- Merchants who use the Paygentic Platform to monetize their products, services, or APIs;
- End Users (also referred to as “End Customers” or “Consumers”) who purchase services from Merchants via the Platform and/or maintain account balances;
- Visitors to the Paygentic Website;
- Vendors and service providers who interact with Paygentic;
- Job applicants and potential users submitting personal information to Paygentic.
1. Personal Information We Collect
1.1 Personal information you provide when you use our Services:
- Contact details, such as name, email address, postal address, phone number, company information (including company name, job role, address, location).
- Account information: if you are a Consumer and wish to interact with multiple merchants, you can create an account. If you do, we will collect your username and password.
- Identity verification details, such as government-issued ID, date of birth, and liveness/selfie checks for KYC/AML purposes.
- Payment information, including your bank account information.
- Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise correspond with us online.
- Marketing information, such as your preferences for receiving our newsletters and marketing communications about our Services, and the types of products we think will interest you based on your past purchases and use of our Services.
- Job applicants, we may collect personal data from you when you enquire or apply for a vacancy with us, such as your name, contact details, curriculum vitae (such as, qualifications, previous employment history and profession activities), results of background checks (such as, references, qualifications, and to the extent permitted by law, criminal background checks (unspent convictions)).
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
1.2 Automatic data collection:
We and our service providers may automatically log information about you, your computer or mobile device, and your interactions with our Services and our communications, such as:- Device and network data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, general location (e.g., derived from your IP address), unique identifiers, and language settings.
- Usage data, such as pages or screens you viewed, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and whether you have opened or otherwise engage with our communications, such as our marketing emails, and what kind of content you’re interested in.
- Location information, such as your city, state, zip or postal code, to personalize content provided to you, or to show you prices and promotions.
1.3 Information we obtain from other sources
- Social media information. We maintain pages on social media platforms, such as LinkedIn, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with your information through the platform, and we will treat such information in accordance with this Privacy Policy.
- Other sources. We may obtain personal information from other third parties, such as identity verification service providers, payment processors and licensed financial institutions, fraud prevention and sanctions screening tools, credit reference agencies and public databases where permitted by law, information provided by Merchants about their End Users as necessary to provide Services, analytics and marketing partners and publicly available sources, including from partners that help us advertise and market our Services.
2. How We Use Your Personal Information
We collect and process your personal data where we have a legal basis to do so. The legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it:- Provide and maintain the Services. To perform our contract with you, or when it is in our legitimate business interests to do so, we will use personal information to operate, provide and maintain our Services, including to create and manage your account so you can log in, build a profile, and interact with us to benefit from our products and Services.
- Improve, monitor and personalize the Services. It is in our legitimate interests to improve and keep our Services safe, which includes protecting the security of our Services, and preventing and detecting security threats, fraud or other criminal or malicious activities.
- Facilitate your login to the Services. It is in our legitimate business interests to use personal information to enable you to access our Services, increasing your access options and the efficiency of using the Services.
- Communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages. To perform our contractual obligations to you, or when it is in our legitimate interests to do so, we will use your personal information to sending you announcements, updates, security alerts, and support and administrative messages respond to your requests, questions, and feedback, and communicate with you about our Services, including by sending announcements, updates, security alerts, and user support and administrative messages.
- Research and development. We use personal information to help us better understand how people use our Services and how we can develop, analyse and improve them where it is in our legitimate interests to do so. This includes analyzing trends, testing new features, and making design or product decisions based on user behaviour. We may also create or use aggregated data to support research and insights that help us build better offerings as part of our Services. This data no longer identifies you.
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Marketing and Advertising. We and our advertising partners may collect and use your personal information for marketing and advertising purposes, including
- Direct marketing. We may send you curated content as permitted by law, including, but not limited to, newsletters and notifications about special promotions, offers, and events that we think may be of interest to you, including by email. You may opt out of our marketing communications as described in the “Opt-out of marketing communications” section below. Except where consent is required, we undertake such marketing on the basis of our legitimate business interests to use your personal information for the purposes described above. Where we rely on your consent, you may withdraw your consent at any time, including by following the opt-out instructions in the “Your Privacy Rights and Choices” section below.
- Compliance and protection. We use your personal information to comply with our legal obligations and to defend us against legal claims or disputes where it is in our legitimate business interests to do so, including to:
- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- Audit our internal processes for compliance with legal and contractual requirements and internal policies.
- Enforce the terms and conditions that govern our Services.
- Where we have a legitimate interest, to prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
- Where we have a legitimate interest, to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
3. How We Disclose Your Personal Information
We may disclose personal information to the following parties:- Affiliates. We may disclose your personal information to our subsidiaries and affiliates for purposes consistent with this Privacy Policy.
- Service providers. We may disclose your personal information to third-party companies and individuals that provide services on our behalf or help us operate our Services (e.g., our third-party vendors providing hosting, information technology, customer support, payment processing platforms, email delivery, and website analytics services).
- Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
- Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
- Advertising partners and other third parties. Third parties, such as advertising companies, social media providers, search engines and data providers, for interest-based advertising and other marketing purposes. These third parties may use the information we share to develop and improve their services, including to improve their ability to target ads on our and their other clients’ behalf. To learn about your choices, please see the “Your Privacy Rights and Choices” section below.
- Business transferees. We may disclose your personal information to acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, our business (including, in connection with a bankruptcy or similar proceedings).
- With your instruction or permission. We may disclose personal information to relevant third parties, where you give us permission to do so in the course of your relationship with us from time to time.
4. International Data Transfers
In the context of providing you with our Services, we may transfer your personal information to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country. When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “How to contact us” section below.5. Your Privacy Rights and Choices
5.1 Opt-out of marketing communications.
You may opt out of marketing-related emails, SMS and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “How to Contact Us” section below. You may continue to receive Services-related and other non-marketing emails and SMS.5.2 Account deactivation and deletion.
If you have an account on our Services, you may deactivate and delete your account by contacting us as described in the “How to Contact Us” section below. Note that deactivating your account may not cause us to fully delete all of your personal information. To request that we do so, please submit a data deletion request as described in the “Personal information requests” section.5.3 Personal information requests.
In addition to the above, depending on where you are based, and as provided under applicable law and subject to any limitations in such law, you may have the right to:- Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
- Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
- Correction of personal information that is inaccurate, incomplete or otherwise out of date.
- Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
- Additional choices for residents of the European Economic Area (“EEA”) and United Kingdom (“UK”):
- Request we restrict our handling of your personal information.
- Opt out of “profiling” in connection with decisions that produce legal or similarly significant effects. We do not engage in profiling in connection with decisions that produce legal or similarly significant effects.
- Object to how we are using your personal information.
- Withdraw your consent to us handling your personal information, where we are relying on your consent to process such personal information.
- Right to complain. You have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. If you reside in the EEA, click here to find your local supervisory authority, and here if you are in the United Kingdom.
- Limit online tracking. There are a number of ways to limit online tracking, which we have summarized below. Please note that these tools are not associated with us and we cannot guarantee that they work as their providers advertise them:
- Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/.
- Using privacy plug-ins or browsers. You can block our Website from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
- Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
- Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
- Digital Advertising Alliance
- Network Advertising Initiative
- Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.