Privacy policy

Last update: Jan 12, 2024

This Privacy Policy is an overview of how Cutros Group Inc. (hereinafter, “Cutros”) collects, uses, and processes your personal data when you use the PayPlume.

Please read this Policy carefully, as it becomes legally binding when you use the Services. Cutros takes privacy and protection of your data very seriously and is committed to handling the personal information with the upmost diligence.

Responsible Entity

The entity responsible for the collection, processing and use of personal data is:

Cutros Group Inc., with registered address located at 905 West Pender Street, 6th Floor, Vancouver, British Columbia, BC V6C 1L6, Canada, holding company registration number BC1449093.

If you have any questions about how Cutros handles or protects your data, you can contact the Compliance department at [email protected]

Data Cutros collects about you

Cutros will collect and process the following data about you:

1. Information you give Cutros:

you may give Cutros information about you when you sign up to use the Service (for example when you provide us with personal details like your name and email address). This also includes information you provide through your continued use of our Services. The information you give us may include, among others: your name, address, email address, passport and/or National ID, phone number, financial information (including your debit/credit card, your bank account information), source of funds, source of wealth, payment details, geographical location, tax identification number, photograph and video interview.
The content of your communications with us, which we collect via telephone call recordings, online chat, emails and other means.
In some cases, including when you send high value transaction, or where we need to comply with anti-money laundering regulations, we may also need more identification from you, including a copy of your bank account statements.
Please ensure that your personal data is current, complete and accurate by logging onto your account and updating it whenever necessary.

2. Information Cutros collects about you:

Cutros may automatically collect details of the transactions you carry out when using the Services, including geographic location from which the transaction originates;
Cutros may automatically collect technical information (including IP address, device fingerprint, browser type and version, time zone setting, browser plug-in types and versions, operating systema and platform);

3. Information Cutros receives from other sources:

Cutros may receive information about you from third parties that Cutros is working with closely (for example payment service providers that are collecting the payments you are uploading funds to PayPlume, providing Cutros with your basic personal information as well as well as your financial information such as limited information regarding your payment card details);

4. Information from social media networks:

if Cutros enables this option and you decide to log in to our Services using your social media account (for example, Facebook or Google) Cutros will receive relevant information that is necessary to enable the Services and authenticate you. The social media network will provide Cutros with access to certain information that you have provided to them. Cutros uses such information, together with any other information you directly provide to Cutros when registering or using the Services.

Minor's data

The Services are directed at adults aged 18 years and over, and not intended for children. Cutros does not knowingly collect data from this age group. The verification process implemented by Cutros prevents processing and storing this data. If any data is collected from a child without verification of parental consent, it will be deleted.

How Cutros protects your personal information

Cutros takes the safeguarding of your information very seriously, and take a number of steps to ensure it stays secure:

Communication over the Internet between you and Cutros servers is encrypted;
Cutros’ technical security team proactively monitors for abnormal and malicious activity in the servers and services;
Cutros restricts access to your personal information to those employees of Cutros who have a business reason for knowing such information.

Purposes of the data processing and legal basis

Cutros processes your personal data for the following purposes:

To carry out Cutros’ obligations relating to your contract with Cutros and to take steps at your request prior to entering into such contract;
To comply with any appliable legal and/or regulatory requirements;
To administer our Services and for internal operational, planning, audit, troubleshooting, data analysis, testing, research, statistical and survey purposes;
To pursue Cutross’ legitimate interests provided that these legitimate interests are not overridden by your interests or fundamental rights and freedoms;
To prevent and detect crimes, including fraud and financial crime;
To notify you about changes to our Services and send you other administrative information;
To enforce our Terms and Conditions with you. Cutros’ legitimate interests include:
Keeping the Services safe and secure;
Constantly improving the Services and to ensure that they are presented in the most effective manner;
To perform a task carried out in the public interest (such as the prevention of money laundering and terrorism financing;

Disclosure of your information

Cutros may share your information with selected third parties including:

Affiliates, business partners, suppliers and subcontractors supporting Cutros in the provision of the Services;
Cutros services providers that are processing your payments and/or are providing payment services needed for the provision of the Services (for example banks);
Business partners, suppliers and subcontractors that help Cutros to perform and execute the Services and/or mitigate fraud (for example Refinitiv is the provider of World-Check which is used for screening sanction lists, external provider used for identity verification);
Analytics that assist in the improvement and optimization of our website;
Limited information is sent to payment beneficiaries when you initiate a payment transaction; if Cutros needs to protect its rights, including exchanging information with other companies and organizations for the purposes of fraud protection;
To prevent and detect fraud or crime and to assist us in conducting or co-operating with investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so.
If Cutros is under a duty to disclose or share your personal data in order to comply with any legal obligation;
In response to a warrant, court order, properly constituted police request or as otherwise required by law.
If you consent, to share your details when using our Services.

If you would like further information, you can contact the Compliance Department at [email protected]

Sharing and storing your personal data

The Services are provided by Cutros, an entity duly incorporated in British Columbia, Canada. When you open PayPlume or you use the Services, your personal data will be processed by Cutros. For the avoidance of doubt, by submitting your personal data, you agree to this processing and storing of personal data.

In the event that Cutros uses thid parties for processing and/or storing personal data, Cutros will ensure that the third parties take adequate and appropriate technical, physical and organizational security measures to protect your data.

Automated Decision Making

Cutros may use Automated Decision Making (ADM) to help fight financial crime. Cutros may use ADM to verify that your IP location matches with the information regarding your residency that you have provided during the registration, or to verify that the account holder of your payment method matches with your account details.

Cookies

Cutross uses cookies for the purposes of ensuring the functionality and security of the website and the Services. As the processing is necessary for the purposes of legitimate interests, this is, to ensure the functionality and security of the website and the Services, Cutros is not requiring your consent for this processing.

Data Retention

Given the nature of the Services, Cutros is required to store some of your personal and transactional data beyond the closure of your account. Cutros will only access your data internally on a need-to-know basis and will only access or process it if absolutely necessary. If you want to know more about this, contact the compliance team at [email protected]

Your rights

You have the right to access information held by Cutros, which include, subject to applicable provisions of the data protection legislation, the following:

Provide you with a copy of the information that you have provided to Cutros;
Provide you with further details on the use Cutros makes of your information;
Update any inaccurate, incorrect, or out of date personal information;
Delete any personal information that is no longer necessary, or no longer subject to a legal obligation to which Cutros is subject to (Cutros has legal obligations so it may not be possible to delete your data at the time of request. Once the required time has passed then Cutros will be able to comply with your request);
Where processing is based on consent, to withdraw your consent requesting Cutros to stop the processing;
Adjusting your notification preferences in the settings section of your account;
Object to any processing based on ground of the legitimate interests unless Cutros’ reasons for undertaking that processing outweigh any prejudice to your data protection rights.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime).

If you exercise any of these rights, Cutros will check your entitlement and respond in most cases within a month.

If you have any questions in relation to the use of your personal information, you can contact the compliance team at [email protected]

Third-party links

The Services may, from time to time, contain links to and from the websites of partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Cutros does not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.

Changes to our privacy policy

Cutros may revise this Privacy Policy at any time without notice provided that is needed to keep up with changing legislation. Likewise, Cutros may revise this Privacy Policy at any time without notice for the purposes of keeping up with best practices and changes in how Cutross processes personal information, provided that is for your interest or when the applicable legislation entitles Cutros to do so. Cutros will post the revised version on this website and when possible, Cutros will notify you via email or via push-up notification when you will access your account. In all other cases, Cutros will revise this Privacy Policy as per the legal requirements of the applicable legislation.

PayPlume website

When you visit and use the website, Cutros will process your IP address, Google Analytics ID, internet browser and device type, location data and your use of the website.

Cutros uses this data for our legitimate interests of making sure the website works properly, including debugging, for DDOS mitigation on the website, and improving the website and to perform statistical analyses for optimizing the website.

Cutros collects this data using cookies and similar techniques.

Cutros will always only keep your data for as long as Cutros reasonably needs it for the purposes listed above.

If you have any questions about how Cutros handles or protects your data, you can contact the Compliance department at [email protected]