Privacy notice

Effective as of 25.05.2018

BACKGROUND:

NordPay Financial Limited (“NordPay”, “we” or “us”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers, partners and employees and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

  1. Information About Us

NordPay Financial Limited.
Limited Company registered in England under company number 07329550.
Registered address: Holland House, 1-4 Bury Street, London, EC3A 5AW
We are regulated by the Financial Conduct Authority for the provision of payment services and are registered as a Data Controller with the ICO.

 

  1. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

 

  1. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

 

  1. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
  • The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. This right is not absolute and only applies in certain circumstances. Please contact us using the details in Part 11 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for a particular purpose or purposes.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including profiling. We do not use your personal data for automated decision-making.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

 

  1. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

  • Name including first name and family name, date of birth, e-mail address, billing address, username, password and/or photograph, address, nationality and country of residence;
  • Card account number, card expiry date, CVC details, bank and/or issuer details;
  • Bank account number, IBAN, BIC and bank details;
  • Information relating to any items purchased, including the location of the purchase, the value, the time and any feedback that is given in relation to such purchase;
  • Technical information including, but not limited to, IP address, Geolocation and system details.

 

  1. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

  • Providing and managing your account.
  • Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
  • Dispute resolution, solving problems and collecting fees.
  • Communicating with you. This may include responding to emails or calls from you.
  • Manage risks or detect, prevent and/or remedy fraud, money laundering or other potentially illegal or prohibited activities;
  • Detect, prevent or remedy violations of applicable regulations or terms of use;
  • Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by informing us of your decision).
  • Measure the performance of our services to improve their content and presentation;
  • Manage and protect our IT infrastructure;
  • Perform credit checks, compare information to make sure it is accurate, and verify it with third parties.
  • Verifying your identity, including account creation and password reset procedures.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We use the following automated systems for carrying out certain kinds of profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 11.

  • The following automated profiling may take place (some or all may be carried out using systems provided by third parties):
    • Identity verification;
    • Risk scoring;
    • Credit checks;
    • Fraud prevention;
    • PEPs and Sanctions checks.

 

  1. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

  • For customers – 10 years after the end of the business relationship, or the longest possible time required by applicable legislation, regulations, law enforcement requests or court orders;
  • For prospects – 5 years after we receive the information or after our last contact with you.

 

  1. How and Where Do You Store or Transfer My Personal Data?

We share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:

We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.

Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.

We also use specific contracts that require any third-parties to provide the same protection for your data you’re entitled to under GDPR.

 

  1. Do You Share My Personal Data?

Like most banks or payment service providers, we work with third-party service providers with the goal of becoming more secure and efficient. For these reasons, we sometimes have to share some or all of your personal data so that they can provide us with their services.

In order to be transparent, we have listed below all the third-party service providers to whom we are entitled to communicate data, as well as the purpose of the communication and the type of information disclosed.

 

Information Systems

Company Name:

NETCOM GROUP LLC – USA

Purpose:

Provide NORDPAY FINANCIAL’s main information system for the execution of payment services, fraud reports, financial and accounting services.
Process payments initiated by the merchant and authorised by the customer to provide services by card, transfer, store transaction information, payment and other customer data related to these transactions.
Provide statistical services for regulatory reporting.
Provide information on merchant enrolment, management of payment accounts and client-provided documents, including information used to provide an identity and address.

Shared data:

Identity validation and KYC (Know Your Customer) checks carried out for regulatory purposes in connection with the onboarding of merchants and subscriptions to our payment services (detection of money laundering and terrorist financing):

  • Unique identifier of the seller
  • MCC Code (merchant category) of the seller
  • Business name of the seller
  • Authorized Signer
  • Address, postal code and country of the seller
  • Phone number of the seller
  • Seller’s email address
  • Seller’s URL
  • Date of birth (only for single owners)
  • Beneficial owner who owns at least 25% of the shares of a company
  • ID
  • Articles of Association
  • Trade register information

Transaction data:

Surname, first name, date of birth, address, telephone number, email addresses, truncated information on the means of payment, expiry dates of the means of payment, type of payment service, identity document, transaction information including merchant website URLs, user reports and statements, correspondence by email or from a dedicated support application (HelpDesk).

 

Outsourcing Customer Service

Company Name:

INNOVATION CENTER SL – SPAIN

Purpose:

Provide KYC customer support and audit services

Shared data:

Identity validation and KYC (Know Your Customer) checks carried out for regulatory purposes in connection with the onboarding of merchants and subscriptions to our payment services (detection of money laundering and terrorist financing):

  • Unique identifier of the seller
  • MCC Code (merchant category) of the seller
  • Business name of the seller
  • Authorized Signer
  • Address, postal code and country of the seller
  • Phone number of the seller
  • Seller’s email address
  • Seller’s URL
  • Date of birth (only for single owners)
  • Beneficial owner who owns at least 25% of the shares of a company.
  • ID
  • Articles of Association
  • Trade register information

Transaction data:

Surname, first name, date of birth, address, telephone number, email addresses, truncated information on means of payment, expiry dates of the means of payment, type of payment service, identity document, information transaction including URLs of merchant websites, reports and user statements, correspondence by email or from a dedicated support application (HelpDesk).

 

Payment Processing

Company Name:

CENTRALPAY SAS – France

Purpose:

Provide a payment service and PCI DSS compliance.
Allow payment processing and anti-fraud checks

Shared data:

All information related to a credit card transaction: amount, currency, BIN CARD, source IP, surname, first name, email, phone number, address, city, country.

 

Anti-fraud checks

Company Name:

MAXMIND – USA

Purpose:

Provide a fraud detection service. The data disclosed to this service provider may be:

  • retained by the service provider for audit and fraud prevention purposes;
  • used by the service provider for the purpose of optimizing its fraud detection services to NORDPAY and other third parties; and
  • transferred outside the European Union and worldwide.

Shared data:

All information related to a credit card transaction (IP, Amount, Currency, date, time, BIN, etc.)

 

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

  1. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

  1. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of NORDPAY FINANCIAL):

Email address: dpo@nordpay.eu
Postal Address: Holland House, 1-4 Bury Street, London, EC3A 5AW.

 

  1. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website, and where appropriate communicated directly to you.