E.3 Política de Privacidade

PART E.3 — PRIVACY POLICY

This page forms part of Part E (ODIX Money Transfer). It explains how the Payments Partner Privacy Policy relates to ODIX Money Transfer and summarises its main points.

Important: this is a summary prepared by ODIX for your convenience. The legally binding document is the Payments Partner Privacy Policy published by the Payments Partner and available on request from support@odixpay.com. If this summary and the Payments Partner document differ, the Payments Partner document applies.

1. HOW THIS RELATES TO ODIX

ODIX obtains the payment processing behind ODIX Money Transfer from the Payments Partner under a contract. ODIX is the Payments Partner's "Account Holder"; ODIX customers who send money through the App are not account holders of the Payments Partner and have no direct contract with the Payments Partner. ODIX remains responsible to you for the service under Part E.

Under the Payments Partner Privacy Policy, when you use the Payments Partner's services through a provider such as ODIX, the provider is the primary controller of your personal data and the Payments Partner processes it on the provider's behalf. ODIX handles your personal data under our own Privacy Policy and shares with the Payments Partner the information needed to process your transfers, such as your name, transaction details, recipient details and screening results.

Requests about your personal data should be sent to ODIX first. The Payments Partner's Data Protection Officer can be contacted, if needed, through the contact details we provide on request.

2. DATA THE PAYMENTS PARTNER MAY PROCESS ABOUT YOU

Name and contact details; identity and verification data; transaction and recipient details; bank details; IP address and device data; and anti-money laundering and sanctions screening results.

3. PURPOSES

Processing and settling transactions, customer due diligence and AML/CFT checks, regulatory compliance, fraud and risk management, enforcing terms and responding to authorities. The Payments Partner states that it does not sell or rent personal data for marketing.

4. SHARING AND TRANSFERS

The Payments Partner may share data with authorities, advisers, IT, KYC and payment service providers, banks and payment networks, its affiliates in several countries, using contractual and legal safeguards.

5. RETENTION

Transaction, AML and KYC data is kept for at least five years from the transaction or the end of the relationship, whichever is later. When the agreement with a provider ends, end-client data is deleted or returned under the data processing agreement.

6. SECURITY AND BREACHES

The Payments Partner uses encryption, access controls and, where applicable, PCI DSS standards. If a breach affects end-client data, the Payments Partner notifies the provider without undue delay, and the provider notifies its customers.

7. YOUR RIGHTS

Depending on the law that applies, you can ask for access and correction, deletion or restriction (subject to record-keeping duties), withdraw consent and ask for human review of significant automated decisions. End clients should contact their provider first.

8. FULL DOCUMENT AND QUESTIONS

The complete Payments Partner Privacy Policy is available on request from support@odixpay.com. The Payments Partner may update it at any time; the version published by the Payments Partner is the current one.

Questions about ODIX Money Transfer go to us at support@odixpay.com.