service by storing user preferences and tracking user trends. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Please note that you will not be able to access certain features of Pathao Pay if your cookies are disabled.
We collect personal information about you in connection with the Pathao Pay Wallet Services. For example, we collect your personal information when you browse our website, register as a User of Pathao Pay Wallet, log into your User Wallet account to avail our Services; or when you participate in one of our loyalty or promotional events, or when you communicate with us by phone, e-mail, web-chat or otherwise, etc.
We also receive personal information about you from other sources, including
DPL Affiliates or Subsidiary Companies and other third party suppliers or merchants providing services on our behalf;
Any other merchants from which you buy goods or services using Pathao Pay Wallet Services;
Banks and other payment institutions that we cooperate with to provide you with the Pathao Pay Wallet Services;
Credit reference and fraud prevention agencies;
Publicly available sources.
We combine information that we have about you from various sources including the information you have provided to us.
We use the information we collect to operate our business, including provision of the Pathao Pay Wallet Services. We may use your personal information for the following purposes:
Verifying your identity, including during account creation and payment password reset processes;
Verifying your eligibility as a User of the Pathao Pay Wallet (including anti-money laundering and counter-terrorist financing checks and verification);
Processing, maintaining, and managing your registration as a User of the Pathao Pay Wallet;
Providing you with Pathao Pay Wallet Services and other related services, including operating the Wallet Services and enabling transactions, customizing your user experience, facilitating the payments, fund transfers, refunds, sending notices about transactions, and responding to your queries, feedback, claims, or disputes;
Contacting you in relation to our provision of Pathao Pay Wallet Services and other legal purposes, contacting you in connection with any communication preferences or requests you have expressed, asking you for feedback about Pathao Pay Wallet Services or other related products and services;
Collecting feedback from you and your staff (if you are a merchant user) about our products and services and using such feedback to improve our business and/or customize products and services for you;
Sending you direct marketing or other information about products and services offered by us, other DPL Affiliates, our business partners or other third parties; including for promotional purposes;
Managing risk, performing creditworthiness and solvency checks, or assessing, detecting, investigating, preventing or remediating fraud, data breaches or other potentially prohibited or illegal activities and otherwise protecting the integrity of our payment system;
Detecting, investigating, preventing or remediating violations of your agreements with us or any merchant or any applicable policy, industry standards, guidelines, regulations and laws of the country and our policies;
Making disclosures as may be required by any law or regulation or by any government bodies. Disclosures may also be made pursuant to court order or other legal process or requirement applicable to us or any Pathao Pay Affiliates (including anti-money laundering and counter-terrorist financing reporting requirements or other commercial disputes);
Making disclosures to third parties including relevant regulators to prevent any harm or financial loss, to report suspected illegal activity or to establish, exercise or defend claims or potential claims on behalf of ourselves or any Pathao Pay Affiliate company; or to enable any due diligence and other appraisals or evaluations for any actual or proposed merger, acquisition, financing transaction or joint venture;
Conducting research and analysis, or otherwise using data to improve, optimize and expand the product functions of the Pathao Pay Wallet Services, if applicable, to develop related products and services;
Managing our business including to protect Users, prevent harm, fraud or theft to ourselves and others, maintain the security of our products and services, and protect our rights or property and those of others; and
Otherwise for everyday business purposes, to comply with law, or in other ways for which we provide specific notice at the time of collection.
We will not sell or rent your personal information to companies or individuals outside of Pathao Pay. If you are making a purchase through Pathao Pay, we may share portions of your credit card number with the retailer to identify the transaction, but we will not share your full credit card number with the retailer without your opt-in consent, except in the limited circumstances described below. In addition, we will only share your personal information with other companies or individuals outside Pathao Pay as permitted by this Policy and in the following circumstances.
We share your personal information to operate and manage our business, including for the purposes indicated hereunder:
Merchants to whom payments are made using the Pathao Pay Wallet;
Companies in the Pathao Pay Affiliates providing services on our behalf or to which we provide services;
Third parties including any agent, contractor or third party service provider that we work with in providing Pathao Pay Wallet Services. For example, we work with third parties to help us with fraud prevention, anti-money laundering checks, credit checking, bill collection, data entry, database management, promotions, marketing, customer service, technology services, products and services alerts, payment settlement and processing and payment extension services;
Entities with whom Pathao Pay maintain commercial arrangements, including online and offline merchants and Pathao Pay Affiliates;
Banks, card associations, payment networks or acquiring institutions, and other, including those involved in processing of payments and conducting of transactions through Pathao Pay Wallet Services;
Law enforcement agencies, insurers, government and regulatory authorities or any other organizations to which Pathao Pay, or any Pathao Pay Affiliate company or third party service provider is under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement and who can help us to detect, prevent or otherwise address fraud, security or technical issues;
Individuals and entities involved in any merger, acquisition, corporate reorganization or financing, or similar transaction with us, including in the event of the sale of all or part of our assets; and
Our own and others’ professional advisors (e.g., lawyers, accountants, auditors and trustees).
We have your consent. We require opt-in consent for the sharing of any sensitive personal information, except as otherwise described in this section.
If you are using a credit card issued by the merchant from whom you are making a purchase through the Processing Service (i.e., a 'private label credit card'), that merchant will receive your entire credit card number in association with your purchase.
If you make purchases on participating merchant websites from your smartphone using the Mobile Wallet, that merchant will receive your entire card number in association with your purchase.
We may share aggregated non-personally identifiable information with third parties. For example, we may disclose that overall usage of Pathao Pay in a particular geographic area or that a certain percentage of users use a particular type of credit or debit card. However, if we do share this aggregated information, we do not include personally identifiable information without your explicit opt-in consent or in the limited circumstances described above.
We provide such information to our Affiliates companies or other businesses or entities for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent or otherwise address fraud, security or technical issues or (d) protect against imminent harm to the rights, property, security or safety of Pathao App, its users or the public as required or permitted by law.
If you are using a credit card issued by the merchant from whom you are making a purchase through the Processing Service (i.e., a 'private label credit card'), that merchant will receive your entire credit card number in association with your purchase.
If you make purchases on participating merchant websites from your smartphone using the Mobile Wallet, that merchant will receive your entire card number in association with your purchase.
We may share aggregated non-personally identifiable information with third parties. For example, we may disclose that overall usage of Pathao Pay in a particular geographic area or that a certain percentage of users use a particular type of credit or debit card. However, if we do share this aggregated information, we do not include personally identifiable information without your explicit opt-in consent or in the limited circumstances described above.
We provide such information to our Affiliates companies or other businesses or entities for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent or otherwise address fraud, security or technical issues or (d) protect against imminent harm to the rights, property, security or safety of Pathao App, its users or the public as required or permitted by law.
When you shop at a seller using Pathao Pay for the first time and complete an order, you’ll be given a choice whether you'd like to receive promotional emails from the seller. If you decide later that you don't want to receive promotional emails from a seller, you will need to contact the seller directly.
If Pathao Pay or its Affiliates or subsidiary companies become involved in a merger, acquisition or any form of sale of some or all of their assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.
We will keep your personal information in accordance with our policies and for as long as it is necessary to provide you with the Pathao Pay Wallet Services or other purposes as set out in this Policy. In addition, we may retain your personal information for a longer period (including after you are no longer a User), if it is necessary to comply with laws and regulations applicable to us.
We use a variety of security measures, programs and technologies designed to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws and regulations applicable in Bangladesh. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical and technical security measures from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws and regulations. For example, your credit card number will always be stored in an encrypted form (except when you provide it to us in a communication outside our web page interface).
The security of your PathoPay User Wallet Account also depends on keeping your account password confidential, and you should not share your account name or password with anyone. Our staff will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a device with others, you should not choose to save your log-in information for the Pathao Pay Wallet (e.g., user ID and password) on that shared device.
The Pathao Pay Wallet Service information security program does not apply to any information, arising from a Third Party Provider Wallet Service, that is stored on your Pathao Pay App, as that information is outside of the Pathao Pay-controlled data centers. It is your responsibility to control access to your mobile device and the Pathao Pay App on your device, including keeping your PIN confidential and not sharing it with anyone. It is your responsibility to alert Pathao Pay or the relevant partner if you believe that the security of the information in the Pathao Pay App has been compromised.
Our service is not directed towards children under 18 years old nor does Pathao Pay knowingly collect information from children under 18. If you are under 18, please do not use Pathao Pay Wallet Services or submit any personal information to us.
If you are above 16 years and below 18 years old and intends to use our Services, you must ask your parents or guardian to read this Policy and provide us with the proof of prior express consent from your parents or guardian and proper age identification. If your guardian disagrees to your use of our services or provision of information to us in accordance with this Policy, please cease immediately the use of our services and notify us promptly so that we can take appropriate actions.
If you, acting as a guardian of a child, have relevant questions in respect of a child’s personal information, please contact us using the details set out in the Contact us section below.
We may provide links to our Affiliates or Subsidiary companies, or other websites, apps and services (including other online merchant sites) for your convenience and information. These services, apps and websites may operate independently from us. Linked services, apps and websites may have their own privacy policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for these websites’, apps’ or services’ content, any use of these services, apps or websites by you, or the privacy practices of these services, apps or websites.
We use your personal information on the following bases:
To comply with legal and regulatory obligations.
For legitimate business purposes.
Using your personal information helps us to operate and improve our business and minimize any disruption to the Pathao Pay Wallet Services that we offer to you. It also allows us to make our communications with you more relevant and personalized and to make your experience of our services efficient and effective.
In cases in which we wish to use your data for our legitimate business purposes, we carefully consider the position and do not go ahead if we think your interests or fundamental rights and freedoms relating to your personal information would be prejudiced.
In accordance with applicable data protection and privacy laws and regulations, you may be entitled to:
Ask us about the processing of your personal information, including to be provided with a copy of your personal information;
Request the correction and/or (in some cases) deletion of your personal information;
In some cases, request the restriction of the processing of your personal information, or object to that processing;
Withdraw your consent to the processing of your personal information (where Pathao Pay is processing your personal information based on your consent);
Request receipt or transmission to another organization, in a machine-readable form, of the personal information that you have provided to Pathao Pay where we are using your personal information based on consent or performance of a contract;
Complain to the relevant supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.
Where you are given the option to share your personal information with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
If you would like to exercise your rights, please contact us using the details set out in the ‘Contact Us’ section below.
Pathao Pay is located at Dhaka, Bangladesh and operates its services from there. Depending on where you live, the information that you provide and Pathao Pay collects may be stored on servers that are outside of your state, province, country or other governmental jurisdiction, and the privacy laws that apply may not be as protective as those in your home jurisdiction. If you are located outside the Bangladesh and choose to provide information to us, Bangladesh transfers personal information to other countries and processes it there. By using this website, you consent to this transfer and processing of data.
Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Policy without your explicit consent. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including notification in your account interface or email notification, by publishing announcements on our website). Each version of this Privacy Policy will be identified at the top of the page by its effective date and we will also keep prior versions of this Privacy Policy in an archive for your review.
If you have questions or requests about the privacy issues relating to the processing of your personal information, you can contact us by email at [email protected] or at our business address: -----------------------------------------------. As required under applicable laws in Bangladesh, please note that we may take steps to ask you to provide further information to verify your identity before granting you access to information or acting on your request to exercise your rights.