RBCPay Privacy & Personal Information Protection Policy

Privacy Is Built Into Every Transaction

Privacy is not limited to a privacy notice displayed on a website.

It is the combination of what information RBCPay collects, why it is collected, how it is obtained, how it is used, who can access it, when it is disclosed, where it is stored, how it is protected, how long it is retained, and how it is securely deleted or anonymized when no longer required.

RBCPay operates under one fundamental privacy principle:

Personal information is collected, used, disclosed, accessed, retained and protected only for legitimate and authorized purposes connected with RBCPay’s marketplace, transaction, payment, security, compliance and business operations.

RBCPay incorporates privacy throughout the information lifecycle:

COLLECT → IDENTIFY PURPOSE → OBTAIN AUTHORITY/CONSENT → USE → PROTECT → CONTROL ACCESS → DISCLOSE RESPONSIBLY → RETAIN → DELETE OR ANONYMIZE

Privacy protection applies from the moment information enters RBCPay’s environment through its final authorized disposition.

1. PURPOSE OF THIS POLICY

This Privacy & Personal Information Protection Policy establishes RBCPay’s requirements concerning personal information.

The policy explains:

What information RBCPay collects;
Why RBCPay collects information;
How information is collected;
How information is used;
How information is disclosed;
How payment information is handled;
How identity information is handled;
How transaction information is handled;
How security information is handled;
How information is protected;
How long information is retained;
How users may exercise applicable privacy rights;
How RBCPay manages service providers;
How RBCPay responds to privacy incidents; and
How RBCPay maintains accountability for personal information.

2. SCOPE

This policy applies to personal information processed through RBCPay’s:

Website;
Marketplace;
Buyer accounts;
Seller accounts;
Payment-related services;
Registration systems;
Identity-verification procedures;
Customer-support channels;
Transaction-management systems;
Fraud-prevention systems;
Dispute-management procedures;
Mobile or web applications;
Administrative systems;
Communications;
Security systems; and
Other services operated on behalf of RBCPay.

The policy applies to information concerning:

Buyers;
Sellers;
Business representatives;
Website visitors;
Applicants;
Authorized users;
Transaction participants;
Customer-support contacts; and
Other identifiable individuals interacting with RBCPay.

3. DEFINITION OF PERSONAL INFORMATION

For purposes of this policy, personal information means information about an identifiable individual, subject to the definitions and exclusions contained in applicable law.

Personal information may include:

Name;
Address;
Telephone number;
Email address;
Date of birth;
Identification information;
Account information;
Transaction history;
Payment-related information;
Device information;
Internet Protocol address;
Communications;
Verification information;
Shipping information;
Purchase history;
Dispute records;
Security information; and
Other information associated with an identifiable person.

Not every piece of information is equally sensitive.

RBCPay applies safeguards proportionate to the nature and sensitivity of the information.

4. RBCPAY PRIVACY PRINCIPLES

RBCPay’s privacy program is based on the following principles.

Accountability

RBCPay accepts responsibility for personal information under its control.

Purpose

RBCPay identifies legitimate purposes for collecting and processing personal information.

Proportionality

RBCPay collects information reasonably appropriate to the relevant purpose and transaction risk.

Transparency

RBCPay provides meaningful information concerning its privacy practices.

Consent and Legal Authority

RBCPay obtains consent where required and processes information under other lawful authority where applicable.

Data Minimization

RBCPay does not intentionally collect unnecessary personal information merely because it may someday be useful.

Access Control

Personal information is available only to authorized persons and systems with a legitimate requirement for access.

Security

Personal information receives safeguards appropriate to its sensitivity.

Retention Limitation

Personal information is retained according to legitimate operational and legal requirements.

Individual Rights

RBCPay provides mechanisms for individuals to exercise applicable privacy rights.

5. INFORMATION PROVIDED DIRECTLY BY USERS

RBCPay collects information users voluntarily provide when they:

Create an account;
Verify an account;
Create a buyer profile;
Create a seller profile;
List a product;
Purchase a product;
Sell a product;
Create a transaction;
Submit payment information;
Add banking information;
Upload documents;
Contact customer support;
Submit a complaint;
Open a dispute;
Request a refund;
Participate in verification;
Communicate through the platform; or
Otherwise interact with RBCPay.

6. ACCOUNT REGISTRATION INFORMATION

Account registration information may include:

Legal name;
Preferred name where applicable;
Email address;
Telephone number;
Country;
Province or state;
Mailing address;
Business address;
Account type;
Buyer or seller designation;
Username;
Authentication information; and
Account preferences.

RBCPay uses this information to establish, authenticate and administer user accounts.

7. SELLER INFORMATION

Seller accounts may require additional information.

This may include:

Legal business name;
Trade name;
Business registration number;
Incorporation information;
Registered address;
Business address;
Business telephone number;
Business email;
Website;
Authorized representative;
Seller category;
Relevant licence information;
Tax-related information;
Payment or settlement information;
Bank-account verification information; and
Other information reasonably required for marketplace operation, risk management or compliance.

8. BUSINESS REPRESENTATIVE INFORMATION

Where a user acts for a corporation, partnership or other organization, RBCPay may collect information concerning the authorized representative.

This may include:

Name;
Position;
Business email;
Business telephone number;
Authority;
Relationship to the organization;
Identification information where required; and
Documentation establishing signing or transactional authority.

RBCPay may verify that a person claiming to act for an organization has appropriate authority.

9. IDENTITY VERIFICATION INFORMATION

RBCPay may collect or process information necessary to verify identity.

Depending upon transaction risk and applicable requirements, this may include:

Full legal name;
Date of birth;
Residential address;
Government-issued identification;
Identification number;
Identification expiration date;
Country of issuance;
Photograph;
Selfie or liveness verification where used;
Business records;
Corporate registry information;
Beneficial ownership information where required;
Bank-account verification information; and
Verification results.

Identity information receives heightened protection.

10. IDENTITY VERIFICATION PROVIDERS

RBCPay may use specialized third-party identity-verification providers.

Where such providers are used, information may be transmitted directly to or processed by the provider.

RBCPay limits its own collection and retention of identity documents where practical and consistent with legal, security and operational requirements.

Third-party verification does not eliminate RBCPay’s responsibility to select and manage service providers appropriately.

11. PAYMENT INFORMATION

Depending upon the payment method selected, payment-related information may include:

Payment method;
Cardholder name;
Billing address;
Payment token;
Payment-provider transaction identifier;
Bank name;
Bank-account information;
Wire information;
ACH information;
Interac e-Transfer information;
Cheque information;
Money-order information;
Cryptocurrency transaction information;
Wallet address where applicable;
Payment amount;
Currency;
Payment status;
Refund information;
Chargeback information; and
Settlement information.

12. PAYMENT CARD INFORMATION

RBCPay minimizes its direct exposure to sensitive payment-card information.

Where practical, card information is submitted directly to qualified payment-processing infrastructure.

RBCPay does not intentionally retain card security codes after authorization where prohibited.

RBCPay’s systems are designed to avoid unnecessary storage of:

Full payment-card numbers;
CVV/CVC codes;
PIN information; and
Other sensitive authentication data.

Payment-card processing is managed in accordance with applicable contractual, payment-network and PCI DSS requirements.

13. BANKING INFORMATION

Where bank information is required for payments, settlements or verification, RBCPay limits access to personnel and systems requiring that information.

Banking information may include:

Account holder name;
Financial institution;
Transit or routing information;
Account information;
Verification status; and
Settlement history.

Banking information is treated as sensitive financial information.

14. CRYPTOCURRENCY INFORMATION

Where RBCPay supports approved cryptocurrency transactions, information may include:

Wallet address;
Blockchain transaction identifier;
Digital asset;
Transaction amount;
Network;
Confirmation status;
Exchange-rate information;
Payment-provider information; and
Other information required for processing, security or compliance.

Blockchain transactions may exist permanently on public distributed ledgers.

RBCPay cannot delete information independently recorded on a public blockchain.

15. CASH, CHEQUE AND MONEY-ORDER INFORMATION

Where permitted, RBCPay may maintain records relating to:

Payment instrument;
Amount;
Date received;
Receipt number;
Cheque or money-order reference;
Clearing status;
Deposit status;
Person receiving payment;
Verification information; and
Related transaction.

RBCPay does not treat physical receipt of an instrument as equivalent to final settlement.

16. TRANSACTION INFORMATION

RBCPay maintains information concerning marketplace transactions.

Transaction information may include:

Transaction ID;
Buyer;
Seller;
Product or service;
Product description;
Quantity;
Price;
Currency;
Taxes;
Fees;
Payment method;
Payment status;
Shipping information;
Delivery address;
Tracking information;
Inspection information;
Acceptance information;
Refunds;
Disputes;
Settlement status; and
Transaction timestamps.

17. PRODUCT AND ASSET INFORMATION

For certain transactions, RBCPay may collect information used to identify or verify goods.

This may include:

Product photographs;
Serial numbers;
Vehicle identification numbers;
Manufacturer;
Model;
Specifications;
Condition;
Ownership documentation;
Purchase invoices;
Warranty records;
Inspection reports;
Warehouse information; and
Shipping documents.

Some of this information may become personal information when associated with an identifiable individual.

18. SHIPPING AND DELIVERY INFORMATION

RBCPay may process:

Recipient name;
Delivery address;
Telephone number;
Email address;
Shipping provider;
Tracking number;
Shipment date;
Delivery date;
Delivery status;
Signature confirmation;
Bill of lading;
Delivery receipt;
Freight documentation; and
Other delivery evidence.

Shipping information is used to facilitate and document fulfillment.

19. MARKETPLACE COMMUNICATIONS

RBCPay may retain communications made through the platform.

These may include:

Buyer and seller messages;
Product questions;
Offers;
Transaction negotiations;
Shipping communications;
Dispute communications;
Support messages;
Complaints; and
Other marketplace communications.

RBCPay may use these communications for transaction administration, security, dispute resolution, fraud prevention and legal compliance.

Users are informed that communications made through marketplace systems may form part of the transaction record.

20. CUSTOMER SUPPORT INFORMATION

When users contact RBCPay, information may include:

Name;
Contact details;
Account information;
Transaction ID;
Description of issue;
Correspondence;
Attachments;
Screenshots;
Call records where lawfully recorded;
Support history; and
Resolution.

Support information is retained according to applicable retention requirements.

21. DISPUTE INFORMATION

Disputes may require additional information.

RBCPay may collect:

Complaint;
Response;
Transaction terms;
Photographs;
Videos;
Invoices;
Receipts;
Tracking information;
Delivery evidence;
Inspection reports;
Communications;
Refund requests;
Payment records;
Expert reports where applicable; and
Other relevant evidence.

Dispute information is accessed only for legitimate dispute, security, legal and operational purposes.

22. FRAUD AND RISK INFORMATION

RBCPay collects and generates information used to identify and reduce fraud.

This may include:

Account history;
Transaction history;
Device information;
IP information;
Login patterns;
Payment activity;
Failed payments;
Dispute history;
Chargeback information;
Account changes;
Risk indicators;
Verification results;
Shipping patterns;
Related accounts;
Security alerts; and
Risk assessments.

Fraud indicators do not automatically establish wrongdoing.

23. DEVICE AND TECHNICAL INFORMATION

When users access RBCPay, systems may automatically receive technical information.

This may include:

IP address;
Browser type;
Operating system;
Device type;
Device identifiers where permitted;
Language;
Referring page;
Pages visited;
Login timestamps;
Session information;
Error information; and
Security events.

This information is used for functionality, security, fraud prevention, troubleshooting and analytics.

24. LOG INFORMATION

RBCPay maintains logs necessary for security and accountability.

Logs may record:

Login attempts;
Successful logins;
Failed logins;
Password changes;
Email changes;
Telephone changes;
Bank-account changes;
Transaction actions;
Administrative actions;
Security alerts;
Payment events; and
System events.

Logs are protected from unauthorized modification and access.

25. COOKIES AND SIMILAR TECHNOLOGIES

RBCPay may use cookies and similar technologies for:

Authentication;
Session management;
Security;
Fraud prevention;
User preferences;
Website functionality;
Performance measurement; and
Analytics.

Where required, RBCPay provides appropriate information and choices concerning non-essential cookies.

Essential security and authentication technologies may be required for the service to function.

26. INFORMATION FROM THIRD PARTIES

RBCPay may receive information from third parties where permitted.

Sources may include:

Payment processors;
Financial institutions;
Identity-verification providers;
Shipping companies;
Fraud-prevention providers;
Business registries;
Public records;
Service providers;
Buyers;
Sellers; and
Other authorized sources.

RBCPay uses third-party information only for legitimate purposes consistent with applicable requirements.

27. PURPOSES FOR COLLECTING PERSONAL INFORMATION

RBCPay collects and processes personal information for purposes including:

Creating accounts;
Authenticating users;
Verifying identities;
Verifying businesses;
Operating the marketplace;
Processing transactions;
Facilitating payments;
Facilitating settlements;
Processing refunds;
Managing delivery;
Providing customer support;
Preventing fraud;
Protecting users;
Protecting RBCPay;
Managing disputes;
Maintaining transaction records;
Improving services;
Securing systems;
Enforcing Terms of Service;
Meeting legal obligations; and
Responding to lawful requests.

28. PURPOSE LIMITATION

RBCPay does not use personal information for materially unrelated purposes without appropriate authority.

Where a new use is materially different from the original purpose, RBCPay evaluates whether:

Additional notice is required;
Additional consent is required;
Another lawful basis applies; or
The proposed use is inappropriate.

29. DATA MINIMIZATION

RBCPay follows the principle:

Collect what is required. Protect what is collected. Retain only as long as legitimately necessary.

RBCPay does not intentionally collect excessive personal information merely because technology makes collection possible.

30. CONSENT

Where consent is the appropriate legal basis, RBCPay obtains meaningful consent appropriate to the circumstances.

Consent may be:

Express;
Electronic;
Written;
Implied where legally appropriate; or
Obtained through another legally permitted mechanism.

The form of consent reflects the sensitivity of the information and reasonable expectations of the individual.

31. WITHDRAWAL OF CONSENT

Where processing depends upon consent and applicable law permits withdrawal, users may withdraw consent subject to:

Legal requirements;
Contractual restrictions;
Transaction requirements;
Security requirements; and
Reasonable notice.

Withdrawal may affect RBCPay’s ability to provide services.

RBCPay explains material consequences where appropriate.

32. PROCESSING WITHOUT CONSENT

Certain circumstances may permit or require collection, use, preservation or disclosure without consent.

These may include circumstances involving:

Fraud prevention;
Investigations;
Legal proceedings;
Court orders;
Regulatory requirements;
Emergencies;
Debt collection;
Security incidents;
Law-enforcement requests; or
Other circumstances authorized by law.

RBCPay relies upon these exceptions only where applicable.

33. USER RESPONSIBILITY FOR THIRD-PARTY INFORMATION

Users must not provide RBCPay with another person’s personal information unless they have appropriate authority to do so.

Examples include:

Shipping recipient information;
Employee information;
Corporate representative information; and
Information submitted as dispute evidence.

Users remain responsible for ensuring they are authorized to provide such information.

34. HOW RBCPAY USES ACCOUNT INFORMATION

Account information is used to:

Operate accounts;
Authenticate users;
Communicate with users;
Provide marketplace functions;
Prevent unauthorized access;
Process transactions;
Maintain records;
Enforce platform rules; and
Provide support.

35. HOW RBCPAY USES TRANSACTION INFORMATION

Transaction information is used to:

Document agreements;
Process purchases;
Process sales;
Facilitate payments;
Track fulfillment;
Verify delivery;
Process acceptance;
Manage disputes;
Process refunds;
Facilitate settlement;
Detect fraud;
Maintain accounting records; and
Establish transaction history.

36. HOW RBCPAY USES SECURITY INFORMATION

Security information is used to:

Authenticate accounts;
Detect suspicious logins;
Identify account takeover;
Investigate fraud;
Protect payment information;
Prevent unauthorized transactions;
Restrict compromised accounts;
Investigate security incidents; and
Protect the integrity of the marketplace.

37. AUTOMATED RISK ANALYSIS

RBCPay may use automated systems to identify activity requiring additional review.

Risk analysis may consider legitimate factors including:

Transaction amount;
Account history;
Payment behaviour;
Device information;
Geographic indicators;
Shipping activity;
Verification results; and
Other fraud indicators.

Automated risk indicators may result in:

Additional verification;
Transaction review;
Payment review;
Temporary restriction; or
Manual investigation.

A risk flag does not itself establish fraud.

38. DISCLOSURE TO SELLERS

RBCPay discloses information to sellers reasonably necessary to complete transactions.

Depending upon the transaction, this may include:

Buyer name;
Delivery address;
Necessary contact information;
Order information;
Product information;
Transaction status; and
Other fulfillment information.

Sellers may use information received through RBCPay only for authorized purposes and in accordance with applicable law and marketplace requirements.

39. DISCLOSURE TO BUYERS

RBCPay may disclose information concerning sellers where appropriate.

This may include:

Seller name or business name;
Seller profile;
Business location;
Verification indicators;
Product information;
Shipping information;
Transaction communications; and
Other information reasonably required for marketplace transparency and transaction completion.

RBCPay does not publicly disclose unnecessary seller personal information.

40. DISCLOSURE TO PAYMENT PROVIDERS

RBCPay may provide information to:

Payment processors;
Acquiring institutions;
Card networks;
Banks;
ACH providers;
Cryptocurrency payment providers; and
Other payment service providers.

Information is disclosed as required to process, authenticate, settle, refund, investigate or secure transactions.

41. DISCLOSURE TO SHIPPING PROVIDERS

RBCPay or sellers may provide shipping companies with information required for delivery.

This may include:

Recipient name;
Address;
Telephone number;
Email;
Delivery instructions; and
Transaction-related shipping information.

42. DISCLOSURE TO IDENTITY AND FRAUD PROVIDERS

RBCPay may disclose information to specialized providers performing:

Identity verification;
Business verification;
Fraud prevention;
Account security;
Device analysis;
Payment-risk analysis; or
Other legitimate security services.

Such providers receive information according to applicable contractual and legal requirements.

43. SERVICE PROVIDERS

RBCPay may use service providers for:

Hosting;
Cloud infrastructure;
Data storage;
Communications;
Email;
SMS;
Customer support;
Analytics;
Cybersecurity;
Payment processing;
Identity verification;
Fraud prevention;
Shipping integration; and
Other operational functions.

RBCPay evaluates critical service providers based upon the nature of the service and information involved.

44. SERVICE PROVIDER CONTRACTS

Where appropriate, contracts with service providers address:

Permitted use of information;
Confidentiality;
Security;
Access restrictions;
Incident notification;
Data retention;
Subcontractors;
Return or deletion of information; and
Applicable legal requirements.

45. CORPORATE TRANSACTIONS

Personal information may be disclosed or transferred in connection with:

Merger;
Acquisition;
Financing;
Reorganization;
Sale of assets;
Due diligence;
Insolvency;
Corporate restructuring; or
Similar business transaction.

RBCPay handles such disclosures in accordance with applicable law.

46. LEGAL AND REGULATORY DISCLOSURES

RBCPay may preserve or disclose information where required or permitted by law.

This may include responding to:

Court orders;
Subpoenas;
Warrants;
Regulatory requests;
Tax authorities;
Law-enforcement requests;
Government authorities; and
Other legally authorized demands.

RBCPay evaluates requests according to applicable legal requirements.

47. EMERGENCY DISCLOSURES

Where legally permitted, RBCPay may disclose information where reasonably necessary to respond to an emergency involving serious threats to life, health or security.

Emergency disclosures are documented where appropriate.

48. RBCPAY DOES NOT SELL PERSONAL INFORMATION AS A DATA BROKER

RBCPay’s business model is based on marketplace and transaction services.

RBCPay does not operate as a data broker whose business consists of selling customer personal information to unrelated third parties for their independent use.

Any legally relevant definition of “sale” applicable in a particular jurisdiction is addressed according to the law of that jurisdiction.

49. MARKETING COMMUNICATIONS

Where permitted, RBCPay may communicate with users concerning:

Platform services;
New features;
Marketplace information;
Promotions;
Relevant offers; and
Service announcements.

Commercial electronic communications are managed according to applicable requirements.

Users receive available unsubscribe mechanisms for marketing communications.

50. TRANSACTIONAL COMMUNICATIONS

Users cannot necessarily opt out of communications required to operate an active account or transaction.

These may include:

Account verification;
Security alerts;
Payment notices;
Transaction confirmations;
Shipping notices;
Dispute communications;
Policy notices;
Legal notices; and
Other essential service communications.

51. CHILDREN AND MINORS

RBCPay’s marketplace and payment services are not intended for individuals who lack legal capacity to enter the applicable transactions.

Account eligibility requirements are established in RBCPay’s Terms of Service.

RBCPay does not knowingly design its marketplace for unauthorized financial transactions by children.

Where RBCPay discovers an ineligible minor account, appropriate restrictions and deletion or preservation procedures are applied according to applicable law.

52. INFORMATION SECURITY

RBCPay maintains administrative, technical and physical safeguards appropriate to the nature and sensitivity of information.

Security measures may include:

Encryption;
Secure network connections;
Access controls;
Multi-factor authentication;
Logging;
Monitoring;
Vulnerability management;
Secure development;
Backups;
Incident response;
Employee training;
Vendor management; and
Physical security.

53. ENCRYPTION IN TRANSIT

Information transmitted between users and RBCPay uses appropriately secured network connections.

RBCPay uses modern transport encryption appropriate to its systems and services.

54. PROTECTION OF STORED INFORMATION

Sensitive stored information receives safeguards appropriate to risk.

Controls may include:

Encryption;
Tokenization;
Access restriction;
Segmentation;
Logging;
Key management;
Backup protection; and
Other technical controls.

55. PASSWORD SECURITY

RBCPay does not store user passwords in readable plaintext.

Passwords are protected using appropriate one-way password-storage techniques.

RBCPay employees do not require users to disclose their passwords.

56. MULTI-FACTOR AUTHENTICATION

RBCPay supports or requires multi-factor authentication for designated accounts and sensitive actions.

Multi-factor authentication provides an additional layer of protection if a password becomes compromised.

57. EMPLOYEE ACCESS

Employee access to personal information follows the principle of least privilege.

Personnel receive access only where required for legitimate responsibilities.

Access may be based upon:

Role;
Department;
Information sensitivity;
Transaction requirements; and
Operational necessity.

58. ADMINISTRATIVE ACCESS

Administrative access receives heightened controls.

Controls include, as appropriate:

Individual administrator accounts;
Multi-factor authentication;
Role-based access;
Activity logging;
Periodic review;
Session controls; and
Prompt removal of unnecessary access.

Shared administrative credentials are prohibited.

59. CONFIDENTIALITY

Personnel with access to confidential or personal information are subject to appropriate confidentiality requirements.

Unauthorized access, disclosure, copying or use of personal information is prohibited.

60. SECURITY MONITORING

RBCPay monitors systems for security events appropriate to the risk profile of the platform.

Monitoring may include:

Unauthorized login attempts;
Suspicious account changes;
Administrative activity;
Payment anomalies;
System vulnerabilities;
Fraud indicators; and
Potential data exposure.

61. USER ACCOUNT SECURITY

Users are responsible for maintaining the confidentiality of account credentials.

Users are instructed to:

Use strong passwords;
Enable available multi-factor authentication;
Protect devices;
Never share passwords;
Never share one-time codes;
Review security notifications;
Verify payment instructions; and
Immediately report suspected unauthorized access.

62. SECURITY NOTIFICATIONS

RBCPay may notify users of material account-security events.

Examples include:

Password change;
Email change;
Telephone change;
Bank-account change;
New login;
Suspicious activity;
Account restriction; and
Other significant security events.

63. DATA BREACH AND PRIVACY INCIDENT RESPONSE

RBCPay maintains a privacy and security incident-response process.

The process follows:

IDENTIFY → CONTAIN → PRESERVE → ASSESS → INVESTIGATE → NOTIFY → REMEDIATE → REVIEW

64. BREACH ASSESSMENT

When a privacy incident occurs, RBCPay evaluates factors including:

Nature of information;
Sensitivity;
Number of individuals affected;
Whether information was encrypted;
Whether information was actually accessed;
Duration of exposure;
Likelihood of misuse;
Potential consequences;
Ability to recover information; and
Applicable notification requirements.

65. REQUIRED BREACH NOTIFICATION

Where applicable law requires notification, RBCPay provides required notices to:

Affected individuals;
Privacy regulators;
Other authorities; and
Relevant service providers.

Notifications are provided according to applicable legal thresholds and timelines.

66. BREACH RECORDS

RBCPay maintains records of privacy and security incidents where required or appropriate.

Records may include:

Date;
Nature of incident;
Information affected;
Individuals affected;
Investigation;
Risk assessment;
Notification determination;
Remediation; and
Corrective measures.

67. DATA RETENTION

RBCPay does not retain all personal information indefinitely.

Retention depends upon:

Purpose;
Transaction status;
Legal obligations;
Accounting requirements;
Tax requirements;
Payment-provider requirements;
Fraud prevention;
Disputes;
Litigation;
Regulatory obligations; and
Security requirements.

68. TRANSACTION RECORD RETENTION

Transaction records are retained for periods reasonably necessary to support:

Transaction history;
Accounting;
Taxation;
Disputes;
Chargebacks;
Fraud prevention;
Regulatory requirements; and
Legal claims.

Retention periods are documented in RBCPay’s Data Retention & Destruction Policy.

69. IDENTITY RECORD RETENTION

Identity information is retained only for the period required by legitimate verification, security, contractual and legal requirements.

RBCPay reduces unnecessary retention of identification documents where practical.

70. SECURITY LOG RETENTION

Security logs are retained for periods appropriate to:

Fraud detection;
Incident investigation;
Account security;
Legal requirements;
Audit; and
Cybersecurity operations.

71. DISPUTE RECORD RETENTION

Dispute records may be retained beyond transaction completion where reasonably required to address:

Appeals;
Chargebacks;
Legal claims;
Fraud patterns;
Regulatory requirements; and
Repeat misconduct.

72. LEGAL HOLDS

Normal deletion is suspended where information becomes subject to a legitimate legal hold.

A legal hold may arise from:

Litigation;
Anticipated litigation;
Investigation;
Regulatory requirement;
Court order;
Law-enforcement matter; or
Other legal obligation.

Information subject to a legal hold is preserved until authorized release of the hold.

73. SECURE DELETION

When information reaches the end of its retention period and no exception applies, RBCPay securely deletes, destroys or anonymizes it using methods appropriate to the information and storage system.

74. BACKUPS

Deleted information may temporarily remain in secure backup systems until normal backup rotation or destruction.

Backup information remains protected and is not restored for ordinary business use solely to recover information previously scheduled for deletion.

75. ANONYMIZATION AND AGGREGATION

RBCPay may create aggregated or anonymized information for purposes including:

Analytics;
Security;
Fraud research;
Business planning;
Platform improvement; and
Statistical reporting.

RBCPay applies reasonable measures designed to prevent anonymized information from identifying an individual.

76. INTERNATIONAL AND CROSS-BORDER PROCESSING

RBCPay may use service providers or infrastructure located outside the user’s province or country.

As a result, information may be processed in other jurisdictions.

Information located in another jurisdiction may be subject to the laws and lawful access requirements of that jurisdiction.

RBCPay evaluates cross-border service arrangements according to applicable privacy, security and contractual requirements.

77. DATA LOCATION TRANSPARENCY

RBCPay maintains reasonable knowledge of where critical categories of personal information are processed by material service providers.

RBCPay’s internal vendor records identify relevant hosting and processing arrangements.

78. ACCESS REQUESTS

Individuals may request access to personal information about themselves subject to applicable law.

RBCPay verifies the identity of the requester before providing sensitive information.

Access may be limited where permitted or required by law.

79. IDENTITY VERIFICATION FOR PRIVACY REQUESTS

Privacy rights cannot safely be exercised without verifying the requester.

RBCPay may require sufficient information to establish that the requester is the individual to whom the information relates or is properly authorized to act for that individual.

RBCPay does not disclose personal information merely because a requester knows an account name or email address.

80. CORRECTION REQUESTS

Individuals may request correction of inaccurate personal information subject to applicable law.

RBCPay evaluates correction requests and makes appropriate amendments where warranted.

Certain historical transaction records are not rewritten merely because current information changes.

For example:

A current address may be updated while the historical delivery address associated with a completed transaction remains part of the transaction record.

81. DELETION REQUESTS

Where applicable law provides a deletion right, RBCPay processes valid requests subject to permitted exceptions.

Information may need to be retained for:

Completed transactions;
Legal obligations;
Accounting;
Tax;
Fraud prevention;
Security;
Disputes;
Chargebacks;
Legal claims; or
Regulatory requirements.

Account closure does not automatically require immediate deletion of every historical record.

82. ACCOUNT CLOSURE

Users may request account closure according to RBCPay’s account procedures.

Before closure, RBCPay may require:

Completion of open transactions;
Resolution of disputes;
Settlement of balances;
Completion of refunds;
Verification of identity; and
Satisfaction of legal or contractual requirements.

Information remaining after closure is governed by applicable retention requirements.

83. DATA PORTABILITY

Where applicable law provides portability rights, RBCPay responds to valid requests in accordance with applicable requirements and technical feasibility.

Portability does not require disclosure of information that would compromise:

Another person’s privacy;
Security systems;
Fraud controls;
Confidential business information; or
Legally protected information.

84. PRIVACY COMPLAINTS

Users may submit complaints regarding RBCPay’s handling of personal information.

Complaints are documented and reviewed.

The review considers:

Nature of complaint;
Information involved;
Applicable policy;
Applicable law;
Relevant systems;
Relevant employees or providers;
Corrective action; and
Response to the complainant.

85. NON-RETALIATION

RBCPay does not retaliate against an individual solely for exercising a legitimate privacy right or submitting a good-faith privacy complaint.

This does not prevent RBCPay from taking legitimate action relating to fraud, abuse, unpaid obligations, prohibited conduct or violation of marketplace rules.

86. PRIVACY OFFICER

RBCPay designates responsibility for privacy governance.

The designated Privacy Officer or responsible privacy function oversees:

Privacy policy;
Privacy inquiries;
Privacy complaints;
Access requests;
Correction requests;
Privacy incidents;
Vendor privacy issues;
Employee training;
Retention;
Privacy assessments; and
Compliance monitoring.

87. PRIVACY BY DESIGN

RBCPay considers privacy when developing new systems and services.

New features are evaluated by asking:

What personal information is collected?
Why is it required?
Can less information be collected?
How sensitive is it?
Who needs access?
Where will it be stored?
Which providers receive it?
How will it be protected?
How long will it be retained?
How will it be deleted?
What happens if it is compromised?
What information will users receive?

Privacy requirements are incorporated into product design.

88. PRIVACY IMPACT ASSESSMENT

Material new products, technologies or data uses may receive a privacy assessment before implementation.

Examples include:

New identity-verification systems;
Biometric verification;
New payment methods;
New fraud-detection systems;
New artificial-intelligence systems;
New international providers;
New advertising technologies;
New sensitive-data collections; and
Material changes to information sharing.

89. BIOMETRIC INFORMATION

Where RBCPay or an identity-verification provider uses facial comparison, liveness detection or other biometric-related technology, RBCPay evaluates applicable consent, notice, retention, security and legal requirements before implementation.

Biometric functionality is treated as high sensitivity.

90. ARTIFICIAL INTELLIGENCE

Where RBCPay uses artificial intelligence or machine-learning systems involving personal information, RBCPay applies appropriate privacy, security and governance controls.

Potential uses may include:

Fraud detection;
Risk analysis;
Customer support;
Security monitoring; and
Transaction analysis.

RBCPay does not treat automated output as infallible.

High-impact decisions receive appropriate safeguards and human review where required.

91. FRAUD PREVENTION VERSUS PRIVACY

RBCPay recognizes that effective fraud prevention can require analysis of personal information.

Fraud controls remain proportionate.

RBCPay does not use fraud prevention as an unlimited justification for collecting unrelated information.

The operating principle is:

Collect enough information to protect the transaction without collecting information that has no legitimate relationship to the risk.

92. PRIVACY AND DISPUTE EVIDENCE

Users submitting dispute evidence are instructed to provide only information relevant to the dispute.

Users are discouraged from uploading unnecessary:

Full banking statements;
Complete card numbers;
Passwords;
Security codes;
Unrelated identification;
Medical records;
Information concerning unrelated individuals; or
Other unnecessary sensitive information.

RBCPay may redact or restrict unnecessary sensitive information where appropriate.

93. PRIVACY AND MARKETPLACE LISTINGS

Sellers are prohibited from intentionally publishing unnecessary sensitive personal information in public marketplace listings.

Public listings are not appropriate locations for:

Personal identification numbers;
Bank-account information;
Full residential information where unnecessary;
Payment-card information;
Passwords;
Government identification; or
Confidential customer information.

94. PUBLIC AND PRIVATE INFORMATION

RBCPay distinguishes between information intended to be publicly displayed and information maintained privately.

Potentially Public

Seller display name;
Business name;
Marketplace profile;
Product listing;
Seller rating;
Product photographs; and
Other information intentionally designated for public display.

Private

Identity documents;
Password information;
Bank information;
Detailed payment records;
Private communications;
Fraud information;
Security logs; and
Internal risk assessments.

Users are informed where information will be publicly displayed.

95. SELLER PRIVACY RESPONSIBILITIES

Sellers receiving buyer information through RBCPay use it only for legitimate transaction purposes.

Seller use may include:

Order fulfillment;
Delivery;
Customer service;
Returns;
Required records; and
Legal compliance.

Seller misuse of buyer information may result in account restriction or other action.

96. BUYER PRIVACY RESPONSIBILITIES

Buyers may receive seller information necessary for marketplace transactions.

Buyers may not use marketplace information to:

Harass sellers;
Commit fraud;
Circumvent security;
Publish private information without authority;
Conduct identity theft; or
Engage in other prohibited activity.

97. EMPLOYEE PRIVACY TRAINING

Personnel with access to personal information receive privacy and security training appropriate to their responsibilities.

Training may include:

Confidentiality;
Access controls;
Phishing;
Identity information;
Payment information;
Customer verification;
Secure document handling;
Privacy incidents;
Customer requests;
Data minimization; and
Secure disposal.

98. EMPLOYEE MONITORING AND AUDIT

RBCPay may audit employee and administrator access to sensitive systems.

RBCPay investigates:

Unauthorized access;
Unusual downloads;
Unnecessary record access;
Unauthorized disclosure;
Privilege misuse; and
Other suspicious administrative activity.

Access to customer information is a business privilege, not a personal entitlement.

99. VENDOR PRIVACY MANAGEMENT

Critical vendors processing personal information are subject to risk-appropriate review.

Review may address:

Information processed;
Processing purpose;
Security;
Privacy practices;
Location;
Subprocessors;
Incident history;
Contract terms;
Retention;
Deletion; and
Business continuity.

100. SUBPROCESSORS

Where service providers use subprocessors, RBCPay manages subprocessor risk according to the nature of the service and contractual arrangements.

Material subprocessors with access to sensitive information receive appropriate scrutiny.

101. DATA INVENTORY

RBCPay maintains an internal understanding of significant categories of personal information.

The data inventory identifies, where appropriate:

WHAT INFORMATION

↓

WHY IT IS COLLECTED

↓

WHERE IT IS STORED

↓

WHO CAN ACCESS IT

↓

WHO RECEIVES IT

↓

HOW LONG IT IS RETAINED

↓

HOW IT IS DISPOSED OF

This inventory supports accountability.

102. RECORD OF PROCESSING ACTIVITIES

Where appropriate, RBCPay documents significant personal-information processing activities.

Records may include:

Purpose;
Information categories;
Individuals affected;
Systems;
Recipients;
Service providers;
Retention;
Security controls; and
Cross-border processing.

103. NO UNAUTHORIZED COPYING

Employees, contractors and administrators may not copy personal information to:

Personal devices;
Personal email;
Unauthorized cloud storage;
Unapproved messaging applications;
Removable storage; or
Other unauthorized locations.

Exceptions require documented authorization.

104. SECURE REMOTE WORK

Where personnel access RBCPay information remotely, appropriate controls apply.

Controls may include:

Managed devices;
Multi-factor authentication;
Secure network connections;
Device encryption;
Screen locking;
Access restrictions;
Endpoint security; and
Prohibition on unauthorized local storage.

105. PHYSICAL RECORDS

Where RBCPay maintains physical documents containing personal information, records are protected through appropriate physical controls.

Controls may include:

Locked storage;
Restricted access;
Secure offices;
Visitor controls;
Document tracking; and
Secure destruction.

106. PRINTING PERSONAL INFORMATION

Sensitive personal information is not printed unless operationally necessary.

Printed records are collected promptly from printers and stored or destroyed securely.

Sensitive documents are not left unattended in public or shared areas.

107. EMAIL SECURITY

Sensitive personal information is not transmitted through ordinary email where a more secure approved method is required by RBCPay’s security procedures.

Employees verify recipients before sending confidential information.

High-risk information receives additional safeguards.

108. PAYMENT INSTRUCTION SECURITY

RBCPay does not treat unexpected emailed banking instructions as automatically authentic.

Changes to settlement or banking information require authenticated procedures.

Privacy and payment security operate together to prevent unauthorized disclosure and payment diversion.

109. LAW-ENFORCEMENT REQUEST MANAGEMENT

Requests for customer information from law enforcement or government agencies are routed to authorized RBCPay personnel.

RBCPay verifies the nature and legal authority of requests before disclosure where legally permitted.

RBCPay documents disclosures as appropriate.

110. GOVERNMENT REQUEST MINIMIZATION

Where legally permitted, RBCPay limits disclosures to information reasonably responsive to a valid request.

RBCPay does not voluntarily provide unrelated customer information merely because a lawful request exists for other information.

111. PRESERVATION REQUESTS

Where legally valid preservation requirements apply, RBCPay preserves identified records for the required period.

Preservation does not automatically authorize disclosure.

Disclosure requires appropriate legal authority.

112. INFORMATION ACCURACY

RBCPay takes reasonable steps appropriate to the purpose to maintain accurate personal information.

Users are responsible for keeping important account information current.

RBCPay may request reverification when information appears inconsistent or outdated.

113. HISTORICAL ACCURACY

RBCPay preserves historical transaction accuracy.

Updating current information does not rewrite historical facts.

For example:

Current Address: Updated

Address Used for Transaction #12345: Preserved

This distinction protects both privacy and transaction integrity.

114. SECURITY VERSUS ACCESS RIGHTS

RBCPay balances privacy access rights with security.

Information provided in response to an access request may exclude or redact information where disclosure would improperly reveal:

Another individual’s personal information;
Confidential fraud controls;
Security architecture;
Internal risk indicators;
Legally privileged information; or
Other information protected by law.

115. ACCOUNT FRAUD AND PRIVACY REQUESTS

RBCPay may delay fulfillment of a privacy request where additional identity verification is reasonably required because of suspected account compromise.

Protecting personal information from an impostor takes priority over responding to an inadequately authenticated request.

116. PRIVACY COMPLAINT INVESTIGATION

Privacy complaints follow a documented process:

RECEIVE

Record the complaint.

VERIFY

Confirm relevant identity where necessary.

ASSESS

Determine the issue and applicable requirements.

INVESTIGATE

Review relevant systems, records and personnel.

CORRECT

Take corrective action where warranted.

RESPOND

Provide an appropriate response.

RECORD

Maintain the complaint record.

117. POLICY VIOLATIONS

Unauthorized handling of personal information may result in:

Removal of system access;
Internal investigation;
Corrective action;
Contractual action;
Employment consequences;
Account restriction;
Legal action; or
Referral to appropriate authorities where warranted.

118. NO UNDOCUMENTED PRIVACY OVERRIDES

RBCPay applies the following requirement:

There are no undocumented privacy overrides.

Where an authorized exception is necessary, the record identifies:

Information involved;
Purpose;
Person authorizing the exception;
Legal or operational justification;
Duration;
Risk;
Compensating controls; and
Final disposition.

119. PRIVACY POLICY REVIEW

RBCPay reviews this policy periodically and following material changes.

Review may be triggered by:

New services;
New payment methods;
New verification technologies;
New jurisdictions;
New service providers;
Material privacy incidents;
Regulatory developments;
Significant security changes; or
New categories of personal information.

120. CHANGES TO THIS POLICY

RBCPay may amend this Privacy & Personal Information Protection Policy as its services, technology, regulatory obligations and business operations evolve.

Material changes are communicated as required.

The effective date and most recent revision date are maintained with the published policy.

121. PRIVACY CONTACT

Questions, requests or complaints concerning RBCPay’s privacy practices are directed to RBCPay’s designated privacy contact.

RBCPay Privacy Office

Email: [PRIVACY EMAIL]

Mailing Address:
[RBCPAY LEGAL ENTITY]
[REGISTERED ADDRESS]
[CITY, PROVINCE/STATE, POSTAL/ZIP CODE]
[COUNTRY]

Users submitting privacy requests are asked to provide sufficient information to identify the relevant account or transaction without sending passwords or unnecessary sensitive information.

122. RBCPAY PRIVACY STANDARD

RBCPay summarizes its privacy framework in six principles:

COLLECT. LIMIT. PROTECT. CONTROL. RETAIN. DELETE.

COLLECT

Collect information for legitimate and identified purposes.

LIMIT

Limit collection, use and disclosure to what is appropriate.

PROTECT

Apply safeguards appropriate to sensitivity and risk.

CONTROL

Restrict access and disclosure to authorized persons and systems.

RETAIN

Maintain information only for legitimate operational and legal periods.

DELETE

Securely destroy or anonymize information when retention is no longer justified.

123. RBCPAY PRIVACY CHAIN

Every significant category of personal information follows a defined privacy chain:

WHAT ARE WE COLLECTING?

Identify the information.

↓

WHY DO WE NEED IT?

Identify the legitimate purpose.

↓

ARE WE AUTHORIZED TO COLLECT IT?

Establish consent or other legal authority.

↓

WHERE WILL IT GO?

Identify systems and providers.

↓

WHO CAN ACCESS IT?

Apply role-based controls.

↓

HOW IS IT PROTECTED?

Apply security appropriate to sensitivity.

↓

WHO CAN RECEIVE IT?

Restrict disclosure.

↓

HOW LONG DO WE NEED IT?

Apply retention requirements.

↓

WHAT HAPPENS AT THE END?

Delete, destroy or anonymize.

124. FINAL PRIVACY PRINCIPLE

RBCPay does not treat personal information as an unlimited corporate asset.

Personal information is entrusted to RBCPay for specific purposes connected with marketplace participation, transactions, security, payment processing, customer service and legitimate business operations.

RBCPay’s privacy framework is founded on:

Purpose + Proportionality + Transparency + Security + Accountability + Individual Rights

RBCPay evaluates every material use of personal information by asking:

Do we need this information?

Why do we need it?

Are we authorized to collect it?

Who needs access to it?

How sensitive is it?

How are we protecting it?

Are we sharing it?

Why are we sharing it?

How long do we need it?

Can we safely delete it?

The ability to collect information does not, by itself, justify collecting it.

The ability to retain information does not, by itself, justify retaining it indefinitely.

The ability to access information does not, by itself, authorize an employee to access it.

The ability to share information does not, by itself, establish a legitimate reason to disclose it.

Privacy is therefore not merely a statement displayed on RBCPay.com.

It is the operating structure governing how RBCPay handles personal information throughout the entire relationship with a user.

125. POLICY COMMITMENT

RBCPay adopts this Privacy & Personal Information Protection Policy as a core operational requirement.

RBCPay maintains personal-information practices designed around:

Legitimate purposes;
Appropriate consent and legal authority;
Data minimization;
Transparency;
Access control;
Security;
Responsible disclosure;
Retention management;
Individual privacy rights;
Service-provider oversight;
Incident response; and
Organizational accountability.

RBCPay’s privacy commitment is:

Information entrusted to RBCPay is handled for legitimate purposes, protected according to its sensitivity, accessible only where authorized, disclosed only where appropriate, retained only as required, and securely disposed of when continued retention is no longer justified.

126. RELATIONSHIP TO OTHER RBCPAY POLICIES

This Privacy & Personal Information Protection Policy operates together with:

RBCPay Security & Transaction Integrity Policy
Terms of Service
Information Security Policy
Identity Verification / KYC Policy
Fraud Prevention & Risk Policy
Payment & Settlement Policy
Buyer Protection Policy
Seller Protection Policy
Dispute Resolution Policy
Data Retention & Destruction Policy
Incident Response Plan
Administrator Access Policy
Vendor & Payment Provider Management Policy
Complaint Handling Policy
Business Continuity & Disaster Recovery Plan
Cookie Policy
Marketing Communications Policy
Cryptocurrency Policy, where applicable
Payment Card Security Procedures
Employee Confidentiality & Access Procedures

Where policies overlap, RBCPay applies them consistently.

127. IMPORTANT LEGAL AND OPERATIONAL NOTICE

This policy describes RBCPay’s privacy governance framework.

Specific legal obligations depend upon:

RBCPay’s legal entity;
Place of establishment;
Locations of users;
Nature of transactions;
Information collected;
Payment architecture;
Service providers;
International transfers;
Applicable Canadian federal and provincial privacy legislation;
Applicable foreign privacy legislation; and
Other regulatory requirements.

RBCPay implements only privacy representations that correspond to its actual systems and practices.

Statements concerning:

Encryption;
Data location;
Identity verification;
Data deletion;
Payment-card storage;
International processing;
Biometrics;
Artificial intelligence;
Service-provider access; and
Information retention

are maintained accurately and updated whenever the underlying operational practices materially change.

128. EFFECTIVE DATE AND VERSION CONTROL

Policy Name: RBCPay Privacy & Personal Information Protection Policy

Policy Owner: Privacy / Compliance

Approved By: RBCPay Management

Effective Date: [EFFECTIVE DATE]

Last Reviewed: [DATE]

Next Scheduled Review: [DATE]

Policy Version: 1.0

Classification: Public / Internal Governing Policy

The current approved version supersedes prior versions to the extent of any inconsistency.

Historical versions are retained according to RBCPay’s policy-record retention requirements.

RBCPay PRIVACY COMMITMENT

YOUR INFORMATION. YOUR TRANSACTIONS. PROTECTED BY POLICY AND PROCESS.

RBCPay recognizes that a marketplace cannot operate without trust.

That trust depends upon more than technology.

It depends upon disciplined decisions about what information is collected, who can see it, why it is used, where it goes and when it is removed.

For that reason:

We collect with purpose.

We verify responsibly.

We restrict access.

We protect sensitive information.

We document authorized disclosures.

We manage our service providers.

We investigate privacy incidents.

We respect applicable privacy rights.

We retain information only for legitimate reasons.

We securely dispose of information when continued retention is no longer required.

Privacy is not an additional feature of RBCPay.

Privacy is part of how RBCPay operates.

Privacy Policy