PAYDOO PRIVACY POLICY

Effective Date: 22 May 2018

We at Paydoo Payments UAB, Paydoo SIA and Paydoo Limited (collectively, “Paydoo,” “we” and “us”) know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about how we collect, store, use and disclose information about you when you interact or use our websites (collectively the “Websites”) or any related events, trade shows, sales or marketing, and/or if you use any of our products, services or applications (including any trial) (collectively the “Services”) in any manner.

1. What does this Privacy Policy cover?

This Privacy Policy covers our treatment of information that we gather when you are accessing or using our Websites or Services or when you contact us in any manner. We gather various types of information, including information that identifies you as an individual (“Personal Information”) from our users, as explained in more detail below.

2. What information does Paydoo Collect?

Information You Provide to Us:

When you use the Websites: We may collect any Personal Information that you choose to send to us or provide to us, for example, on our “Sign Up” (or similar) online form or if you register for a Paydoo webinar. If you contact us through the Websites, we will keep a record of our correspondence.

When you use the Services: We receive and store information you provide directly to us. For example, when setting up new users, we collect Personal Information, such as name and e-mail address, to provide them with Services. The types of information we may collect directly from our customers and their users include: names, usernames, email addresses, postal addresses, phone numbers, job titles, transactional information (including Services purchased), as well as any other contact or other information they choose to provide us or upload to our systems in connection with the Services.

Information We Automatically Collect:

When you use the Websites: When you visit the Websites, we collect certain information related to your device, such as your device’s IP address, referring website, what pages your device visited, and the time that your device visited our Website.

When you use the Services: Usage information – we keep track of user activity in relation to the types of Services our customers and their users use, the configuration of their computers, and performance metrics related to their use of the Services.  Log information – we log information about our customers and their users when you use one of the Services including Internet Protocol (“IP”) address. Information collected by cookies and other similar technologies – we use various technologies to collect information, which may include saving cookies to users’ computers.

For further information, please see the section below headed “Cookies and other Tracking Technologies”.

3. How do we use the information?

Websites:

We will use the information we collect via our Websites:

  • To administer our Website, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
  • To improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
  • Analyze customers’ use of the Websites for trend monitoring, marketing and advertising purposes;
  • For purposes made clear to you at the time you submit your information – for example, to fulfill your request for a demo, to provide you with access to one of our webinar’s or whitepaper’s or to provide you with information you have requested about our Services; and
  • As part of our efforts to keep our Website safe and secure.

Services:

We may use the information we collect from our customers and their users in connection with the Services we provide for a range of reasons, including to:

  • To set up a user account,
  • Provide, operate and maintain the Services;
  • Process and complete transactions, and send related information, including transaction confirmations and invoices;
  • Manage our customers’ use of the Services, respond to enquiries and comments and provide customer service and support;
  • Send customers technical alerts, updates, security notifications, and administrative communications;
  • Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities; and
  • For any other purposes about which we notify customers and users.

We may also use the information you send to us via the Websites and/or Services, to communicate with you via email and, possibly, other means, regarding products, services, offers, promotions and events we think may be of interest to you or to send you our newsletter, if this is in accordance with your marketing preferences.  However, you will always be able to opt-out of such communications at any time (see the “Your Choices” section below).

How do we share and disclose information to third parties?

We do not rent or sell your Personal Information to anyone. We may share and disclose information (including Personal Information) about our customers in the following limited circumstances:

Vendors, consultants and other service providers: We may share your information with third party vendors, consultants and other service providers who we employ to perform tasks on your behalf. These companies include (for example) our gateway, security and fraud management providers (e.g. ACI Worldwide, Kount, Webshield Ltd., GBG Plc.), website analytics companies (e.g., Google Analytics), product feedback or help desk software providers (e.g. ZenDesk), CRM service providers (e.g., Salesforce), email service providers (e.g., Mailchimp) and others.

Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Protection of Paydoo and Others: We reserve the right to access, read, preserve, and disclose any information as necessary to comply with law or court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, or safety of Paydoo, our employees, our users, or others.

Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

4. Is Personal Information about me secure?

We use appropriate technical, organizational and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction.  Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

5. Cookies and other tracking technologies

Our Websites and some of our Services use cookies (small text files containing a string of alphanumeric characters that we put on your computer) and other similar tracking technologies (like web beacons, tags and scripts) to uniquely identify your browser and to gather information about how you interact with the Websites and Services. We use this information for the following purposes:

  • Assisting you in navigation;
  • Assisting in registration, login, and your ability to provide feedback;
  • Analyzing your use of our products, services or applications; and
  • Assisting with our promotional and marketing efforts (including behavioral advertising).

Please consult our Cookie Policy for more information about the type of cookies and tracking technologies that we use on this Website and why, and how to accept and reject them.

We also may use clear gifs in HTML-based emails sent to our users to track which emails are opened by recipients. This information is used to enable more accurate reporting, improve the effectiveness of our marketing, and make our Services and Websites better for our users.

We also utilize Google Analytics, a web analysis service provided by Google, to better understand your use of our Websites and Services. Google Analytics collects information such as how often users visit the Websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Websites to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google offers an opt-out mechanism for the web available here.

6. Your Privacy Rights

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

7. Marketing Communications

You can opt-out of receiving certain promotional or marketing communications from us at any time, by using the unsubscribe link in the emails communications we send, fill out this Contact form, or email to [email protected] directly.

If you have any account for our Services, we will still send you non-promotional communications, like service related emails.

How can I update and access my information (Exercise my Data Subject Rights)?

If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), you can either fill out this Contact form, or email to [email protected] directly.

Our Privacy team will examine your request and respond to you as quickly as possible!

Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual, and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Storage Security & International Transfers

The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (EEA). As we provide an international service your data may be processed outside of the EEA in order for us to fulfill our contract with you to provide the Paydoo Services. We will need to process your personal data in order for us, for example, to action a request made by you to execute an international payment, process your payment details, provide global anti-money laundering and counter terrorist financing solutions and provide ongoing support services. We will take all steps to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or a secure virtual private network. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

9. Retaining Your Information

Paydoo is obligated under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) to retain personal data about you and your Paydoo Transactions for a period of five years.

10. Your Legal Rights

You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team via email to [email protected]

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team via email to [email protected]

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request. As an EMI authorised firm, Paydoo is under certain obligations to retain certain data for a minimum of 5 years (see above). Please note that these retention requirements supersede any right to erasure requests under applicable data protection laws.

Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. As an EMI authorised institution, Paydoo is under certain obligations to process and retain certain data for compliance purposes. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide the Paydoo Services and it is likely we will have to terminate your account.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the Paydoo Services). In this case, we may have to cancel your use of the Paydoo Services but we will notify you if this is the case at the time.

Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support via email to [email protected]

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

11. No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

12. What We May Need From You

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

13. Time Limit To Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14. If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Paydoo Services). In this case, we may have to cancel your use of the Paydoo Services but we will notify you if this is the case at the time.

15. Changes To Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail and/or when you log onto the Site. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

16. Contact

All questions relating to data and your privacy are welcomed and should be addressed to our support team. If you have any questions, comments or requests regarding this privacy policy then please contact Paydoo support via email to [email protected]