_{Policy Effective as of March 15, 2024.}

_{This privacy policy ("Policy") describes how we collect, protect and use the personally identifiable information ("Personal Information") you ("User", "you" or "your") provide on the www.lebupay.com website and an y of its products or services (collectively, "Website" or "Services") owned and operated by Clavis Fintech Solutions Ltd. ("Clavis Fintech Solutions Ltd.", "us", "we" or "our"). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.}

_{We may update this privacy statement to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.}

Collection of Personal Information

When you initiate the online registration process for a transaction with Clavis Fintech Solutions Ltd., we ask for certain personal information, for example, your name, date of birth, email address, physical address, driver’s license number, Social Insurance Number, Passport and financial or banking account information. In general, we seek to limit the amount and type of information collected to that which is necessary to run our everyday business and provide our products and services. If you choose to add a beneficiary on our website, we will ask you for your beneficiary’s name, email address, financial information (bank information) and physical address.

Use of collected information

Clavis Fintech Solutions Ltd. collects personal information about you so that we can effectively provide our services to you including:

• processing and settling currency exchange & money transfers;
• verify your identity;
• managing fraud and security risks;
• responding to your inquiries and requests for technical support; and
• complying with legal and regulatory requirements.

If we need to use your information for any other purpose, we will identify that purpose to you. We may also use your information to communicate special offers, new products or features or invite you to participate in surveys or opinion-gathering activities or events. If you do not wish to receive such communications, you may “opt out” at the time Clavis Fintech Solutions Ltd. collects information or at any time thereafter by simply contacting us at +1- (XXX) XXX XXXX

or unsubscribe@clavisint.com

Managing Personal Information

You can access, add to, update, and delete certain Personal Information about you. The information you can view, update, and delete may change as the Website or Services change. When you update information, however, we may maintain a copy of the unrevised information in our records. We will retain your information for as long as your account is active or as needed to provide you Services. Some information may remain in our private records after your deletion of such information from your account. We will retain and use your information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

Children

We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Website or Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide personal information through our Website or Service without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Website or Service, please contact us.

Newsletters

We offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

Cookies

The Website uses "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.

Advertisement

We may display online advertisements and we may share aggregated and non-identifying information about our customers that we collect through the registration process or through online surveys and promotions with certain advertisers. We do not share personally identifiable information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience.

Affiliates

We may disclose information about you to our affiliates for the purpose of being able to offer you related or additional products and services. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Privacy Policy.

Links to Other Websites

Our Website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect personal information.

Information Security

We secure information you provide on computer servers in a controlled, secure environment [RapidSSL], protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your personal information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite our best efforts.

Data Breach

In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do the same, we will post a notice on the Website, send you an email.

Legal Disclosure

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account and personal data will likely be among the assets transferred.

Changes and Amendments

We reserve the right to modify this privacy policy relating to the Website or Services at any time, effective upon posting of an updated version of this privacy policy on the Website. When we do the same, we will send you an email to notify you. Continued use of the Website after any such changes shall constitute your consent to such changes.

Acceptance of this Policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

Contacting Us
If you have any questions about this Policy, please contact us: 

Email: contactus@clavisint.com 

Phone or Text: +1-365-800-0223
Mail: Clavis Fintech Solutions Ltd.
Attn: Customer Service
Unit 775, 2785 Commercial Dr, Vancouver BC V5N 4C5