VIP 360 PRIVACY POLICY 

Date of Last Update: 8th of October 2024 

This Privacy Policy tells you what to expect when GENERAL PAYMENTS GATE LIMITED, a legal entity established and incorporated in Canada, and having its registered address located at SUITE 1700, 777 DUNSMUIR STREET VANCOUVER, BC, CANADA V7Y1K4 (referred to as the “Company”, “VIP 360”  “we” or “our”), operating under the brand VIP 360, collects personal information. The Company is committed to safeguarding the data that our website visitors and service users share with us. This privacy policy explains how the Company processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through the use of its website and platform. 

For the purposes of this Policy, the Company defines the term “User”, “Visitor”, “Client” or “You” as a natural or legal person, either a visitor of the Company’s website or as the user with a trading account with the Company. 

Any information stored on the Company’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. The Company implements and maintains appropriate technical, security and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure. 

By continuing your interactions with us, such as by submitting information to us, or using our Services, you confirm that you understand and consent to the collection, use, disclosure, and processing of your personal data (or the personal data of any individual you provide) as described in this Privacy Policy. 

CONTROLLER 

GENERAL PAYMENTS GATE LIMITED is the controller and responsible for your personal data in accordance with the applicable data protection laws. 

GENERAL PAYMENTS GATE LIMITED is incorporated and established in Canada under registration No.: BC1354852 and having its registered address at SUITE 1700, 777 DUNSMUIR STREET VANCOUVER, BC, CANADA V7Y1K4.  

CONTACT DETAILS 

Our full details are: 

Full name of legal entity:  GENERAL PAYMENTS GATE LIMITED 

Brand Name: VIP 360 

Email address: dpo@vip-360.com  

Postal address: SUITE 1700, 777 DUNSMUIR STREET VANCOUVER, BC, CANADA V7Y1K4. 

Telephone Number: +1 (778) 725-0083 

PERSONAL DATA COLLECTED 

The Data Controller shall collect the following categories of Personal Data: 

Voluntary contents and information provided by the User 

• Contact information and contents: Information about the business for the purposes of account opening including but not limited to business name, address, and phone number. Information about the application including but not limited to applicant name, email address, phone number, address, birth date, government-issued identification number, title/ position as well as other information you may be asked to provide when signing-up for an account, providing identity verification or engaging in a transaction. 

• If the User does not communicate Personal Data, for which there is a legal or contractual obligation, will be impossibile to the Data Controller to provide, in whole or in part, its services. It will be impossible also in case that Personal Data is necessary requirement for the use of the service or for the contract conclusion. 

• The User who communicates to the Data Controller third parties Personal Data, is directly and exclusively liable for their origin, collection, processing, communication or disclosure. 

Data and contents automatically acquired while using the Application 

• Technical Data: the computer system and the software procedures functional to our platfrom may acquire, in the course of their ordinary activity, any Personal Data whose communication is implicit in the use of internet communication protocols. Such information is not collected to be associated with identified Users, however, those Data, due to its nature, may identify Users in the Processing and through the association with Data held by third parties. This category includes IP addresses or domain names used by Users who connect to the Application, addresses of Uniform Resource Identifier (URI) of the requested resources, time of the request, method used to submit the request to the server, size of the file obtained, etc. 

• Usage Data: Data may be collected relating to the use of the Application by the User, such as the pages visited, the actions performed, the features and services used by the User. 

Personal Data collected through cookies or similar technologies 

• We may use cookies, web beacons, unique identifiers and any other similar technologies to collect Data regarding pages, visited links and other actions, which you may perform while using our Services. They are stored for being communicated back to the same websites at the next visit of the User. 

• The User may read the complete Cookie Policy found in our website. 

PURPOSES OF PROCESSING 

All the data collected by us is required in order for VIP 360 to provide you with a trusted service. We may collect data for internal record keeping, to use as feedback to improve our products and services delivered to you. VIP 360  will not sell or share your Personal Information to third parties for promotional purposes. 

• We ask you for your Personal Information for the following reasons: 

• To verify your identity and protect against fraud; 

• To understand your financial service requirements; 

• To determine the suitability of products and services for you; 

• To set up and manage products and services you have requested, and 

• To comply with legal, regulatory and contractual requirements. 

PERSONAL DATA PROCESSING METHODS 

The Processing of Personal Data is performed with paper, IT and/or digital tools, with methods of organizations and with logics strictly related to the indicated purposes. In certain cases, subjects other than the Data Controller who are involved in the organization of the Data Controller (such as personnel management, sales personnel, system administrators’ employees, etc.) or who are not (as IT companies, service providers, postal couriers, hosting providers, etc.) may access to Personal Data. These subjects will be appointed, where necessary, as Data Processors by the Data Controller and will have access to Users Personal Data whenever required and shall be contractually obliged to keep it confidential. 

The updated list of Data Processors may be requested via email at the email address dpo@vip-360.com 

LEGAL BASIS FOR THE PROCESSING 

The Data Controller processes Personal Data regarding the User under the following conditions: 

• the User has given consent for one or more specific purposes 

• It is always possible to ask the Data Controller to clarify the concrete legal basis of each processing. 

PLACE 

Personal Data are processed in the places in which the parties involved in the Data processing are located. For further information, you may contact the Data Controller at the following email dpo@vip-360.com or at the following mailing address SUITE 1700, 777 DUNSMUIR STREET VANCOUVER, BC, CANADA V7Y1K4. 

SHARING PERSONAL DATA 

 We Share Personal Data Under Controlled Circumstances: 

• With third parties who may access data about you to provide you with the Services; 

• With third parties who may access data about you to perform functions on our behalf; 

• With financial institutions, processors, payment card associations and other entities that are involved in the payment process; 

• With government and law enforcement where reasonably necessary to comply with applicable law, regulation, legal process, or governmental request; 

• With others where reasonably necessary to protect the security or integrity of our Services or user safety; 

• In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture or dissolution of all or a portion of our business; 

We may transfer personal information we collect about you to jurisdictions other than the jurisdiction in which the information was originally collected and your personal information may be processed and stored outside of your jurisdiction of residence, including outside of Canada. Those jurisdictions may not have the same data protection laws as your jurisdiction of residence and your personal information may be subject to applicable foreign laws. If we transfer your personal information to other jurisdictions, we will protect that personal information in the manner described in this Privacy Policy. 

SECURITY OF PROCESSING 

We take reasonable measures, including administrative, technical and physical safeguards to help protect your personal data from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. 

We maintain strict security standards and procedures with a view to preventing unauthorized access to your data by anyone, including our staff. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your data. 

If you have any concerns about your personal or financial information with VIP 360 or there has been any evidence or unusual activity to suggest you may be at risk of fraud or identity theft, report the incident to us immediately at dpo@vip-360.com 

SECURITY CHOISES 

• Location Data, if applicable: Our web may require location data. If you do not grant us access to this data then you may not be able to use our Services. 

• Cookies: You can set your browser to reject cookies but our Services may not function properly in this setting. 

• Marketing: You can opt-out of email  by following instructions in these messages. If you opt-out we may still send you emails  regarding transactions and services related to our ongoing business relationship. 

• Notifications: Our Services may ask you for permission to send notifications to your device. Our services will still work if you do not grant us permission to send you notifications. 

• Website Tracking: Certain websites you visit may provide options regarding advertisements you receive. For more information or to opt out of certain online behavioural advertising, please visit http://www.aboutads.info. 

• Do Not Track: Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Services do not currently change the way they operate based upon detection of a Do Not Track or similar signal. 

PERIOD OF DATA STORAGE 

• The Data Controller will store Personal Data for the necessary time to perform the purposes connected with the performance of the agreement in force between the Data Controller and the User and Data shall not be stored beyond the duration of years 5 after the end of the relationship with the User. In any case Data could be stored within the limitation term prescribed by the current regulations. 

• When the Processing of Personal Data is necessary for the purposes of the legitimate interests pursued by the Data Controller, Personal Data shall be stored until the performance of the relevant interest. 

• When the Processing of Personal Data is based on the User consent, the Data Controller may store Personal Data until the withdrawal of the User. 

• Personal Data may be stored for a longer period of time in order to perform a legal obligation or public Authority order. 

• All Personal Data shall be deleted at the end of the period of storage. At the expiration of such period, the rights of Data access, rectification, erasure and portability must not be exercised. 

RIGHTS OF THE USER 

Under certain circumstances, you have rights under data protection laws in relation to your personal data: 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine -readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please Contact us to the following email: dpo@vip-360.com. 

In your email, please explain in detail your request.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

AMENDMENTS TO THE POLICY 

This Privacy Policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at the sole discretion of the Company. When we make changes to this Privacy Policy, we will notify all users on our website, and make the amended Privacy Policy available on our website. We encourage you to review this Privacy Policy from time to time to stay informed. For significant material changes in the Policy or, where required by the applicable Laws, we may seek your consent. 

INFORMATION, COMPLAINTS AND CONTACT 

If you have any further questions regarding the data the Company collects, or how we use it, then please feel free to contact us by email at dpo@vip-360.com. You have a right to lodge a complaint with supervisory authority, to enforce your rights, as specified above.