WHAT PERSONAL DATA DO WE COLLECT AND WHY?

The Personal Data collection process includes various categories, sources, and reasons. In cases where Personal Data is collected based on your consent, you have the right to withdraw your consent whenever you wish.

PayShop is committed to not selling or sharing Personal Data, as defined by applicable laws. We retain Personal Data for a reasonable period necessary to provide our Services and fulfill our legal obligations.

If you have any questions or concerns regarding the processing of your Personal Data, please feel free to contact us at dpo@payshop.clic.

PayShop obtains Personal Data from the following sources:

• Directly from you through direct interactions and forms.
• Internet websites, by passively collecting information about your interactions, such as page clics, time spent, or other automatically collected meta-data.
• Advertising networks and social media services.
• Internet service providers, operating systems, and platforms.
• Data analytics providers.
• Government databases.
• Service providers.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect personal data about you from various sources. For example, we collect and obtain information:

• Directly from you:
We gather personal information that you share with us, whether it be when utilizing our Service, setting up a profile, reaching out to us (including through chat), completing a survey, engaging with us at events, joining a sweepstakes, contest, or other promotional campaign (including WhyISend), leaving a review, or subscribing to receive emails, text messages, and/or postal mailings.
• Using cookies and other automatic data collection technologies:
When you access our websites, utilize our app, open or clic on emails we send you, or engage with our advertisements, we or our affiliated partners automatically gather specific data through the use of technologies like cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other tools for data collection. To obtain further details, kindly refer to our Cookie Policy.
• From Other Sources:
Information about you may be acquired from various sources, including data analytics providers, marketing or advertising service providers, social media platforms or networks, fraud prevention or identity verification service providers, electronic databases, credit reporting agencies, vendors that offer services on our behalf, or publicly accessible sources.

HOW DO WE USE OR PROCESS YOUR PERSONAL DATA?

We will only use your personal data when the law allows us to. Depending on the country in which you are in, we rely on the following legal bases to process your personal data:

1- COMPLY WITH LEGAL OBLIGATIONS

We utilize personal information in order to adhere to our legal or regulatory responsibilities, to assert or practice our rights, and to protect against a legal dispute:

• Comply with Applicable Laws:
We utilize your personal information to adhere to relevant laws and regulations, including those pertaining to "know-your-customer," anti-money laundering obligations, sanctions legislation, and the diverse regulatory rules and guidance concerning risk assessment, risk scoring, fraud prevention, counter terrorist financing, consumer protection, and complaint resolution.
• Security and Fraud Prevention:
Personal data is utilized for the purpose of identifying, examining, averting, or responding to potential malicious, deceptive, fraudulent, or unlawful behavior, such as fraudulent transactions, efforts to circumvent or breach our guidelines, protocols, and agreements, security breaches, and threats to the rights, assets, or well-being of payshop and our clients, customers, staff, or other individuals.

2- TO PERFORM A CONTRACT

• Communicating With You:
We utilize your personal information to engage in communication with you, including but not limited to addressing and/or following up on your inquiries, requests, concerns, or feedback, as well as delivering exceptional customer service.
• To Provide Our Services:
Your personal data is utilized when you access or utilize our Services, such as for processing your Transaction(s), overseeing and maintaining your account, delivering promotional offers or rewards (including our referral program), and processing payments.

3- CONSENT OR LEGITIMATE INTEREST

• Analytics and Personalization:
• We utilize personal data for the purpose of conducting research and analysis, which includes enhancing our services and product offerings.
• This enables us to gain insights into your interactions with our websites, mobile apps, advertisements, and communications, thereby improving our websites, apps, and marketing campaigns.
• Additionally, we employ personalization techniques to enhance your experience, save your time during website and app visits, and tailor the marketing and advertising content that we present to you.
• Furthermore, we strive to comprehend how you utilize our app and website.

• Marketing and Promotional Purposes:
• We utilize personal information for marketing and promotional objectives, including sending marketing, advertising, and promotional messages via email, text message, or postal mail.
• Additionally, we display customized advertisements for products and/or services that align with your preferences on social media platforms and other websites.
• Furthermore, we manage our new customer promotions, sweepstakes, contests, and similar promotional activities.

• Other Business or Commercial Purposes:
• We may process specific personal data for various business or commercial purposes under your guidance or approval.
• For more details regarding the legal grounds for processing your personal data, please refer to the section titled "What is our Legal Basis for Processing your Personal Data?" below.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

In addition to the specific situations discussed elsewhere in this privacy policy, we disclose personal data in the following circumstances:

• Service Providers:
We disclose specific personal information to external parties who provide assistance in carrying out our essential business operations and internal processes. These parties may include banks, payment providers, or other financial institutions responsible for processing your transfers or other financial service requests (such as payment processors), identity verification or KYC service providers, software and tool providers for sending postal mail, emails, and text messages, customer data analysis, marketing support, review administration, fraud investigation, customer surveying, and outsourced customer service providers.
• Corporate Affiliates:
Personal data may be shared with our corporate affiliates, such as our parent company, affiliates, and subsidiaries. These corporate affiliates handle personal data on our behalf to offer services or in other situations with your consent or as allowed or mandated by law.
• Third Party Partners:
We have the possibility of sharing your personal information with third parties whom we have collaborated with to collectively develop and provide a product, service, or joint promotional activity. Additionally, if we suspect any violation of our terms or fraudulent behavior related to our business, we may share your personal data with our banking or distribution partners. It is important to note that their utilization of your information is regulated by their own privacy policies and not by this privacy policy.
• Business Transactions:
In the event that we engage in a merger, corporate transaction, or any other circumstance that entails the transfer of our business assets, we may disclose your information to the relevant business entities or individuals involved in the negotiation or transfer.
• Social Media Platforms and Networks:
Certain websites under our domain offer a range of functionalities, including plugins, widgets, and other tools provided by external parties. These features may involve the collection or sharing of information between us and the third party involved. For instance, if you utilize our referral feature to recommend individuals through platforms like WhatsApp, Facebook, email, or SMS, please note that the handling of your information by these platforms is not subject to the terms outlined in our privacy policy.
• Legal Process:
Personal data may be disclosed in response to subpoenas, warrants, court orders, government inquiries or investigations, or to comply with applicable laws and regulations. Additionally, information may be disclosed to assert, exercise, or safeguard our rights or the rights of others; to defend against a legal claim; to ensure the safety and security of our visitors; to identify and prevent fraud; and to address potential illegal activities or violations of our policies. You may be requested to provide explicit consent for the gathering, utilization, and retention of your biometric information while undergoing the verification procedure, as mandated by privacy laws in your area. In the event that you do not grant consent, we have alternative verification methods available, albeit they may require more time. Rest assured that we will not divulge or distribute any biometric data to any party aside from our identity verification partners, unless compelled by relevant legislation or in compliance with a lawful court order.

DO WE MAKE AUTOMATED DECISIONS ABOUT YOU?

We employ automated procedures to ensure that your access to our services and your utilization of our services adhere to our specified criteria, which includes validating your identity, and to deter fraud or any unlawful actions. These procedures might result in an automated determination to decline your intended transaction, to thwart a dubious login attempt to your account, or to terminate your account. If you suspect that an automated procedure has affected you, kindly reach out to our Privacy team at pdo@payshop.clic.

WHAT ARE MY PRIVACY RIGHTS?

Customers in certain global regions are entitled to specific data privacy rights under relevant privacy laws, such as those in Europe or the UK. We are committed to upholding the highest privacy standards for all our customers.

• Access Your Data & Data Portability:
You have the right to ask us for a copy of your personal data that we hold. We will provide this information to you promptly, unless there are specific exceptions or limitations that may impact the rights and freedoms of others.
• Correct Your Data / Data Rectification:
You are entitled to make a request for the modification and rectification of any inaccuracies in your personal data. You have the option to update specific information pertaining to your account by logging into our website or app, or by contacting us as outlined in the section titled "Exercising Your Privacy Rights" below.
• Data Deletion/Erasure:
Subject to applicable law, you have the option to request the deletion of your personal data. In the event that you decide to close your account, we will update our database to indicate that your account is "Closed." However, certain account information will be retained for a specific period of time, as explained below. This measure is essential to prevent fraudulent activities, ensuring that individuals attempting to engage in fraudulent behavior cannot evade detection by simply closing their account and opening a new one. Additionally, it allows us to fulfill our legal obligations. Rest assured that if you choose to close your account, your personal data will not be utilized for any further purposes by us, nor will it be shared with any third parties, except when necessary to prevent fraud, assist law enforcement, comply with legal requirements, or as outlined in this Policy.
• Restrict Processing of Data Requests:
You are entitled to ask for limitations or raise objections to the processing or transfer of your personal information in specific situations. If you believe that processing based on legitimate interests is affecting your fundamental rights and freedoms due to your unique circumstances, you have the right to object.
• Automated Individual Decision-Making, Including Profiling:
In certain legal jurisdictions, individuals possess the right to not be subjected to decisions that are solely based on automated processing of their personal data. These decisions, which may include profiling, can have significant legal or similar effects on the individual. However, there are exceptions to this right as outlined in relevant data protection laws. We reserve the right to reject your request in accordance with applicable law, such as when providing the requested information would result in the disclosure of a trade secret or hinder the prevention or detection of fraud or other criminal activities. Nevertheless, in most cases, we will ensure that the algorithm and source data are functioning as intended, without any errors or biases. If required by law, we will make necessary adjustments to the processing.
• Unsubscribe from Direct Marketing:
You have the option to request that we do not process your personal information for marketing purposes. You can exercise this right at any time by taking the necessary "unsubscribe" actions that are provided to you, such as clicing on the "unsubscribe" link in any promotional email we send you. We will respect your decision and refrain from sending you any further marketing communications. It is important to note that if you choose to opt out of email communication at a specific email address, we will keep a record of that email address on a "suppression list" in order to comply with your request to not be contacted. You have the freedom to modify your marketing preferences whenever you wish. Additionally, you have the ability to control how we utilize certain aspects of your personal data within our Services, such as how we communicate with you. You can confirm your preferences in your Profile. Please be aware that not all forms of communication can be disabled. For instance, we may be obligated to send you email notifications regarding our Services in order to comply with legal requirements outlined in national laws and regulatory guidelines.
• Withdraw Your Consent:
You are entitled to revoke your consent for us to process your data, provided that our legal grounds for processing are based on that consent. It should be noted that withdrawing consent does not impact the legality of any processing that may have occurred prior to the withdrawal. However, please be aware that if you choose to withdraw your consent, there is a possibility that we may not be able to offer you certain products or services.
• Identity Verification:
In order for us to proceed with certain requests, it is necessary for us to authenticate your identity to ensure that the request originated from you. You may be contacted via phone or email for verification purposes.
• Exercising Your Privacy Rights:
In order to utilize any of the aforementioned privacy rights, kindly make a request by either sending an email to data@payshop.clic or by reaching out to us through Phone.

HOW DO WE PROTECT YOUR DATA?

We adhere to industry-recognized standards to safeguard the data you provide to us. Our website and application utilize SSL encryption technology to protect sensitive information like bank account numbers, credit card details, date of birth, and government IDs. Additionally, users must use security credentials, such as a username and password, to access their information on our platform. If you have been provided with security credentials, it is your responsibility to maintain their confidentiality. In the event that you use your fingerprint to access our services (e.g. Apple Touch ID), do not allow others to register their fingerprint on your device to prevent unauthorized access. While we implement various security measures, no method of transmission or storage is entirely foolproof. Therefore, the transmission of personal data is done at your own risk. For any security-related inquiries, please reach out to us at privacy@payshop.clic.

TRANSFERRING PERSONAL DATA OUTSIDE THE EEA OR UK

We disclose your personal information within the payshop group and to external third parties (the categories of which are outlined in this Policy). This could involve the transfer of your personal data outside of the EU or UK. When we do transfer your personal data outside of the EU or UK, we will guarantee that it receives a level of protection similar to what it would have in Europe. In certain cases, your personal data may be transferred to countries that the European Commission has deemed to offer an adequate level of protection for personal data. In other cases, we will ensure that at least one of the lawful safeguards is in place, which may involve using specific contracts approved by the UK Government and/or European Commission to provide your personal data with the same level of protection it would have in Europe.

HOW LONG DO WE RETAIN YOUR DATA?

We will retain your personal data only for the necessary duration to fulfill the purposes for which it was collected, such as meeting legal, accounting, or reporting obligations. The appropriate retention period for personal data is determined based on various factors, including the laws and regulations applicable to your country of residence, the type and sensitivity of the data, the potential risks associated with unauthorized use or disclosure, and whether the purposes of processing the data can be achieved through alternative means. As a regulated financial institution, we are mandated to retain certain personal and transactional data even after your account is closed. By using our Services, you explicitly consent to us retaining your personal data, including information related to your transactions and identity verification, for a minimum of 7 years after the termination of your legal relationship with us.

CHANGES TO THIS POLICY

We reserve the right to modify this Policy at any given time. In the event of any changes, we will inform you by publishing an updated version on our Site and App. We recommend reviewing this Policy each time you engage in a Transaction, as it may have been revised since your initial registration for our Services or your last Transaction. If you disagree with any part of this Policy or any modifications made, you have the option to terminate your Agreement with us and deactivate your Profile. Please contact us via email at data@payshop.clic or through other means of communication.

CHILDREN

We kindly request that individuals under the age of 18, whom we consider as children and minors, abstain from utilizing our Services or providing any personal details to us. Individuals under the age of 18 are not permitted to access our Services, and should we find that an individual under the age of 18 has created a Profile with us, we will deactivate it.

PRIVACY POLICY TRANSLATION

The Policy has been formulated in English, and there is a possibility of translations being available in other languages. In case of any discrepancies between the English version and the translated versions, you acknowledge that the English version of the Policy will prevail in any dispute concerning this Policy.

CONTACT AND COMPLAINTS

Should you have any inquiries, feedback, or inquiries about our privacy policy, please do not hesitate to contact us at privacy@payshop.clic. If you are unsatisfied with the resolution of your questions or issues, or if you suspect that your data protection or privacy rights have been violated, you have the option to file a complaint with a supervisory authority or other relevant public body tasked with upholding privacy regulations, as detailed in the "Our Relationship with You" section.

HOW CAN I CONTACT THE COMPANY REGARDING MY DATA?

You can always submit a request to our Data Protection Officer, by sending an email to the following address: dpo@payshop.clic.