1. INTRODUCTION
At DicePay Canada ('DICE' or the 'Company'), we are committed to protecting your privacy. This Privacy Policy explains how we collect, use, protect, and share your personal information. You accept or consent to this Privacy Policy when you sign up for Dice services, ensuring you expressly consent to provide us with your personal information. This policy follows best practices and aligns with the General Data Protection Regulation (GDPR). Data privacy has become a major priority following various breaches globally, exposing public personal data and resulting in financial loss or reputational damage. When organizations infringe on Data Subjects' privacy rights, various fines are imposed under national laws and regulations such as GDPR. Hence the need for a data privacy governance framework guiding the management of Personally Identifiable Information (PII) of Data Subjects (customers).
1.1 Objectives of this document
The objectives of this framework are:
- •Provide an enabling environment for the management of data subject information
- •Identify and highlight requirements of relevant regulations guiding data privacy.
- •Identify roles and responsibilities of participants in the data privacy ecosystem
- •Provide general guidelines for the implementation of processes involving sensitive data subject information
2.0 DATA GOVERNANCE
Data governance helps DICE align data management efforts with business objectives, support regulatory compliance, and manage inherent risks in data processing. This data includes personal information, intellectual property, trade secrets, and business data.
In accordance with GDPR requirements, DICE will appoint a Data Protection Officer (DPO) who must be a senior executive to oversee the organization's data protection activities and its compliance with GDPR.
3.0 PRINCIPLES OF PERSONAL DATA PROCESSING
This policy is based on the following principles:
3.1 Data Categories
Personal Data: (e.g., name, home address, location data, email address, account number, social security number, tax identification number, etc.)
Previously Collected Data: This is also called secondary processing and takes place when data previously collected for a particular purpose is used or processed for another purpose without the knowledge or new consent of the data subjects.
Processing: Processing of personal data is any operation or set of operations performed on personal data, whether by manual or automatic means. These include collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure, transmission, dissemination, blocking, erasure or destruction.
3.2 Required Information
To open an account with us or use our services, you must provide:
- Your legal name
- Gender
- Address
- Phone number
- Date and place of birth
- Nationality
- Identification document details
- Financial history
- Source of funds
- Bank statements
- Bank details
- Purpose of transaction
This information may vary depending on the nature of your business and the service you require. To fund your account or make certain payments through us, you must provide your bank details. We will also require other commercial or identification information for high-value transactions.
Photographs: We may ask you to upload a photo of yourself (for example, your ID photo). Your face must be recognizable for verification purposes.
3.3 Reason why we collect your information
We use your information to provide services which may include:
Verify your identity during account creation
Authorize and process transactions
Monitor and improve our services
Protect against and prevent fraud
Provide customer support services
Communicate about products and services
Meet legal and regulatory requirements
Maintain business and transaction records
Measure and improve website performance
3.4 Customer Consent
Consent is described as the freely given, specific, informed, and unambiguous indication of the individual's wishes (GDPR).
Cookies and Device Data
Express consent is obtained from individuals visiting the Company's website for device data.
Direct Marketing
Consent is required from individuals for direct marketing, except for existing customers.
Account Opening
Consent is obtained via online channels or physical business offices of the Company.
Data Transfer
Consent for data transfer to third parties or foreign countries - DICE will seek the data subject's consent prior to transferring the data to a third party or foreign country.
3.5 Individual Rights of Access and Rectification
3.6 Lawful Reasons for Data Collection
We collect data based on these legal grounds:
3.7 Customer Diligence
3.7.13.7.1 Third Party Websites
Dice's website may include links to third-party websites. Note that these websites are operated by third-party organizations and Dice is not responsible for their operations, including their data protection practices. You are therefore required to review their privacy statements before providing them with personal information.
3.7.23.7.2 Transaction Information
When you send or request money, we may ask you to provide information about the transaction, including the amount and type of transaction and the identity of the recipient. We also collect the IP (Internet Protocol) address of the computer or device you use to send or request money to help authenticate your identity and detect unauthorized activity.
3.7.33.7.3 Customer Information from Third Parties
We also use third-party service providers (payment partners and anti-fraud agencies) to verify user information. For certain high-volume users, we may also conduct background checks, including a credit report (if and where permitted by law).
3.7.43.7.4 Communications
Communication with our customer support may result in the communication (emails, phone conversations, tweets, etc.) being retained in your account records as evidence of business transactions.
3.7.53.7.5 Questionnaires, Surveys, Contests
Dice may periodically conduct voluntary surveys where demographic data may be collected. Before participating in any survey, notice of the reason and use of the data will be provided.
3.8 Data Protection and Storage
Dice uses firewalls, data encryption, and strict physical access controls. Access to personal information is limited to employees who need it for their job responsibilities and who are committed to confidentiality.
Account Security
Users are responsible for protecting their password. Dice representatives will never ask for your password. Change it immediately if you suspect unauthorized access.
3.9 Accessing and Modifying Your Information
You can review and update your information at any time by logging into the Dice Empire website. If you close your account, we retain account information for 10 years to comply with data retention laws and prevent fraud.
4.0 DATA BREACH
A data breach is a security breach resulting in the destruction, loss, or unauthorized access to personal data. DICE will:
6.0 CHANGES TO THIS POLICY
This privacy policy may be revised as features are added. We will provide 30 days notice on our website or via email for revised policies. Continued use after the effective date constitutes consent to all changes.