Paybase Limited (Paybase) is committed to protecting and respecting your privacy. This policy, together with any agreement we enter into with you, sets out how your personal data will be treated, your privacy rights and how the law protects you.
Paybase (our, us, we, data controller) provides a full range of payment services and is responsible for your personal data. Our details are included below, and the purposes for which we act as a data controller are detailed in the table under the section titled “Purposes for which we will use your personal data”.
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Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By providing consent you are accepting and consenting to the practices described in this policy.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Where we need to collect personal data by law, or under the terms of a contract we have with you and if you fail to provide that data when requested, we may not be able to meet our regulatory obligations or perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). If you do not provide the requested information we may have to decline your application or cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data about you (and your business) including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We have also included which data controllers will use, and be responsible for, your data in the manner specified.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer, to verify your identity, to open an account, provide services to you and manage our relationship with you (e.g. inform you of changes and correspond with you)||
|To enable you to use your account to make and receive payment transactions.||
|To administer and protect our business, your account and our website, to improve our website and products/services (including troubleshooting, data analysis, testing, system maintenance, support, security, reporting, complying with our regulatory obligations and hosting of data)||
|To give you, or allow selected third parties to give you, information about goods and services we think you may be interested in.||
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you or your business. This is how we decide which products, services and offers may be relevant for you or your business (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.
You can ask us to stop sending you marketing messages or sharing your data with third parties for marketing purposes at any time by contacting us using the details provided above.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.
Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Intercom is our partner that provides the in-website chat functionality.
These cookie is used by Intercom as a session so that you, as a user, can continue a chat as you move through the site and to track the different users across sessions.
Set by Google Analytics to collect anonymous information about you, the user, and how you use our website. Typical information it collects would include how many visitors we get to the website and how long visitors stay on our website.
The _ga cookie is specifically used to store the Client ID. The _ga cookie is essential to us as we use it to identify unique users. This cookie expires after 2 years.
The _gid cookie is used to distinguish between users and has an expiration time of 24-hours.
The _gat cookie is used to throttle request rate.
Throttling is a process that is used to control the usage of APIs by consumers during a given period. Throttling limit is considered as cumulative at API level. We use throttling to limit the number of API requests per day/week/month.
The Crazy Egg Script stores cookies on your computer used by you whenever you visit our website. The cookies contain a cookie value that allows Crazy Egg to detect if you are a returning Visitor or a first-time Visitor. No Personally Identifiable Information relating to the you or details about content or statistics are stored within this cookies.
We use Crazy Egg and the ceg.s, ceg.u and ceir cookies for heatmap tracking. A heatmap is a graphical representation of data that uses a system of color-coding to represent different values. We use heatmap tracking to show your behaviour on our website. We track where you and other users have clicked on a page and how far you have scrolled down a page.
||Paybase Console authorisation cookie containing refreshable short lived tokens.|
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
You agree that we may disclose your personal information to:
You agree that we can and will disclose your personal information to third parties:
We may use systems to make automated decisions based on information we hold about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future. The following are some of the ways we may use systems to make automated decisions:
Tailoring products and services
We may use your data along with that of other customer in order to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer groups, and to manage our relationships with them.
We use your personal information to help determine if your account, or transaction, is being used for fraud or money laundering. If there is a risk of fraud, or money laundering, we may suspend or terminate your transaction and/or account and refuse access to your account.
We use automated checks to help determine if you satisfy our criteria for an account, including fraud, money laundering and eligibility checks.
Your rights with respect to automated decisions
All information you provide to us will be transferred and stored in a jurisdiction located in the European Economic Area (EEA). However, we may transfer some or all of your data to countries outside of the EEA which may not offer the same level of protection as the GDPR with respect to the processing of your personal data. Where your data is transferred to such countries it will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission (EC) can can by found on the EC’s website:https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
Where data is to be transferred to a group company in a country outside of the EEA which may not offer the same level of protection as the GDPR with respect to the processing of your personal data., we will ensure that the group company agrees to binding corporate rules in accordance with Article 47 of the GDPR which can be found at:https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679
Where we transfer data to organisations based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission:https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We keep certain data for minimum periods, namely:
The majority of personal data we hold will be deleted seven years after the termination of any agreement you have with us unless it is needed for other necessary or legitimate purposes.
In some circumstances you can ask us to delete your data: see request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under the GDPR you have the right to:
If you wish to exercise any of these rights you will need to contact us using the contact details above. In the case of exercising your right to access, you will also need to provide appropriate evidence of your identity.
If you decide to exercise one or more of these rights please note that it may mean that we have to terminate any agreement we have with you as we may no longer be able to provide the service you requested.