PSI-Pay Privacy Policy

This document was last updated on January 13, 2018.

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. About PSI-Pay
  2. Introduction
  3. Personal information
  4. Your consent
  5. Collection of information
  6. Use of "cookies"
  7. Questionnaires and surveys
  8. Use of collected information
  9. Retaining collected information
  10. Disclosure of collected information
  11. Transfer of personal information to other countries
  12. Your rights to access or limit use of personal information
  13. Your use of information obtained from the Website
  14. Using Your personal information to contact You about products and services
  15. Third party websites
  16. Security
  17. Changes to this Privacy Policy
  18. Contacting Us

1. About PSI-Pay


1.1. PSI-Pay is a brand name for 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.

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2. Introduction


2.1. We take the privacy of Your personal information very seriously. We are responsible for ensuring that personal information is collected and processed in line with the Data Protection Act 1998 of the United Kingdom and the Privacy and Electronic Communications (EC Directive) Regulations 2003 of the United Kingdom.

2.2. This Privacy Policy forms an integral part of the Terms of Use for the Business Entity Account and Terms of Use for the User Account (‘Terms of Use’) and describes how We collect, process, disclose and transfer personal information that is provided to Us during use of ecoPayz Services.. Please check the Terms of Use for the meaning of capitalized terms.

2.3. Please read this Privacy Policy carefully. It is legally binding on You when using ecoPayz Services.

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3. Personal information


3.1. In this Privacy Policy ‘personal information’ means information that relates to an individual and on that basis makes the individual distinguishable from other individuals.

3.2. We will use the personal information only for the purposes and as under this Privacy Policy and in the Terms of Use.

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4. Your consent


4.1. By consenting to the Terms of Use before using ecoPayz Services and by using ecoPayz Services You expressly consent to the processing of Your personal information under this Privacy Policy. You consent to the transfer of personal information via the Internet, including transfer of Your personal information to countries outside the European Economic Area (‘EEA’). If You object to Your personal information being collected, processed or disclosed under this Privacy Policy, You should not use ecoPayz Services.

4.2. If We intend to collect, process or disclose personal information for a purpose not under this Privacy Policy, We will tell You and give You the opportunity to object or decline collection, processing or disclosure of Your personal information in question.

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5. Collection of information


5.1. Information about You. Information that You give Us when applying for ecoPayz Services and while You use ecoPayz Services may include Your:

  • first name(s) and last name;
  • date of birth;
  • address (may include domicile and/or postal address as well as copies of proof of address, for example, utility bill or other document bearing Your name and last name and address, issued within the last 6 (six) months);
  • government-issued/photo identification (may include a valid passport, personal identification card or driver licence);
  • social security number;
  • personal identity number or details of passport or identity card;
  • phone number (may include landline phone number and/or mobile phone number);
  • e-mail address;
  • payment instrument details (credit/debit card or bank account information);
  • personal description;
  • geographical location; and
  • We may also ask You to choose a security question to answer (such as Your city of birth or the name of Your pet) and to let us have a password.

We use this information to open ecoAccount for You and provide ecoPayz Services to You, for example, to administer Your ecoAccount, to carry out Our identity and security validation and verification checks, to process or execute Transactions, eMoney transfers sent to You, to process Your request to purchase eMoney or redeem eMoney from Your ecoAccount, and to communicate with You.

5.2. Information about Transactions. Information about a Transaction relates to information required to process and execute a Transaction. This may include:

  • the Transaction amount;
  • the type of Transaction;
  • details of the Transaction, including the reason for the Transaction and geographic location from which the Transaction is instructed and consented to;
  • e-mail address of the recipient;
  • phone number of the recipient; or
  • We may need additional commercial and/or identification information from You, for example, if You send or receive high-value or high volume Transfers, or as needed to comply with anti-money laundering regulations and other mandatorily applicable laws, and Our internal procedures;
  • in order to help detect possible Unauthorised Transactions, We also collect the Internet protocol address (IP address) used to connect Your computer, Mobile Device or other device to the Internet and that You use to access Your ecoAccount, as well as by fingerprinting the said device We collect data on the Internet browser, operating system, and screen resolution of it.

5.3. Website Information. When You visit the Website, We automatically receive information about full Uniform Resource Locators (URL) clickstream to, through and from the Website (including data and time). We also collect information about Your login details and the pages of the Website You visit when You access Your ecoAccount and the times You access the Website, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, the Internet browser type and version, time zone setting, Your Internet browser plug-in types and versions, operating system and platform. We do not track websites that You visit before or after You leave Our Website.

We use this information to try to understand Your behaviour and preferences, to develop and improve ecoPayz Services and to manage the load on Our servers.

5.4. Information about third parties. When giving Us personal information about individuals (other than Yourself), You must obtain their consent before disclosing their personal information to Us, including, their consent to Our collecting, processing, disclosure and transfer of their personal information for the purposes set out in this Privacy Policy.

We may retain a third party’s personal information, for example, a third party’s e-mail address, as it may be necessary to provide ecoPayz Services or to fulfil Our obligations under any applicable law.

5.5. Information about You provided by third parties. We are working closely with third parties and may receive information about You from them, for example when verifying information provided by You or Your identity with third parties. This may include:

  • if You register a payment instrument (credit/debit card or bank account) with Us, We will wherever possible use card authorisation, authentication and fraud screening services to verify that details of Your payment instrument and address match the information that You gave Us, to verify that You are legally authorised to use the payment instrument You provide to Us and that the payment instrument (credit/debit card) has not been reported as lost or stolen;
  • if You incur a debt, for example, You have a negative balance on Your ecoAccount, We may conduct a credit check on You by obtaining additional information about You from a credit reference agency, to the extent permitted by any applicable law. At Our sole discretion, We may periodically retrieve and review a business and/or consumer credit report for any account, and may close Your ecoAccount based on information obtained during a credit review.

5.6. Communicating with Customer Support Service - correspondence and phone calls. We may send communications and notices to You at the e-mail address or postal address You gave Us during application process for opening of Your ecoAccount (or as later updated by You) or to Your ecoAccount profile on the Website. We may also communicate with You by phone to resolve complaints from You or other Users or Business Entities or to investigate suspicious Transactions.

To ensure continuity of ecoPayz Service provided to You, We may retain and monitor correspondence (including e-mails and faxes) send to or by Us. Additionally, We may record, monitor and/or retain phone calls made to or from Us. Correspondence and phone conversations may be monitored and retained:

  • to help us improve the quality of ecoPayz Services;
  • to check whether We executed Transactions correctly;
  • to detect, investigate or prevent fraud or other crimes and potential violations of the Terms of Use;
  • to resolve Your complaints and answer Your questions;
  • for regulatory purposes;
  • for Our employee training purposes.

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6. Use of "cookies"


6.1. We use cookies to distinguish You from other Users and Business Entities that use ecoPayz Services or from persons visiting the Website. A cookie is a small file of letters and numbers that is sent to and stored on the Internet browser of Your computer or Mobile Device that You use whenever You access a website. For detailed information on the cookies We use and for the purposes for which We use them please see Our Cookie Policy.

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7. Questionnaires and surveys


7.1. We may offer You optional questionnaires and surveys for purposes like collecting demographic information, assessing Your interests and needs and evaluating Your experience with ecoPayz Services. You will be notified about use of information collected by these questionnaires and surveys before You participate in a questionnaire and/or survey.

7.2. If You wish, You need not respond to these questionnaires and surveys and You can opt out from receiving information on questionnaires and/or surveys.

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8. Use of collected information


8.1. We collect and process information and personal information for the purpose of providing ecoPayz Services and in the following ways:

  • to carry out Our obligations relating to You that arise from the Terms of Use and to provide You with ecoPayz Services;
  • to recover unpaid Fees or a negative balance on Your ecoAccount or a debt deriving from the Terms of Use or any applicable law;
  • to ensure the functionality of Your ecoAccount, for example, at Your request to issue a new password if You forget or lose it;
  • as part of Our efforts to keep ecoPayz Services safe and secure, for example, to prevent fraud;
  • to comply with any applicable law requirements, for example, to meet legal requirements set by anti-money laundering regulations;
  • to communicate with You and to tell You about changes to ecoPayz Services;
  • to administer ecoPayz Services and the Website for internal operations, for example, troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to develop and enhance ecoPayz Services;
  • to administer the Website and to improve its performance, to analyse Your behaviour and preferences, to analyse trends, to manage the load on Our servers, to gather demographic information for aggregate use;
  • to conduct market analysis and strategic planning;
  • to establish Your eligibility to receive special features, promotions and products from Us or to give You information about such offers for special features, promotions, and products that We feel may be of interest to You;
  • to measure or understand the effectiveness of advertising ecoPayz Services and to deliver relevant advertising to You;
  • to allow You to participate in interactive features of ecoPayz Services when You choose to do so;
  • to combine information We receive from other sources with information You give to Us and information We collect about You; we use this information and the combined information for the purposes set out above (depending on the types of information We receive).

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9. Retaining collected information


9.1. Closing Your ecoAccount does not mean that We delete personal information that We hold on You. For fraud and/or security purposes We will continue to keep personal information, including Transaction history, for at least 5 (five) years or longer if so required by any applicable law. Your personal information will not be used for any other purpose or shared with third parties except as necessary to prevent fraud or as required by any applicable law.

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10. Disclosure of collected information


10.1. We may share Your personal information with third parties for the limited purposes described below or as permitted by any applicable law. We may disclose Your personal information:

  • to affiliates, subsidiaries, agents or subcontractors, to ensure rendering of ecoPayz Services and performance of Our obligations arising out of the Terms of Use;
  • to card authorisation, authentication and fraud screening service providers, to ensure security of ecoPayz Services and for Your identity and security validation and verification checks that We perform;
  • to credit reference agencies, debt collection agencies and/or law firms or to pursue court claims for recovery of funds that You owe Us;
  • to assess financial and insurance risk;
  • to government authorities in response to a subpoena, warrant, court order, or as otherwise required by any applicable law;
  • to government authorities, agencies or commissions or private parties to assist Us in conducting or co-operating in investigating fraud or other criminal or illegal activities where We believe it is reasonable and appropriate to do so or in order to enforce or apply the Terms of Use or to protect the rights, property, or safety of Us, other Users or Business Entities;
  • to government authorities, agencies or commissions to prevent and detect fraud or crime;
  • to Your agent or legal representative (such as the holder of a power of attorney that You grant, or a guardian appointed for You);
  • to Business Entities and/or Users which You have asked to execute a Transaction or from which You receive a transfer of eMoney for the purpose of identity and security validation and verification checks;
  • to service providers that manage marketing or development programs on Our behalf;
  • 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 with, to the prospective buyer, transferee, or merger partner or seller 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 this Privacy Policy.

10.2. Where a third party processes Your personal information on Our behalf, it is subject to strict security and confidentiality obligations consistent with this Privacy Policy and applicable law. We will make sure that Your personal information is protected by the third party to which We disclose it to at least the same standards as under this Privacy Policy.

10.3. Your personal information may be disclosed only for the purposes of providing services to Us or in connection with ecoPayz Services. Third parties to which We disclose Your personal information are limited by contract or applicable laws from using personal information for secondary purposes. Where a third party processes personal information on its own behalf, this is subject to their own privacy policy and applicable laws.

10.4. We will not sell or rent any of Your personal information to third parties.

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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 European Economic Area (‘EEA’). Your personal information may be processed by Our affiliates, subsidiaries, agents, subcontractors and service providers as well as Business Entities located outside the EEA. By giving Your personal information, You consent to this transfer, storing and/or processing. We will take all steps reasonably necessary to ensure that Your personal information is treated securely and in accordance with this Privacy Policy.

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12. Your rights to access or limit use of personal information


12.1. You may have the right to access personal information We hold about You. We may charge a Fee for providing or making this information available.

12.2. You may be able to require Us not to process Your personal information for marketing purposes.

12.3. To exercise Your rights mentioned above, please contact Us by sending an e-mail to customersupport@ecopayz.com.

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13. Your use of information obtained from the Website


13.1. By accepting this Privacy Policy, You agree to use only information You may have obtained from use of ecoPayz Services for communication with Us, and not for any unsolicited commercial communications.

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14. Using Your personal information to contact You about products and services


14.1. We use information provided by You for marketing purposes so that We can tell You about offers for special features, promotions, and products We feel may interest You. We may also tell You about products and services from Our carefully selected business partners. This could continue after Your relationship with Us ends.

14.2. For marketing purposes, We will contact You by e-mail unless You have asked Us not to. You can change Your preferences at any time by accessing Your ecoAccount profile, choosing ‘Personal Settings’ from the left-hand menu, selecting ‘Account Option’, de-selecting the tick box regarding advertising emails, and clicking ‘Update’.

14.3. By agreeing to the Terms of Use, You also indicate Your consent to receive information on offers for special features, promotions, and products.

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15. Third party websites


15.1. We are not responsible for the operations of Business Entities or third parties, including, but not limited, their information practices. If You give information to or through a Business Entity’s or third party’s website, please note that these websites have their own privacy policies and You should review them before giving Your personal information to or through them.

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16. Security


16.1. 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.

16.2. 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 ecoPayz Services to You or perform Our obligations or exercise Our rights under the Terms of Use.

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17. Changes to this Privacy Policy


17.1. This Privacy Policy may change. We will notify You 2 (two) months before any 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.

17.2. Any changes to this Privacy Policy will be effective after lapse of the 2 (two)-month period after posting a notice on the Website and notifying You by e-mail. If We give You notice and You do not tell Us that You wish to end the Terms of Use and to close Your ecoAccount, then Your continued use of ecoPayz Services will constitute acceptance of the changes to this Privacy Policy and We will treat You as having accepted the changes.

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18. Contacting Us


18.1. If You have any questions in relation to Your personal information or Your rights under applicable laws, including requests for information and rectification regarding Your personal information that We hold, please contact Our Customer Support Service. You can contact the Customer Support Service via:

18.2. The Customer Support Service is available 24/7 for any questions You may have. If You call the Customer Support Service please leave a message including:

  • Your ecoAccount number;
  • if You are a User – Your name and last name
  • if You are a Business Entity – Your company’s name, and Your authorized representative’s name and last name;
  • Your full telephone number, including country code;
  • a brief message describing Your question.

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