1. Data Types
Personal Data: Reap collects personal data and your business information when you register with us and use the Site, including but not limited to: your name, email address, mailing address, telephone number, and HKID number (to the extent permissible under applicable laws), your date of birth (solely for identity verification purposes), business name, business address, business registration number, credit card numbers and billing information. We tokenise your credit card numbers and your billing information for secure storage and we only store tokenised information. Once you register an account with Reap, we will associate your identity with your Reap account (“Account”). Transaction Data: Reap also collects information about your transactions with us and automatically receives and records information on our server logs from your browser, including your IP address, Reap cookie information, and the page you request. Third-Party Data: Reap may from time to time require information relating to your payment recipient (“Recipient”) (including the Recipients’ name, bank account number, and a copy of your contract, invoice or receipt with the Recipient) in order to process your payments and/or to complywith regulation and perform verification checks. Such information may include personal data of the Recipient or third parties. By providing us with such information, you warrant that you have obtained the consent of the relevant Recipient or third party to the provision of their personal data to Reap, and to Reap’s collecting, using and storing such personal data for the purpose of processing payments and conducting compliance or verification checks. You hereby warrant that information provided to us is accurate to the best of your knowledge and that you will comply with all applicable laws (including applicable data privacy and confidentiality laws) in relation to the collection, disclosure, use and storage of such personal data. It is mandatory to provide certain types of personal data to us. In the event that you do not provide such personal data, you may not be able to fully enjoy our Services or register an Account.
2. Use of Data and Information
We may collect, use, disclose and/or process your personal data for one or more of the following purposes: to consider and/or process yourapplication/transaction with us or your transactions or communications with third parties via the Services; to manage, operate, provide and/or administer your use of and/or access to our Services and our Site, as well as your relationship and Account with us; to tailor your experience through the Services by displaying content according to your interests and preferences, providing a faster method for you to access your Account and submit information to us and allowing us to contact you, if necessary; to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual Account actions; to enforce our Services Agreement or any applicable end user licence agreements; to protect personal safety and the rights, property or safety ofothers; for identification and/or verification of you and your Recipient; to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services; to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf; to contact you or communicate with you via voice call, text message, email and/or postal mail or otherwise; to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience; to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience; only where you give us your prior consent, to send you direct marketing material (please see details below); to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding Reap and/or related corporations or affiliates; to produce statistics and research for internal and statutory reporting and/or record-keeping requirements; to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us; to prevent or investigate any fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or anyother matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned; to store, host, back up (whether for disaster recovery or otherwise) your personal data, whether within or outside of your jurisdiction; any other purposes which we notify you in writing of at the time of obtaining your consent. Unless you have expressly opted outof communications, deactivated or terminated your Account and removed payment details therein, you acknowledge that payment history, username and password may remain in our system including for the purpose of legal compliance. If your Account is not used for more than 5 years, we will keep your Account alive but erase your other personal data and we may retain non-personal information.
With your consent, we may use your name, telephone number, email address, mailing address, your preferred language of communication and your birthday month information (“Marketing Data”) to provide you with information about goods and services of Reap, our affiliates and our third party business partner which are in the business of financial and technology services, money services and money lending (“Reap Business Partners”). These goods and services include financial services, moneyservices, money lending, and technology services (“Marketing Subjects”). Our affiliates and Reap Business Partners may also use Marketing Data to provide you with information about their Marketing Subjects. We may receive compensation in sharing your Marketing Data with our affiliates and Reap Business Partners. We cannot use your personal data as above without your consent.
4. Information Protection
Reap is equipped with standard encrypted Secure Sockets Layer (SSL) Certificate and your payment card details are not stored by Reap but instead managed in a Payment Card Industry Data Security Standard (PCI DSS) compliant network. We also limit access to your personal data to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable law) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
6. Information Collected by Third-Parties
7. Access to Your Information and Updating Your Information
You have the right to request access to and correction of the personal data that we hold about you. If you would like to make such requests, please send an email to our data officer at [email protected] If any personal data that you have provided changes, for example if you change your email address, name or payment details, please let us know by correcting the details on your Account profile page or by sending an email to our data officer at [email protected] You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
By providing your email address associated withyour Account, selecting the check box on the registration page or subscribing to our email list via your Profile page, you are granting consent to us sending emails to you relating to the Services including transactional and product updates. You can withdraw your consent to receive electronic marketing communications at any time by opting out on your Profile page, emailing us at [email protected] or following the unsubscribe procedure contained in any electronic communication you receive from us. Reap reserves the right to send users that have provided an email address updates that are transactional in nature including, but not limited to payment receipts, updates such as administrative messages, password reset notifications and other Account related information.
Significant changes to this Policy will be notified to you through direct email to the address associated with your Account, or a notification prominently displayed on our Site.
(Version: September 2020)