Global Privacy Policy

Effective May 12, 2020

NorthStar Currency Limited, doing business as NorthStar Currency, and our subsidiaries and affiliates (collectively “NorthStar Currency”, “we”, “us”, “our”) respect your privacy. Our Privacy Policy explains how we may collect, use, and disclose information we obtain through our website and online services (the “Service”) and the choices you can make about the handling of the information. We also describe how you can contact us about our privacy practices. This Privacy Policy is incorporated by reference into the NorthStar Currency Terms of Use.

A. Information We Collect

We may obtain information about you in a variety of ways, such as when you voluntarily provide it to us, in our role as a processor of payment transactions, or when it is automatically sent to us by the device you use to access the Service.

Information We Collect From You

When you use the Service, you may provide us with the following types of information:

Payment Information. When submitting a payment through our Service, we ask the payer for information such as the payer’s name, address, phone number. You will also need to provide information about the person for whom you are submitting a payment. For example, when submitting a payment to an educational institution, we will also ask for the student’s name, student ID, invoice number, date of birth, year of graduation, educational institution, and student email address. As part of the payment process, or to process a refund or charge-back, we and/or our partners may need the payer’s financial account information, such as bank account numbers, names, and routing codes
Referrals. To invite others to use the Service, you may submit their names, emails, and, for students, their educational institution.
Messages and Customer Service Requests. We collect the information you submit when you communicate with us by email, chat, or other methods. This includes customer support where you may choose to submit information regarding a problem or whether you speak to one of our representatives directly or otherwise engage with our support team. A summary of the problem you are experiencing, screen shots, documentation or information that would be helpful in resolving the issue.
Use of the service. We collect information about you when browsing our website and taking certain actions. This information includes links you click on; the type, size and filenames of attachments you upload to the services, content using analytics techniques that hash, filter or otherwise scrub the information and we collect clickstream data about how you interact with and use features of the services.
Device Information. We collect information about your computer, phone, tablet or other devices you use to access the services. Including browser type, IP address, device identifiers and crash data. We will also use your IP address and/or country preference to provide you with better service.

Information We Collect From Others

We may receive information from others, including:

Financial Institutions and Service Providers. In the course of processing your payment transaction we may work with a number of institutions, who we have partnered with, to help us provide our Service including banks and non-bank financial institutions such as card processors, electronic money institutions and payment service providers. To process a payment, a financial institution or service provider may share with us information about the payer’s account such as account name, number, routing code and other identifying information.
Designated Entities. We may be provided with your name and email address, from the educational institutions and other entities for which we serve as a payment agent, in order to contact you to encourage you to make a payment through our Service. Furthermore, these Designated Entities, may use the Service to communicate with you and manage the receipt of payments.

Information We Collect Using Cookies and Similar Technologies

When you visit our Service or open our emails, we and our third-party service providers may collect certain information by automated means, such as cookies, web beacons and web server logs. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Service. We may link this data to your profile. You may be able to change browser settings to block and delete cookies when you access the Service through a web browser. However, if you do that, the Service may not work properly.

We work with third party partners such as analytics and advertising partners, who may collect information about your use of other websites and online services over time. To learn more about Google Analytics and the choices Google provides regarding your information, please visit http:///www.google.com/policies/privacy/partners/.

To learn more about the use of cookies by us and third parties, including your opt out options, please visit our Cookie Policy.

B. How We Use the Information We Collect

We may use the information we obtain about you, as permitted by applicable law, to:

Provide and improve the Service;
We use information about you to verify accounts and activities, to monitor suspicious or fraudulent activities and to identify violations of policy
Process your payment transaction and keep you informed about the status of your payment;
Comply with and enforce applicable legal requirements, industry standards and our policies
Prevent potentially illegal or prohibited activities and enforce our Terms of Use;
Respond to your inquiries, resolve disputes and provide support;
We use collective learnings about how people use our services to troubleshoot and to identify trends, usage, patterns and areas of integration to better analyze, operate and improve our business and the Service (including enhancing the user experience, managing communications and functionality, and developing new products and services);
Communicate with you for Service-related purposes, such as sending payment reminders;
Compare information for accuracy and verify it with third parties;
Further our business relationship with you, if we have collected your personal information in the context of an actual or potential business relationship;
De-identify or aggregate data collected through the Service and use and disclose it for any purpose; and
Fulfill other purposes to which you have consented, which would be reasonably expected by you, or which are otherwise authorised or required by law. Where required by law or where we believe it is necessary to protect or legal rights; we will use information about you in connection to legal claims, regulatory issues, audit function, merger or funding.

C. Information We Share

We may share your information, as permitted by applicable law, in connection with the purposes described in Section B of this privacy policy. This includes sharing your information in the following ways:

To process your payment, we may share some of your information with the Designated Entity, for whom we serve as the payment agent.
We may share your information with service providers and vendors who assist us with the delivery of our Service. In some cases, to successfully process your payment or refund, we may share bank/payment receipt documents that you have sent to us with financial institutions under contract with whom we work, to assist with the processing and/or refund of that payment. Our contracts oblige these financial institutions to only use your personal information in connection with the services they provide to us and not for their own benefit.
Additionally, your information may be shared with other financial institutions, trade bodies, anti-fraud organizations and law enforcement agencies for the purposes of identifying and preventing fraud, money laundering, terrorist financing and other financial crimes.
NorthStar Currency is a business incorporated in Canada, which also operates several international affiliates and subsidiaries. We may share personal information with these, or future, affiliates.
If we are required to do so by law or legal process or to comply with the law, or when we believe, in our sole discretion, that the disclosure of personal information is appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity or to investigate violations of our Terms of Use and other agreements.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction.

We do not rent, sell, or share personal information about you with other people or non affiliated companies for their direct marketing purposes, unless we have your permission.

On our website, you may choose to use certain features which are provided by other entities. These features, which include social networking buttons (which will be prominently displayed on our webpage), are operated by third parties that are not affiliated with NorthStar Currency, and they may collect information directly from you. These third parties may use your information in accordance with their own privacy policies and practices.

D. Legal basis for processing

We collect and process information about you only when we have a legal basis for doing so under applicable laws. This means we collect and use your information where:

We need to provide you the service, provide customer support, and to protect the security of the service;
In some instances, we may share your information if we believe that having your information is reasonably necessary to comply with any applicable laws.

E. Your Rights and Choices

You may have certain rights regarding the personal information we collect and maintain about you and how we communicate with you.

When we request information from you on the Service, you may always choose not to provide us with that information. However, if you decline to provide us with certain information, we may not be able to provide you with the Service offered.
If you are located in Europe or UK you may direct us not to share your personal information with third parties, except (i) with the service providers and financial institutions under contract we have retained to perform services on our behalf, (ii) in the event we are acquired or we transfer all or a portion of our business or assets, (iii) if a legal process or law requires disclosure, (iv) with other financial institutions, trade bodies, anti-fraud organizations and law enforcement agencies for the purposes of identifying and preventing fraud, money laundering, terrorist financing and other financial crimes, or (v) when we believe, in our sole discretion, that the disclosure of personal information is appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
You can access, modify or update certain personal information submitted on our Service by contacting us by email, studentpay@northstarcurrency.com. Subject to applicable law, you may have the right to request access to and receive other personal information we hold about you, update and correct inaccuracies in your personal information, and have the information deleted, as appropriate or to request a copy of your information. To exercise these rights, contact us as described below (see section N of this privacy policy). Your right to access, update, correct or delete personal information may be limited in some circumstances by local law requirements.
Where your data is needed to be shared with third parties for payment, for example, payment partners, you will need to contact those third-party service providers directly to enforce your rights.
You may ask us to stop using or processing your data where you have given us consent.
You may contact us to withdraw your consent, but this will not affect any processing that has already taken place at the time.

F. Data Transfer

To facilitate our global operations, we transfer and store information in Canada and allow access to that information from other countries in which NorthStar Currency operates. These countries may not have the equivalent privacy laws as those of the EU or UK. When we share information about you within and among our corporate affiliate we make use of standard contractual data protection clauses, which have been approved by the European Commission.

G. How We Protect Your Personal Information

NorthStar Currency maintains reasonable safeguards combining administrative, technical, and physical measures to provide protection to the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, interference, modification, disclosure or misuse.

We use data hosting service providers in Canada to host the information we collect and we use technical controls to secure that data

We use Secure Socket Layer (SSL) encryption on our website when transmitting information and use other commercially reasonable efforts to protect your information. We continue to assess new technology for protection of information and upgrade our information security systems where appropriate. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

H. Notice

During initiation of payment, every NorthStar Currency user is provided with our Global Privacy Policy, which provides details regarding our collection and handling of Personal Information and instructions for accessing this European privacy policy.

I. Retention

We retain your information for as long as is necessary to comply with our legal obligations. After such time we will either delete or anonymize your information or if it is not possible then we will securely store your information and isolate it from any further use until deletion is possible.

J. Children’s Privacy

NorthStar Currency is not directed to children, and we do not knowingly collect personal information from children under 13. If we find out that a child under 13 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 13 has given us personal information, please email us at studentpay@northstarcurrency.com

K. Links to Other Websites

Our site may include links to other websites. When you access another website, we strongly suggest you review the privacy policy or notices on those external websites. NorthStar Currency not responsible for the content or privacy practices of external websites.

L. Changes to Our Privacy Policy

NorthStar Currency may periodically make changes to this privacy policy to reflect any changes in our information practices. We will notify you by revising the “Last Updated” date at the top of this Privacy Policy. If we make any material changes, we will let you know through the Service, by email, or other communication. We encourage Users to read this Privacy Policy periodically to stay up-to-date about our privacy practices. As long as you use the Service, you are agreeing to this Privacy Policy and any updates we make to it.

M. Questions, Comments and Complaints about Our Handling of Personal Information

If you have any questions, comments or complaints about our collection, use, storage or disclosure of personal information, please contact us as set forth below. NorthStar Currency will take any privacy complaint seriously and we will aim to resolve any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

N. Information related to the Personal Information Protection and Electronic Documents Act (PIPEDA) applicable in Canada

The legal base for the processing of personal data of clients located in Canada where PIPEDA applies, will be the consent of the client expressed by the client with the providing of it’s personal data to us. What types of data will be collected, the purposes for which this data will be used, the retention periods, and the recipients of the data are specified above in our Global Privacy Policy and apply to all of our clients and users. Each client may withdraw the consent that was provided by reaching out to us through the contact details below, however, if the consent is withdrawn we will not be able to provide you with our services. When data is provided to us by third parties (Educational institutions or Agents), these third parties will be responsible to ensure that appropriate legal basis for processing of the data under PIPEDA is in place.

If you are located in Canada you will have the right to:

Access your personal data maintained by us without restrictions. Upon request, we will inform you about the existence, the use, and disclosure of your personal information and will give you access to this information.
After we provide you with the information mentioned above you will have the right to make modifications where needed.
You have the right to lodge complaints about how your data is used if you sense that someone is violating your privacy.

O. Family Educational Rights and Privacy Act (FERPA)

FERPA applies to any public or private elementary, secondary, or post-secondary school (Educational institution) and any state or local education agency that receives funding from the US Department of Education.

FERPA provides the students the right of privacy regarding educational information and records unless the Educational institution has specific permission from the student/parent to share that specific type of information unless an exception applies or the information was designated as "directory information". Any Educational institution that is subject to FERPA must assess what data it could share with us and to ensure for itself how to comply with the applicable requirements. However, we have made the following commitments to show how we will support our partners in complying with FERPA:

We commit to use all personal data that we receive from the Educational Institutions only to provide them and their students with our services and compatible purposes.

We also commit not to disclose such data except as necessary for the performing of our services, or as required by law.

P. Contact Information

If you have any questions or concerns related to this privacy policy, or if you wish to request access to, or correction of, your personal information or make a privacy complaint or to contact the designated individual who is responsible for our organization's compliance under PIPEDA, you may contact us at:

NorthStar Currency
Attn: Privacy Officer
Email: studentpay@northstarcurrency.com

Our representative in the EU for matters concerning data protection is NorthStar Currency Ltd, located at Unit 3D, North Point House, New Mallow, Rd, Cork, Ireland, T23C6CV, Ireland, email: studentpay@northstarcurrency.com