The Privacy Policy below governs your 2C2P account and any information you provide on this site.

A. Introduction
B. Information We Collect
C. Our Use and Disclosure of Information
D. Information Security
E. Accessing and Changing Your Information
F. Contacting Us

A. Introduction

In order to operate the 2C2P service and to reduce the risk of fraud, SinaptIQ Co., Ltd (‘2C2P’ or ‘we’) must ask you to provide us information about yourself and your credit card and/or bank account. This Privacy Policy describes the information we collect and how we use that information. 2C2P takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the 2C2P.com Web site.

Notification of Changes

This policy may be revised over time as new features are added to the 2C2P service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail. If you have closed your 2C2P account, you will not be contacted to notify you of the amended Policy and your personal information will not be used or disclosed in this new manner. We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the 2C2P Web site at https://www.2C2P.com/ at any time for the most current version of our Privacy Policy.

B. Information We Collect
Required Information

To open a 2C2P account, you must provide your name, address, phone number, and e-mail address. In order to make payments through 2C2P, you must provide credit card (Visa or MasterCard) or bank account information. We also ask you to choose two different security questions to answer (such as maiden name or your first school name). This required information is necessary for us to process transactions, issue a new Password if you forget or lose your Password, protect you against credit card fraud and bank account fraud, and to contact you should the need arise in administering your account.

Transaction Information

When you use 2C2P to send money to someone else or request money from someone else, we ask you to provide information related to each transaction, including the amount of the transaction, the type of transaction (purchase of goods, purchase of services, or simple money transfer and the e-mail address of the third party. We retain this information for each of your transactions through 2C2P. We also collect the Internet address (IP address) of the computer or device you use to access your 2C2P account, in order to help detect possible instances of unauthorized transactions.

Information About You From Third Parties

In order to protect all our customers against potential fraud, we verify with third parties the information you provide.

Additional Verification

If we cannot verify the information that you provide, we will ask you to send us additional information by fax (such as your Citizen ID, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions online to help verify your information.

Web Site Traffic Information

Because of the way that World Wide Web communication standards work, when you arrive at or leave the 2C2P Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the 2C2P site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve our service and your experience with 2C2P. We do not track the Web sites that you visit before or after you leave the 2C2P site.

Our Use of ‘Cookies’

‘Cookies’ are small files of data that we send to your computer to allow us to recognize you as a 2C2P customer if you return to the 2C2P site using the same computer and browser. We send a ‘session cookie’ to your computer if and when you log in to your 2C2P account by entering your e-mail address and Password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don’t need to re-enter your Password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

We also use longer-lasting cookies to display your e-mail address on our sign-in form, so that you don’t have to retype the e-mail address each time when you log in to your 2C2P account. In addition, we use cookies to process our referral program, described in Section C below. Our cookie files are encoded so that your e-mail address and other information can only be interpreted by 2C2P. We may, however, share cookie information regarding whether or not a certain user is already registered with 2C2P with certain merchants with whom we have an official co-marketing relationship.

Customer Service Correspondence

If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from 2C2P to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

Questionnaires, Surveys and Profile Data

From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users’ interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

Non-member Recipients and Requests

When a member either sends a payment to, or requests a payment from, an individual who is not a registered member of 2C2P, we will retain the information that the member submits to us, including, for example, the other party’s email address and/or name, for the benefit of the member who is attempting to contact the non-member, so that the member can see a complete record of his or her transactions, including uncompleted transactions. Although this information is stored indefinitely, we will not market to the non-member in any way at any time. Additionally, these non-members have the same rights to access and correct information about themselves (assuming that their email addresses were correct enough to reach them) as anyone else who uses 2C2P.

C. Our Use and Disclosure of Information

Internal Uses

We use the information we collect about you in order

1. to provide our services and process your transactions,
2. to provide customer service,
3. to determine your eligibility to receive offers for special features or products, and
4. to improve our products and services. At your option (as indicated in your 2C2P Profile settings), we use the information you provide to access specific third party services on your behalf and perform the actions that you request us to perform, such as invoicing winning bidders on behalf of auction sellers.

We give access to individually identifiable information about our users only to those employees who require it to fulfill customer service requests.

Disclosure to Other 2C2P Customers

If you are a registered 2C2P user, your name, e-mail address, date of sign-up, and whether you have verified control of a bank account are displayed to other 2C2P customers whom you have paid or who are attempting to pay you through 2C2P. If you use 2C2P for e-Commerce purpose, we will also display to other 2C2P customers the Web site address (URL) and customer service contact information that you provide us. However, your credit card number, bank account and other financial information will NEVER be revealed to anyone whom you have paid or who has paid you through 2C2P, except if we are required to do so pursuant to a subpoena or other legal process.

Disclosure to Third Parties Other Than 2C2P Customers

2C2P will not sell or rent any of your personally identifiable information to third parties. 2C2P will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission (and to other 2C2P customers as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.

* We share information with companies that help us process the transactions you request.
* We share information with companies that help us protect our customers’ transactions from fraud. See ‘Information About You From Third Parties’ in Section B above.
* We disclose the information we collect, as described in Section B above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. These companies are subject to confidentiality agreements with us and other legal restrictions that prohibit using the information except to market the specified 2C2P-related products or services, unless you have affirmatively agreed or given your prior permission for other uses.
* We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement. Specifically, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity’s contact information (but not bank account or credit card information) to victims who request it.
* We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
* We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
* We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in Bangkok. However, this aggregated information is not tied to personally identifiable information.
* As with any other business, it is possible that 2C2P in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by 2C2P, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section A above.

Our Contacts with 2C2P Customers

We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of a 2C2P account, to send you notice of payments that you send or receive through 2C2P (including referral payments described below), to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

Internet Address Information

We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

D. Information Security

2C2P is committed to handling your customer information with high standards of information security. Your credit card and bank account information are stored only in encrypted form on computers that are not connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes. For more information on 2C2P’s security practices, please visit the 2C2P Security Center.

The security of your 2C2P account also relies on your protection of your 2C2P Password. We strongly urge that you never share your 2C2P Password with anyone. 2C2P representatives will never ask you for your Password, so any e-mail or other communication requesting your Password should be treated as unauthorized and suspicious. If you do share your 2C2P Password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your Password. If you believe someone else has obtained access to your Password, please change it immediately by logging in to your account at https://www.2C2P.com/ and changing your Profile settings, and also contact us right away as described in Section F below.

E. Accessing and Changing Your Information

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your 2C2P account, at any time by logging in to your account on the 2C2P Web site and changing your preferences in the Profile page of the ‘My Account’ tab.

You can also close your account by contacting our customer service. If you close your 2C2P account, we will mark your account in our database as ‘Closed,’ but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.

F. Contacting Us

If you have any questions about this privacy statement, 2C2P’s information practices, or your dealings with 2C2P, you can contact us using this form, email us at privacy@2C2P.com , or email us from ‘Contact Us’ page.