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The Isle of Man Data Protection Act 2002 came into force on 1st April 2003 and has been drafted in order to meet the standards set out in the European Data Protection Directive 95/46/EC.
Debit-Direct Limited as Sun-Pay’s Service Provider, will together with Sun-Pay, collect, store and use information provided by you when registering on, or using the Sun-Pay Payment Platform. This privacy policy explains what information will be collected and what that information is used for.
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What Information is collected?
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| Personal and Security Information
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To open a Sun-Pay account, you must provide us with the information requested in our Account Opening Application Form. We will also ask you to provide security information consisting of a password and to choose a security question to answer (such as your favorite pet’s name or favorite TV show). This information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against fraud, and to contact you should the need arise in administering your account. In order to make payments through Sun-Pay, you may also be required to provide bank account information. We will only collect personal information relating to an account from the account holder, and a Sun-Pay account can only be held by one person.
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| Transaction Information
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We retain transaction information for each of your transactions through Sun-Pay. We also collect the Internet address (IP address) of the computer or device you use to access your Sun-Pay account, in order to help detect possible instances of unauthorized transactions.
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| Information About You From Third Parties
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As part of our due diligence requirements we may verify with third parties some or all the information you have provided to us in your application form. In the course of such verification, we may receive personally identifiable information about you from such outsource partners.
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| Web Site Traffic Information
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Because of the way that World Wide Web communication standards work, when you arrive at or leave the Sun-Pay website, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the Sun-Pay site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with Sun-Pay. We do not track the Web sites that you visit before or after you leave the Sun-Pay site.
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| Customer Service Correspondence
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If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Sun-Pay and/or its Service Provider to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records as permitted by law.
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Use and Disclosure of Personal Information
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We will use the personal data and other information you have provided us for completing your application, opening and administering your Sun-Pay Account and for our own internal marketing, profiling, risk assessment, fraud prevention purposes and conducting analysis of transactional information.
We agree to retain the personal data which we obtain in connection with this Agreement only for as long as is necessary for the performance of our service to you. We will not disclose such personal data to third parties other than to the Bank or other third parties as necessary for the performance of our services, or unless required to do so by law, any Court of competent jurisdiction, any Government agency or regulatory body lawfully requesting the same.
As with any other business, it is possible that Sun-Pay and/or its Service Provider could in the future merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by Sun-Pay or its Service Provider, including customer account information, but would continue to be bound by this Privacy Policy unless and until such time as it may be amended and such amendments have been communicated to you.
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Information Security and Protection
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We are committed to handling and storing your information with high standards of information security. We restrict access to your personally identifiable information to employees who need to know that information in order for us to provide you with the services you request.
We maintain physical, electronic and procedural safeguards to guard your non-public personal data. We test our systems regularly and contract with trusted specialised third party companies to audit our systems and procedures on a regular basis.
Your Customer ID and Password are also critically important in ensuring the security of your Sun-Pay account. You determine the identity of your password and accept responsibility for the confidentiality and security of it at all times. If you do reveal your security details to anyone else and they access your account, Sun-Pay and/or its Service Provider will not be liable for any loss arising from such action
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Our Use of "Cookies"
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A cookie is a small amount of information recording details of your visit to our web site, but it does not identify you. The cookie is created by our web server and saved on your PC’s hard drive. The next time you visit our web site the web server will check to see if you have a cookie. If you do the web server will be able to check the last time you visited our site. This information is used if you wish to view what has been updated since your last visit; this is done by clicking the “New” button on the menu bar.
If you do not want to receive cookies or you would prefer to be prompted first you should check the settings in the “Internet Options” of your web browser.
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| Relationships
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| The Sun-Pay Web site may contain links to other Web sites. We are not responsible, nor accept any liability for the privacy practices or the content of such Web sites.
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| Contacting Us
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If you have any questions or concerns regarding this Privacy Policy, you should contact Sun-Pay Customer Service
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