At Payoneer NY Solution, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your data when you use our services.
1. Information We Collect
We collect various types of information to provide and improve our financial services:
Personal Information
- Full name, date of birth, and contact information
- Social Security Number or Tax Identification Number
- Government-issued identification documents
- Employment information and income details
- Financial account information and transaction history
- Investment objectives and risk tolerance
Technical Information
- IP address, browser type, and device information
- Cookies and similar tracking technologies
- Website usage data and analytics
- Login credentials and security authentication data
2. How We Use Your Information
We use the collected information for the following purposes:
- Providing financial advisory and wealth management services
- Processing transactions and managing your accounts
- Conducting risk assessments and due diligence
- Complying with legal and regulatory requirements
- Preventing fraud and ensuring platform security
- Communicating with you about your accounts and services
- Improving our services and customer experience
- Sending marketing communications (with your consent)
3. Know Your Customer (KYC) Compliance
Regulatory Requirement: As a licensed financial services provider, we are required by federal and state law to implement comprehensive KYC procedures to verify the identity of our clients.
KYC Verification Process
To comply with KYC regulations, we require all clients to undergo identity verification, which includes:
- Identity Verification: Submission of government-issued photo identification (passport, driver's license, or state ID)
- Address Verification: Proof of residential address through utility bills, bank statements, or government correspondence
- Source of Funds: Documentation explaining the origin of funds to be invested or managed
- Beneficial Ownership: For business entities, disclosure of ultimate beneficial owners and controlling persons
- Purpose of Relationship: Clear understanding of your investment objectives and intended use of our services
Enhanced Due Diligence
In certain circumstances, we may conduct Enhanced Due Diligence (EDD) for higher-risk clients, which may include:
- Additional documentation regarding source of wealth
- More frequent monitoring of account activity
- Verification of business activities and relationships
- Senior management approval for account opening
4. Anti-Money Laundering (AML) Policy
Zero Tolerance: Payoneer NY Solution maintains a strict zero-tolerance policy toward money laundering, terrorist financing, and other financial crimes. We are committed to full compliance with the Bank Secrecy Act, USA PATRIOT Act, and all applicable AML regulations.
AML Program Components
Our comprehensive AML program includes the following key elements:
Customer Due Diligence (CDD)
- Verification of customer identity using reliable, independent source documents
- Understanding the nature and purpose of customer relationships
- Ongoing monitoring to identify and report suspicious transactions
- Risk-based assessment of customer profiles
Transaction Monitoring
- Real-time monitoring of all financial transactions
- Automated alerts for unusual or suspicious activity
- Investigation of transactions inconsistent with customer profiles
- Documentation of monitoring activities and findings
Suspicious Activity Reporting
We are required to file Suspicious Activity Reports (SARs) with the Financial Crimes Enforcement Network (FinCEN) when we detect:
- Transactions involving $5,000 or more where we know, suspect, or have reason to suspect the transaction involves illegal funds
- Transactions designed to evade BSA reporting requirements
- Transactions that appear to serve no legitimate business or lawful purpose
- Transactions that involve potential terrorist financing
Currency Transaction Reporting
We file Currency Transaction Reports (CTRs) for cash transactions exceeding $10,000 in a single day, as required by federal law.
Prohibited Activities
The following activities are strictly prohibited and will result in immediate account closure and reporting to authorities:
- Structuring transactions to avoid reporting requirements
- Using our services for money laundering or terrorist financing
- Providing false information during account opening or verification
- Conducting transactions on behalf of sanctioned individuals or entities
- Using accounts for illegal activities or proceeds from illegal activities
OFAC Compliance
We screen all clients and transactions against the Office of Foreign Assets Control (OFAC) sanctions lists, including:
- Specially Designated Nationals (SDN) List
- Sectoral Sanctions Identifications List
- Foreign Sanctions Evaders List
- Country-based sanctions programs
5. Data Protection and Security
We implement robust security measures to protect your personal information:
- Encryption: All sensitive data is encrypted using 256-bit SSL technology
- Access Controls: Strict access controls limit employee access to personal information on a need-to-know basis
- Multi-Factor Authentication: Enhanced security through 2FA for account access
- Regular Audits: Periodic security audits and vulnerability assessments
- Secure Infrastructure: Data stored on secure servers with regular backups
- Employee Training: Regular training on data protection and privacy best practices
6. Information Sharing and Disclosure
We may share your information in the following circumstances:
- Service Providers: Third-party vendors who assist in providing our services (under strict confidentiality agreements)
- Legal Requirements: When required by law, regulation, subpoena, or court order
- Regulatory Authorities: Financial regulators, law enforcement, and government agencies as required
- Business Transfers: In connection with a merger, acquisition, or sale of assets
- Consent: When you provide explicit consent to share information
7. GDPR Compliance
For users in the European Economic Area (EEA), we comply with the General Data Protection Regulation (GDPR):
- Lawful Basis: We process your data based on consent, contractual necessity, legal obligations, or legitimate interests
- Data Rights: You have the right to access, rectify, erase, restrict processing, data portability, and object to processing
- Data Protection Officer: Contact our DPO at privacy@payonneer-ny.com
- International Transfers: We implement appropriate safeguards for international data transfers
- Breach Notification: We will notify you and relevant authorities of data breaches within 72 hours
8. Cookies and Tracking Technologies
We use cookies and similar technologies to enhance your experience:
- Essential Cookies: Necessary for website functionality and security
- Analytics Cookies: Help us understand how visitors use our website
- Marketing Cookies: Used to deliver relevant advertisements (with your consent)
You can control cookie preferences through your browser settings, though disabling certain cookies may affect website functionality.
9. Data Retention
We retain your personal information for as long as necessary to:
- Provide our services and maintain your accounts
- Comply with legal and regulatory retention requirements (typically 7 years for financial records)
- Resolve disputes and enforce our agreements
- Maintain records for AML and KYC compliance purposes
10. Your Privacy Rights
You have the following rights regarding your personal information:
- Access: Request access to your personal information
- Correction: Request correction of inaccurate or incomplete data
- Deletion: Request deletion of your data (subject to legal retention requirements)
- Opt-Out: Unsubscribe from marketing communications
- Data Portability: Request a copy of your data in a portable format
- Restriction: Request restriction of processing in certain circumstances
To exercise these rights, contact us at privacy@payonneer-ny.com.
11. Children's Privacy
Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete it promptly.
12. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.
13. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
- Email: privacy@payonneer-ny.com
- Phone: +1 (212) 459-3847
- Address: 40 Wall Street, Suite 2800, New York, NY 10005
- Data Protection Officer: dpo@payonneer-ny.com
Important Notice: By using our services, you acknowledge that you have read, understood, and agree to this Privacy Policy, including our KYC and AML procedures. Your cooperation with these compliance requirements is essential for us to provide our services and maintain the integrity of the financial system.