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ecoPayz Privacy Policy

This document was last updated on May 23, 2018

This is the ecoPayz Privacy Policy applicable to ecoPayz Services, as defined below. PSI-Pay provides ecoPayz Services to both Users and Business Entities (as defined below), thus this Privacy Policy applies to both and should be read and interpreted accordingly.

This Privacy Policy applies to PSI-Pay Ltd.

Our Privacy Policy may be made available in several languages; all versions are legally binding, but in the event of inconsistency between English version and a translated version, English version prevails.

CONTENT


Please click the links below if You wish to go directly to a particular section of this Privacy Policy. The headings are for reference only and do not affect construction and interpretation.

  1. Definitions
  2. About PSI-Pay
  3. Privacy statement
  4. Collection of personal information
  5. The purpose and legal basis for processing personal information
  6. Personal information that We may process and groups of the personal information
  7. Disclosure of collected personal information
  8. Credit reference agencies
  9. Fraud prevention agencies
  10. Automated decision making
  11. Transfer of personal information to other countries
  12. Marketing
  13. Retaining collected personal information
  14. Your rights
  15. Your consent and how to withdraw it
  16. Children
  17. If You choose not to give personal information
  18. Use of "cookies"
  19. Third party websites
  20. Security
  21. Changes to this Privacy Policy
  22. Contacting Us and how to make a complaint

1. Definitions


"Business Entity" – a legal person, commercial or business entity that meets all the eligibility requirements set in the Terms of Use for the Business Entity Account and that opens and holds an ecoAccount and is enabled to use ecoPayz Services.

"customer" – means a User or Business Entity.

"ecoPayz" – Our (PSI-Pay) brand name.

"eMoney" – monetary value stored in electronic form issued by PSI-Pay under the relevant national laws of the United Kingdom and applicable regulations of the European Union and the Terms of Use.

"ecoPayz Services" – innovative payment services provided by PSI-Pay and based on eMoney issued by PSI-Pay upon demand and for the account of Users and Business Entities and including activities required for operations with an ecoAccount, identity verification and security checks, execution of Transactions, receipt of eMoney transfers, issuance and redemption of eMoney and other activities, as described in the Terms of Use.

"EEA" – the European Economic Area.

"Mobile Application" – an information technology solution available on Mobile Devices exclusively to Users for accessing and partly using ecoPayz Services. We may make this service available to Business Entities in the future.

"Mobile Device" – a portable computing device such as a smartphone or tablet computer.

"non-personal information" – information on which basis an individual is not distinguishable from other individuals, including anonymised personal information.

"personal information" – information that relates to an individual and on that basis makes the individual distinguishable from other individuals.

"process" or "processing" – means collecting, storing, using, disclosing or transferring of personal information and non-personal information.

"PSI-Pay", "We", "Us" or "Our" – PSI-Pay Ltd., a company incorporated under the laws of England and Wales and authorised by the Financial Conduct Authority of the United Kingdom to issue electronic money and to provide payment services as described in the Terms of Use.

"Privacy Policy" – this Privacy Policy concerning ecoPayz Services and Website, as may be amended from time to time.

"Terms of Use" – the Terms of Use for the User Account or the Terms of Use for the Business Entity Account, as may be amended from time to time.

"User" – an individual who meets all the eligibility requirements set in the Terms of Use for the User Account and that opens and holds an ecoAccount and is enabled to use ecoPayz Services.

"Website" – the website branded as ecoPayz and referring to domain https://www.ecopayz.com/. The term “Website” also includes reference to a Mobile Application in this Privacy Policy, when applicable.

"You", "Your" or "Yourself" – an individual who is applying, accessing or using ecoPayz Services either on his or her own account or on behalf of a Business Entity. This includes, an individual acting as a User or as a prospective User, or an individual acting on behalf of a Business Entity, including any principals (the managing and financial directors, other directors and officers, shareholders, partners and beneficial owners of the Business Entity), as well as any member of staff or an employee accessing or using ecoPayz Services on behalf of a Business Entity.

Other terms not provided in the preceding paragraphs are used in this Privacy Policy, too. Please check the Terms of Use for the meaning of capitalized terms that are not provided in this Privacy Policy.

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2. About PSI-Pay


2.1 Personal information is processed by Us – PSI-Pay Ltd., a company incorporated under the laws of England and Wales with registration number 05899168 and with registered office at Afon Building, Worthing Road, Horsham, West Sussex, RH12 1TL, United Kingdom.

PSI-Pay Ltd. is authorised by the Financial Conduct Authority (FCA) of the United Kingdom to issue electronic money and also to provide payment services. The registration number issued by the FCA to PSI-Pay is 900011.

2.2 We are the data controller responsible for Your personal information. Your personal information is processed by Us in line with applicable data and privacy laws and regulations and will be used only for the purposes and in the manner, and only will be disclosed to third parties, as set forth herein.

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3. Privacy statement


3.1 This Privacy Policy is to let You know how We promise to look after Your personal information and non-personal information. In particular, this Privacy Policy:

  • Contains information on the personal information We collect about You.
  • Describes how We process Your personal information and non-personal information.
  • Tells You about persons with whom Your personal information might be shared with.
  • Tells You about Your rights and how to exercise them.
  • Is intended to assist You in making informed decisions when applying, accessing or using ecoPayz Services and Our Website.

3.2 This Privacy Policy should be read together with the Terms of Use, if You use or wish to use ecoPayz Services. Please also read Our Cookie Policy to find out more about how We use cookies.

3.3 This Privacy Policy applies:

  • To features and services of the Website provided to You when You apply, access or use ecoPayz Services, including any of Our loyalty programmes.
  • At the moment when You apply to use and/or are accessing or using ecoPayz Services on Your own behalf (or on behalf of the Business Entity You represent).
  • To Your use of any software, including Our Website, used by You (or by the Business Entity You represent) to access or use ecoPayz Services.
  • To communications between You and Us by using email and other electronic messages, including SMS, telephone, Our Website, and other communications.

3.4 We recommend that You download or print a copy of this Privacy Policy and store it for Your records and future reference. Please contact Us, if You want a copy of this Privacy Policy.

3.5 Please contact Us if You have questions about Our privacy practices that are not addressed in this Privacy Policy.

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4. Collection of personal information


We may collect information about You (or the Business Entity You represent) from these sources:

4.1 Personal Information You give to Us:

  • When You (or the Business Entity You represent) apply for ecoPayz Services.
  • When You are accessing or using ecoPayz Services.
  • When You upload and/or store information with Us while using ecoPayz Services, for example on Your (or the Business Entity’s You represent) ecoAccount profile.
  • When You are accessing or using Our Website.
  • In communications between You and Us by using email and other electronic messages, including SMS, telephone, website/portal, and other communications.
  • In financial reviews and interviews.
  • In customer surveys.

4.2 Information We collect when You are accessing or using ecoPayz Services, including information regarding the amount, frequency, type, location, origin and recipients:

  • Transaction data of Your (or the Business Entity’s You represent) ecoAccount, including information about the recipients to whom You (or the Business Entity You represent) asked to execute a Transaction.
  • Data on eMoney transfers, including information about the person who is sending eMoney to Your (or the Business Entity’s You represent) ecoAccount.
  • Data on requests to purchase eMoney or redeem eMoney from or to Your (or the Business Entity’s You represent) ecoAccount.
  • Points or rewards earned or redeemed by You (or the Business Entity You represent) in any of Our loyalty programme.
  • Usage of Your (or the Business Entity’s You represent) ecoAccount profile on the Website. This includes the profile You create while using information and communication services to identify Yourself (or the Business Entity You represent) when You connect to ecoPayz Services online. It also includes other information about how You use those services. We gather this information from devices You use to connect to those services, such as computers and Mobile Devices, and by using cookies and other internet tracking software.

The extent of personal information required about recipients or persons who transfer eMoney to You (or the Business Entity You represent) may vary depending on the type of a Transaction, eMoney transfer, and other services You (or the Business Entity You represent) are using to send or request eMoney or needs of ecoPayz Services.

4.3 Information provided by third parties with whom We are working with:

  • Government authorities and regulators and law enforcement bodies worldwide.
  • Card authorisation and authentication service providers.
  • Credit reference agencies (Credit reference agencies).
  • Debt collection agencies.
  • Fraud prevention agencies (including Action Fraud, Financial Fraud Action and the Financial Fraud Bureau) and to government authorities, agencies or commissions or private parties.
  • Organisations that introduced You to Us.
  • Organisations with whom We have an agreement to corporate with, including banks, other electronic money issuers and payment service providers.
  • Our business partners, sub-contractors and other organisations providing services to Us and Our customers.
  • Business Entities.
  • Our agents and distributors.
  • Card associations.
  • Market researchers.
  • Financial and legal advisers.
  • Retailers.
  • Comparison websites.
  • Social networks.
  • Payroll service providers.
  • Public information sources.

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5. The purpose and legal basis for processing personal information


5.1 We are processing Your personal information on the basis of one or more of the following reasons:

  • To fulfil a contract We have with You (i.e. the Terms of Use).
  • When it is Our legal obligation to do so (processing of You personal information is necessary for Us to comply with the applicable law).
  • When it is in Our legitimate interests. This is when We have a business or commercial reason to use Your personal information and non-personal information. However, when We process Your personal information for Our legitimate interest, it must not unfairly go against what is right for You or is in Your interests.
  • Where You consent to it.

5.2 We use Your personal information and non-personal information in the ways and for the reasons listed below. Where We process Your personal information to achieve Our legitimate interests, We have provided an explanation about them. If You give Us personal information and non-personal information, including sensitive personal information, about Yourself or other individuals, You agree (and confirm that such other individual has agreed) that We can process the said information in the way set out in this Privacy Policy.

What We use Your personal information for Our reasons Our legitimate interests
To provide ecoPayz Services and to manage Our business needs:
  • To manage Our relationship with You (or with the Business Entity You represent) and Our customers.
  • To provide advice or guidance about ecoPayz Services.
  • To collect and recover funds that are owed to Us.
  • To respond to complaints and seek solutions for them.
  • To communicate with You and to tell You about changes to ecoPayz Services.
  • To manage how We work with Our business partners and other organisations providing services to Us and Our customers.
  • To exercise Our rights and obligations set out in the Terms of Use and other contracts concluded between Us and You (or the Business Entity You represent).
  • To run Our business in an efficient and proper way. This includes managing Our financial situation, corporate governance, and audit.
  • Fulfilling contract.
  • Our legitimate interests.
  • Our legal duty.
  • Being efficient about how We fulfil Our legal and contractual duties.
  • Keeping Our records up to date.
  • Complying with applicable laws.
  • Managing Our everyday business needs.
To manage Our relationship with You (or the Business Entity You represent):
  • To provide ecoPayz Services to You (or to the Business Entity You represent) and Our customers.
  • To process or execute Transactions, eMoney transfers sent to You (or to the Business Entity You represent), to process Your (or the Business Entity’s You represent) request to purchase eMoney or redeem eMoney from Your (or the Business Entity’s You represent) ecoAccount.
  • To manage Fees, charges and currency exchange rates due on Our customer accounts.
  • To facilitate the collection or redemption of any points or other rewards in respect of any of Our loyalty programme.
  • Fulfilling contract.
  • Our legitimate interests.
  • Our legal duty.
  • Being efficient about how We fulfil Our legal and contractual duties.
  • Keeping Our records up to date.
  • Complying with applicable laws.
To manage risks and protect ecoPayz Services:
  • To authenticate Your (or the Business Entity’s Your represent) access to ecoAccount.
  • To keep ecoPayz Services safe and secure.
  • To carry out Our identity and security validation and verification checks.
  • To detect, investigate, report and prevent financial crime, fraud and money-laundering.
  • To detect and prevent abuse of ecoPayz Services.
  • To manage risk for Us, Our customers and Our business.
  • To obey any applicable law requirements.
  • Fulfilling contract.
  • Our legitimate interests.
  • Our legal duty.
  • Developing and improving how We deal with financial crime, fraud and money-laundering, as well as doing Our legal duties in this respect.
  • Complying with applicable laws.
  • Being efficient about how We fulfil Our legal and contractual duties.
  • Managing Our everyday business needs.
To administer ecoPayz Services and Our Website:
  • To allow Our customers to participate in interactive features of ecoPayz Services and the Website.
  • To administer ecoPayz Services and ecoAccounts.
  • To administer the Website and to improve its performance.
  • To analyse Our customer behaviour and preferences, to analyse trends and to manage the load on Our servers.
  • Fulfilling contract.
  • Our legitimate interests.
  • Our legal duty.
  • Being efficient about how We fulfil Our legal and contractual duties.
  • Developing new products and services.
  • Managing Our everyday business needs.
To render, develop and improve Our business:
  • To develop, manage and enhance Our brand and ecoPayz Services, and the Website.
  • To develop new ways to meet Our customers’ needs and to grow Our business.
  • To test new products and services.
  • To conduct market analysis and strategic planning.
  • To study how Our customers use ecoPayz Services and other services similar to or connected with ecoPayz Services.
  • To measure and understand the effectiveness of advertising of ecoPayz Services.
  • Fulfilling contract.
  • Our legitimate interests.
  • Our legal duty.
  • Developing new products and services, and what We charge for them.
  • Defining types of customers for new products or services.
  • Being efficient about how We fulfil Our legal and contractual duties.
  • Keeping Our records up to date.
  • Assessing which of Our products or services may interest Our customers.
  • Managing Our everyday business needs.
Marketing:
  • To develop and carry out marketing activities.
  • To establish Our customer eligibility to receive special features, promotions, products and services.
  • To deliver relevant advertising to Our customers.
  • Your consent.
  • Fulfilling contract.
  • Our legitimate interests.
  • Our legal duty.
  • Keeping Our records up to date.
  • Assessing which of Our products or services may interest Our customers and telling about them.
  • Seeking Your consent when We intend to inform You about special features, promotions, products and services.

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6. Personal information that We may process and groups of the personal information


6.1 We may process different kinds of personal information, including personal information, non-personal information and financial information You (or the Business Entity You represent) provide to Us. We gather personal information in the following groups:

Group Description Type of personal information that could be included within the group
Financial data Our customers’ financial position, status and history.
  • Financial information.
  • Payment instrument details (credit/debit card details, card number, card expiry date, CVC details, bank and/or card issuer details, bank account details).
  • Information that We receive from Our business partners, sub-contractors and other organisations providing services to You (or the Business Entity You represent), for example, financial data and data received from credit reference and fraud prevention agencies.
Contact Our customers’ contact information.
  • First name/last name.
  • Date of birth.
  • Nationality.
  • Country of residence.
  • E-mail address.
  • Address (residence, postal address), including copies of proof of address.
  • Phone number (landline/mobile phone number.
  • Photograph.
Transaction data Details about Transactions, eMoney transfers sent to Our customers, information on Our customer requests to purchase eMoney or redeem eMoney from their ecoAccounts.
  • Type, amount and time of a Transaction, eMoney transfer, purchase of eMoney or redemption of eMoney.
  • Transaction details (geographical location, IP address and country, recipient’s e-mail address, phone number).
  • Additional commercial information and identification information.
  • Fingerprint of the device used to access ecoAccount.
  • Any other information You provide.
Contractual Details about You and ecoPayz Services provided.
  • First name/last name.
  • Date of birth.
  • Nationality.
  • Country of residence.
  • E-mail address.
  • Address (residence, postal address), including copies of proof of address.
  • Phone number (landline/mobile phone number.
  • Payment instrument details (credit/debit card details, card number, card expiry date, CVC details, bank issuer details, bank account details).
  • Information about login details (login user name, password, authentication data (if a two-step verification system (strong customer authentication) is used) and other security credentials (i.e. secure identification, security questions and answers)).
Locational Information We get about where You, such as may come from the device You use to access Your (or the Business Entity’s You represent) ecoAccount, including the address from which You connect the said device to the Internet.
  • Geographic location, including access real-time location based information.
  • IP address and country.
  • Fingerprint of the device used to access ecoAccount.
Behavioural and Technical (collected by cookies. Please see Our Cookie Policy) Details about how You (or the Business Entity You represent) use ecoPayz Services and the Website and details on the devices and technology You (or the Business Entity You represent) use.
  • IP address and country.
  • Information about login details (login user name, password, authentication data (if a two-step verification system (strong customer authentication) is used) and other security credentials (i.e. secure identification, security questions and answers)).
  • Access time of the Website.
  • Website response times.
  • Length of visits of certain pages of the Website.
  • The internet browser type, version, time zone setting, plug in types and versions, operating system and platform.
  • Full Uniform Resource (URL) clickstream.
  • Fingerprint of the device used to access ecoAccount.
Communications Information that We learn from You (or from the Business Entity You represent) letters, emails, and conversations, either textual or oral, with Us.
  • Your comments and opinions disclosed in Your communications, for example, content of a complaint or question submitted to Us.
Social Relationships Information about Your family members, friends and other relationships.
  • First name/last name.
  • Date of birth.
  • Nationality.
  • Country of residence.
  • E-mail address.
Open data and Public Records Details about You that are in public records and information about You openly available on the Internet.
  • Your comments and opinions made on social network sites (i.e. Facebook or Twitter) about Us, ecoPayz Services, other services similar to or connected with ecoPayz Services, and other products and services that are or may be provided by Us.
  • Public records.
Usage data Other information about Your (or the Business Entity’s You represent) use of ecoPayz Services, other services similar to or connected with ecoPayz Services, and other products and services that are or may be provided by Us.
  • Information that We receive from Our business partners, sub-contractors and other organisations providing services to You (or the Business Entity You represent), for example, financial data and data received from credit reference and fraud prevention agencies.
Documentary data Details about You that are stored in documents in different formats, or copies of them.
  • Government issued photo identification.
  • Details of passport/ identity card/ drivers licence or birth certificate.
Special types of data Applicable laws treat some types of personal information as special. We will only collect and use these types of information if it is permitted under the applicable laws. This includes information on Your:
  • Trade union membership.
  • Health data, including gender.
  • Criminal convictions and offences.
Consents Any permissions, consents or preferences that You give Us.
  • Consent to receive offers for special features, promotions, products and services from Us.
  • Consent to collect real-time location based information.
National identifier A number or code given to You by a government to identify who You are.
  • Social security number/tax code.
  • Details of passport/ identity card/ drivers licence or birth certificate.

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7. Disclosure of collected personal information


7.1 We may share Your personal information and non-personal information in a variety of ways with the following third parties:

  • Our affiliates, Our and their directors, employees, professional advisors, advisers, subsidiaries, agents, subcontractors, and service providers that We use to ensure rendering of ecoPayz Services, performance of Our obligations arising out of the Terms of Use, to manage risks, to help detect and to prevent financial crime, fraud and money-laundering, to help us to manage availability and connectivity of the Website and ecoPayz Services, to collect funds what You (or the Business Entity You represent) owe to Us, to help Us to conduct marketing of ecoPayz Services and other services similar to or connected with ecoPayz Services and to explore new ways of doing business.
  • Government authorities and regulators and law enforcement bodies worldwide.
  • Card authorisation and authentication service providers.
  • Credit reference agencies (Credit reference agencies).
  • Debt collection agencies.
  • Fraud prevention agencies (including Action Fraud, Financial Fraud Action and the Financial Fraud Bureau) and to government authorities, agencies or commissions or private parties.
  • Organisations that introduced You to Us.
  • Organisations that We introduced to You
  • Organisations with whom We have agreement to corporate with, including banks, other electronic money issuers and payment service providers, account information service providers and payment initiation service providers.
  • Our business partners, sub-contractors and other organisations providing services to Us and Our customers.
  • Persons to whom You ask to share Your personal information with, this includes Business Entities and/or Users to whom You (or the Business Entity You represent) have asked to execute a Transaction or from which You (or the Business Entity You represent) receive a transfer of eMoney.
  • Our agents and distributors.
  • Card associations.
  • Market researchers.
  • Financial and legal advisers.
  • Your (or the Business Entity’s You represent) agent or legal representative (such as the holder of a power of attorney that You grant, or a guardian appointed for You) and any other party linked with You (or the Business Entity You represent).
  • Price comparison websites and similar organisations that offer ways to research and apply for financial products and services.
  • Service providers that manage Our marketing or development programs.
  • Retailers.
  • Comparison websites.
  • Social networks.
  • Payroll service providers.
  • Public information sources.

7.2 We may also need to share Your personal information with other third parties to provide You (or the Business Entity You represent) with ecoPayz Services based on Your (or on the Business Entity’s You represent) interests:

  • If You (or the Business Entity You represent) have applied for and are issued with an ecoCard Payment Card, We will share transaction details with organisations which help Us to provide this service (for example Mastercard).
  • If You (or the Business Entity You represent) have a loyalty scheme, We will share Your personal information with that scheme.
  • If You (or the Business Entity You represent) use direct debits, We will share Your personal information with the Direct Debit scheme.
  • If You (or the Business Entity You represent) apply for insurance though Us, We may pass Your (or the Business Entity’s You represent) details to the insurer, and to any reinsurers.

7.3 We may go through structural changes in future, in particular, if We sell, transfer or merge part or all of Our business or assets or any associated rights or interests, or if We acquire a business, or enter into a merger, We may disclose Your personal information to the prospective buyer, transferee, merger partner and/or their advisers. If the transaction goes ahead, the buyer, transferee or merge partner may use or disclose Your personal information in the same way as set in this Privacy Policy.

7.4 In addition, We may provide aggregated statistical data to third-parties, including other organisations or members of the public, about how, when, and why You (or the Business Entity You represent) visit Our Website and use ecoPayz Services. This data is non-personal information and will not identify You or provide information on how You (or the Business Entity You represent) individually use the Website or ecoPayz Services.

7.5 Where a third party process Your personal information on Our behalf, it is subject to strict security and confidentiality obligations consistent with this Privacy Policy and applicable laws. We will take all steps reasonably necessary to ensure that Your personal information is treated by the third party to which We disclose it securely and is processed in accordance with this Privacy Policy.

7.6 Your personal information may be disclosed only for the purposes of providing services by a third party to Us or in connection with ecoPayz Services or Your visits of the Website. Third parties to which We disclose Your personal information are governed by a contract and applicable laws and may not use Your personal information for secondary purposes. Processing of personal information by a third party on its own behalf is subject to its privacy policy and applicable laws.

7.7 We will not sell or rent any of Your personal information to third parties. We do not share Your personal information with third parties for their marketing purposes without Your consent.

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8. Credit reference agencies


8.1 When You (or the Business Entity You represent) are applying for ecoPayz Services and open an ecoAccount with Us, We are performing Our identity and security validation and verification checks. We may use credit reference agencies to help Us with this. We may also use credit reference agencies on a periodic basis while providing ecoPayz Services to You (or to the Business Entity You represent) to verify information provided to Us.

8.2 The following information may be exchanged between Us and credit reference agencies:

  • Name, last name, address and date of birth.
  • Financial situation (including, credit scoring) and history.
  • Public information, from sources such as the Companies House.

8.3 Information received from credit reference agencies are used by Us to:

  • Assess whether You (or the Business Entity You represent) are eligible to use ecoPayz Services.
  • Make sure what You (or the Business Entity You represent) have told Us is true and correct information.
  • Help Us detect and to prevent financial crime, fraud and money-laundering.
  • To render ecoPayz Services to You (or to the Business Entity You represent) and to manage Your (or the Business Entity’s You represent) ecoAccount and ecoAccount profile.
  • Trace and recover debts and funds that are owed to Us.

8.4 We may cooperate and share Your personal information with credit reference agencies as long as You (or the Business Entity You represent) remain Our customer. Information shared by Us may include information on Transactions, receipt of eMoney transfers, issuance and redemption of eMoney, ecoAccount’s balance and other activities conducted by using Your (or the Business Entity’s You represent) ecoAccount, including, information on funds not fully repaid to Us on time. Credit reference agencies may link together information provided by Us with the information that it has on You (or on the Business Entity You represent). Credit reference agencies may share this information on You with other organisations.

8.5 Credit reference agencies may keep personal information for up to 6 (six) years.

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9. Fraud prevention agencies


9.1 When You (or the Business Entity You represent) are applying for ecoPayz Services and open an ecoAccount with Us, We are performing Our identity and security validation and verification checks. We may use fraud prevention agencies to help Us with this. We may also cooperate with and disclose Your personal information to fraud prevention agencies on a periodic basis while providing ecoPayz Services to You (or to the Business Entity You represent) to help detect financial crime, fraud and money-laundering risks. This may include recording sensitive personal information such as criminal offences You have been accused of.

9.2 We use fraud prevention agencies to help Us to obey applicable laws or for Our legitimate interests. Information received from fraud prevention agencies are used by Us to:

  • Carry out Our identity and security validation and verification checks.
  • Help identify, monitor and prevent financial crime, fraud and money-laundering.
  • Exercise Our rights and obligations set out in the Terms of Use and other contracts concluded between Us and You (or the Business Entity You represent).

9.3 Fraud prevention agencies may keep Your personal information for different lengths of time, if they found risk of financial crime, fraud or money-laundering.

9.4 Fraud prevention agencies may disclose and allow access to government authorities and regulators, for example, law enforcement bodies, to Your personal information worldwide. This is to support their duty to detect, investigate, prevent and prosecute financial crime, fraud and money-laundering.

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10. Automated decision making


10.1 We sometimes use systems to make automated decisions based on personal information We have or We are allowed to collect from others about You. This helps Us to make sure Our decisions are quick, fair, efficient and correct based on what We know. These automated decisions can affect Our provision of ecoPayz Services and other services similar to or connected with ecoPayz Services to You (or to the Business Entity You represent) now and in future, or fees We charge from You (or from the Business Entity You represent).

10.2 We are making the following automated decisions:

  • Opening an ecoAccount. When You (or the Business Entity You represent) are applying for ecoPayz Services and open an ecoAccount with Us, We are performing Our identity and security validation and verification checks based on what We know and based on the personal information You (or the Business Entity You represent) provide to Us. This may include checking of age, residence, nationality, financial position. We are doing this to make sure You (or the Business Entity You represent) have told Us true and correct information, to confirm Your identity and to detect and prevent financial crime, fraud and money-laundering risks.
  • Detecting fraud. We use Your personal information to detect if Your (or the Business Entity’s You represent) ecoAccount is perhaps used for financial crime, fraud or money-laundering or being used or is used in the manner that potentially abuses ecoPayz Services or violates the Terms of Use. We may detect that an ecoAccount is used in a way that is unusual for Your (or to the Business Entity You represent). We may at Our discretion suspend or otherwise restrict the functionality of Your (or the Business Entity’s Your represent) ecoAccount at any time, if We suspect unauthorised or fraudulent use of Your (or the Business Entity’s You represent) ecoAccount or that it has been accessed without Your (or the Business Entity’s You represent) authorization.
  • Fees. We may decide what fees should be determined for some services on the basis of what We know.
  • Tailoring ecoPayz Services and other services similar to or connected with ecoPayz Services. We may place You (or the Business Entity You represent) in groups with similar customers. These are called customer segments. We use these to study and learn about Our customers’ needs and to make decisions based on what We learn. This helps Us to design ecoPayz Services and other services similar to or connected with ecoPayz Services for different customer segments, and to manage Our relationships with them.

10.3 As an individual You have rights over automated decisions. You have the right:

  • To ask Us not to make our decisions based on the automated means alone.
  • To object an automated decision and ask that an individual reviews it.

10.4 Please contact Us, to exercise Your rights mentioned in the preceding paragraph.

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11. Transfer of personal information to other countries


11.1 In order to deliver ecoPayz Services, Your personal information may be transferred to and stored at a destination outside the EEA. We will only send Your personal information outside the EEA to:

  • Follow Your (or the Business Entity’s You represent) instructions.
  • Fulfil Our legal duties.
  • Work with Our affiliates, subsidiaries, agents, subcontractors, and service providers who We use to help Us to render ecoPayz Services and to ensure performance of Our obligations under the Terms of Use.

11.2 If We do transfer Your personal information to Our affiliates, subsidiaries, agents, subcontractors, and service providers outside the EEA, We will make sure that it is protected in the same way as if it was used in the EEA. We will take all steps reasonably necessary to ensure that Your personal information is treated securely and is processed in accordance with this Privacy Policy. If We transfer Your personal information outside the EEA, We will make sure that one of the following safeguards is put in place:

  • Transfer of personal information to a non-EEA country with privacy laws that give the same protection as the EEA.
  • A contract with the recipient according to which the recipient is obliged to protect personal information to the same standards as required in the EEA.
  • Transfer of personal information to organisations that are part of Privacy Shield (a framework that sets privacy standards for information sent between the US and EU countries).

11.3 By submitting personal information to Us, You agree to such transfer, storing and processing as stated in preceding paragraphs.

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12. Marketing


12.1 We may use Your personal information for marketing purposes, so that We can tell You about offers for special features, promotions, products and services We feel may interest You. This is what We mean when We talk about ‘marketing’.

12.2 For marketing purposes We use the personal information We have on You based on what You tell Us and information We collect when You apply, access or use ecoPayz Services and Our Website, or from third parties We work with.

12.3 We study Your personal information to gain a view on what may interest You (or the Business Entity You represent), or what You (or the Business Entity You represent) may want or need. This is how We decide which special features, promotions, products or services may be relevant for You (or for the Business Entity You represent).

12.4 We can only use Your personal information for marketing purposes, if We have either Your consent or a ‘legitimate interest’. This is when We have a business or commercial reason to use Your personal information and non-personal information. However, when We process Your personal information for Our legitimate interest, it must not unfairly go against what is right for You or is in Your interests.

12.5 For marketing purposes, We will contact You by post, e-mail, telephone, text message and/or recorded calls depending on Your choice, unless You have asked Us not to. You can either:

  • Change Your preferences at any time by accessing Your (or the Business Entity’s You represent) ecoAccount profile, choosing ‘Personal Settings’ from the menu, selecting ‘Account Option’, de-selecting the tick box regarding advertising by post, e-mail, telephone, text message and/or recorded calls, and clicking ‘Update’.
  • Ask Us to stop contacting You for marketing purposes by post, e-mail, telephone, text message and/or recorded calls depending on Your choice by contacting Us at any time.

12.6 If You change Your mind You can update Your choices at any time by contacting Us.

12.7 We may ask You to confirm or update Your choices, if You apply for a use or use any new product or service with Us in future. We will also ask You to do this, if there are changes in applicable laws or the structure of Our business.

12.8 Even if You asked Us not to contact You for marketing purposes, You (or the Business Entity You represent) will still receive statements and other important information regarding ecoPayz Services, such as changes to ecoPayz Services and information on Transactions or eMoney Transfers.

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13. Retaining collected personal information


13.1 We will retain Your personal information as long as You (or the Business Entity You represent) are Our customer and for at the least for the period necessary for Us to comply with Our legal obligations and for Our business purposes.

13.2 Closing Your (or the Business Entity’s You represent) ecoAccount does not mean that We delete personal information that We hold on You. We will continue to keep Your personal information for at least 5 (five) years or longer for one of these reasons:

  • For fraud and/or security purposes.
  • To respond to any question or complaint.
  • To show that We treated You fairly.
  • To maintain records required by the applicable law.
  • For Our legitimate interests.
  • To comply with the applicable law.

13.3 We also may keep Your personal information for longer than 5 (five) years for research or statistical purposes. If We do so, We will make sure that Your privacy is protected and that Your personal information is only used for those purposes.

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14. Your rights


14.1 You have certain rights that may be exercised regarding Our processing of Your personal information. To exercise Your rights mentioned below, please contact Us.

14.2 Accessing Your personal information. You may have the right to access personal information We hold about You and to require Us to provide certain information regarding Our processing of Your personal information. We may request to prove Your identity before We disclose any information to You. We may charge a fee for providing or making this information available. This is known as the ‘right of access’.

14.3 Letting Us know if Your personal information is incorrect. You have the right to question any information We have about You that You think is wrong or incomplete. If You do, We will take reasonable steps to check its accuracy and correct it. This is known as the ‘right to rectification’.

14.4 Requiring Us not to process Your personal information. You have the right to ask Us to delete, remove or stop using Your personal information, if there is no need for Us to keep it. Even if You object to Our use of Your personal information, We may still process it due to legal or other official reasons, such as legal claims, or to exercise Our legal rights. However, please tell Us if You think that We should not be using it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’.

14.5 Restricting Our processing of Your personal information. You have the right to restrict processing of Your personal information. In this situation We would not use or share Your personal information while it is restricted, except if We need to use it for certain things, such as legal claims or exercising Our legal rights. This is known as the ‘right to restriction of processing’.

You can ask Us to restrict use of Your personal information if:

  • It is not accurate.
  • It has been used unlawfully, however You do not want Us to delete it.
  • It is not relevant any more, however You want Us to keep it for use in case of legal claims.
  • You already asked Us to stop using Your personal information, but You are waiting for Us to tell You if We are allowed to continue using it.

14.6 Receiving Your personal information. From May 25, 2018 You have the right to receive Your personal information that We process by automated means on the basis of Your consent or on the basis of the Terms of Use or other contracts concluded between Us and You (or the Business Entity You represent). In this situation We will provide Your personal information to You in a format that can be easily re-used. You can also ask Us to pass on Your personal information in this format to other organisations, and, if technically feasible, We will do so. This is known as the ‘right to data portability’.

14.7 Objecting Our processing of Your personal information. You have the right to object Our processing of Your personal information. Even if You object to Our processing of Your personal information, We may still process it due to legal or other official reasons, such as legal claims or exercising Our legal rights. However, please tell Us if You think that We should not be processing it. This is known as the ‘right to object’.

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15. Your consent and how to withdraw it


15.1 You can withdraw Your consent at any time free of charge. Please contact Us, if You want to do so.

15.2 If You withdraw Your consent, We may be unable to provide ecoPayz Services and other services similar to or connected with ecoPayz Services to You (or to the Business Entity You represent) fully or partly. If so, We will tell You (or to the Business Entity You represent).

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16. Children


16.1 ecoPayz Services are not rendered to and Our website are not directed to children under the age of majority in their country of residence. We do not knowingly collect information, including personal information, from children or other individuals who are not legally able to use ecoPayz Services or Our Website. If We obtain actual knowledge that We have collected personal information from a child under the age of majority in their country of residence, We will promptly delete it, unless We are legally obligated to retain such information. Please contact Us, if You believe that We have mistakenly or unintentionally collected information from a child under the age of majority in their country of residence.

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17. If You choose not to give personal information


17.1 We may need to collect personal information by applicable laws or under the Terms of Use or other contracts concluded between You and Us (or the Business Entity You represent).

17.2 If You choose not to give Us Your personal information, it may delay or prevent Us from meeting Our obligations. Also, We may be unable or prohibited to render ecoPayz Services to You (or the Business Entity You represent). Further, We may cancel provision of ecoPayz Services to You (or the Business Entity You represent).

17.3 If collection of any information is optional, it will be made clear before its collection.

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18. Use of "cookies"


18.1 We use cookies to distinguish You from other customers that use ecoPayz Services or from individuals visiting the Website. To find out more about how We use cookies please see Our Cookie Policy.

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19. Third party websites


19.1 This Privacy Policy applies to Your personal information when You (or the Business Entity You represent) apply for, access or use ecoPayz Services, and does not apply to third party websites or services that We do not own or control, including websites of Our customers. We are not responsible for the operations of Our customers or third parties, including, but not limited to, their practices on processing of personal or non-personal information. If You give information to or through a third party’s website, please note that these third parties have their own privacy policies and You should review them before giving Your personal information to or through such third party’s website.

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20. Security


20.1 We are committed to ensuring protection of information that You give Us by using state-of-the art security technology. We use leading technologies such as, but not limited to, encryption by using the highest grade cryptographically strong cyphers before storing personal information in the database, along with firewall and network security technology to protect Our computer systems from unauthorized access. We test Our security systems regularly and also contract with outside companies to audit and test Our security systems and processes.

20.2 Our employees and third parties that provide support services to Us are required to observe Our privacy standards. We restrict access to Your personal information to employees who need that information in order to provide access to the Website, to render ecoPayz Services or to perform Our obligations or to exercise Our rights under the Terms of Use.

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21. Changes to this Privacy Policy


21.1 This Privacy Policy may change. You are responsible for ensuring You periodically visit Our Website and this Privacy Policy to check for any changes. If You (or the Business Entity You represent) have an ecoAccount, We will notify You (or the Business Entity You represent) before any material change to this Privacy Policy is due to take effect. We will do so by posting a notice of the changes on the Website and by sending a notification e-mail to Your e-mail address.

21.2 Any changes to this Privacy Policy will be effective from the date indicated in the notice posted on the Website and notified to You by e-mail (if You (or the Business Entity You represent) have an ecoAccount). If We give You (or the Business Entity You represent) notice and You (or the Business Entity You represent) do not tell Us that You (or the Business Entity You represent) wish to end the Terms of Use and to close an ecoAccount, then Your (or the Business Entity You represent) continued use of ecoPayz Services will constitute acceptance of the changes to this Privacy Policy and We will treat You (or the Business Entity You represent) as having accepted the changes.

21.3 However, should You wish not to be bound by any changes of this Privacy Policy, You must notify Us that You do not agree to the changes before those changes enter into force. In that event, We will treat Your notice as a notification that You immediately wish to terminate use of ecoPayz Services and to close Your ecoAccount and the Terms of Use will be terminated immediately.

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22. Contacting Us and how to make a complaint


22.1 Please contact Our Customer Support Service, if You:

  • Have any questions in relation to Your personal information or Your rights under applicable laws.
  • Want to exercise Your rights regarding Your personal information that We hold.
  • Wish to make a complaint.

22.2 You can contact the Customer Support Service:

22.3 The Customer Support Service is available 24/7 (namely, twenty-four hours every day) for any questions You may have.

22.4 You also have the right to complain to the Information Commissioner’s Office of the United Kingdom. Find out on their website how to report a concern. Please see: https://ico.org.uk/concerns/.

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