1. ABOUT PLATFORM
- Account has the meaning of the account created by Platform to the Merchant;
- Merchant has the meaning of an individual or legal entity holding Account;
- Payment portal has the meaning of Platform’s payment portal located at payassist.io and used for provision of Services;
- Personal data has the meaning of information that can be used to directly or indirectly identify you.
- Services has the meaning of the services provided by Platform to its Merchants;
- Website has the meaning of the website available at https://www.payassist.io/;
- We has the meaning of Platform;
- You has the meaning of the person whose Personal data is processed by Platform;
4. PERSONAL DATA WE COLLECT
- In order to provide You with Account and Services, Platform collects various types of your Personal Data.
- Personal Data is collected and used during 3 principal steps: registration, identity verification and the use of Account and Services.
B. Processing of Personal data
- During the registration process we collect your e-mail address. Submission of Personal data is mandatory for your registration. Failure or refusal to provide your email address will dismiss your registration.
- Finalizing the registration, you shall confirm your email address provided after the respective message is sent to it.
- After providing Personal data for registration you can continue with application for opening the Account. For this purpose, we may request more information in order to meet legal and regulatory obligations. Therefore proceeding with the Account opening you should provide us your additional Personal data, which may include such data as: Name, Surname, Date of birth, Residential Address, ID document number (national identification card/ Passport Number/ Itinerary document), ID document number expiry Date, Passport Nationality, Occupation, Source of Funds, copy of identification document (ID / Passport / Itinerary document), photograph and any other information you provide us in order to prove your eligibility to use Services. Submission of all required Personal data is mandatory for creating an Account. Failure to provide any or all required Personal data will dismiss your application.
- Personal data collected by Platform in the Registration step is used for the following purposes:
- Account opening;
- Merchant’s identification and verification;
- Risk assessment mandatory under applicable laws;
- Providing to the Merchants the information regarding changes of any service agreements applicable to them or Services they use as well as other important information.
- Platform processes Personal data on the legal basis of:
- Your consent, expressed when submitting your Personal data details which are not mandatory; and
- Conclusion and performance of contractual arrangements and obligations between Platform and the Merchant.
- You may at any time edit, update or delete your contact details contacting our service center via e-mail or by filling request form on Website. Please note that you will be able to request deletion of your contact details and other registration data only if there is no legal obligation for Platform to preserve such data by the applicable laws.
- While you are using our Payment portal we collect and process:
- your login history for the security purposes; and
- history and other information of your actions while using Payment portal in order to: (i) ensure the functionality of Payment portal and to provide further updates and improvements, (ii) ensure compliance with all relevant legal obligations.
5. HOW WE SHARE PERSONAL DATA
- In order to provide you with the Services and meet our legal and regulatory obligations, we share Personal data with third parties (Data processors) while using their services as follows:
- Cloud storage and virtual servers providers: we use their service in order to store your data safely and securely;
- Identification and verification services providers: we use their service in order to verify your identity;
- Auditors, accountants and lawyers: we use their service in order to complete financial, technical and legal audits of Platform’s operations;
- Other service providers which we have engaged by service provision agreements or when such Personal data sharing is mandatory according to applicable law.
- We only use the services of those data processors which ensure safeguards and use technical and organizational security measures equivalent to the ones required by EU General Data Protection Regulation.
- As a regulated financial institution, we may need to share your Personal Data to state and public authorities. We will only do so when we are legally required to provide information or when we need to take legal action to defend our rights, as well as the cases, where we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, enforce applicable service agreements, including investigation of potential violations, detect, prevent or otherwise address fraud, security or technical issues.
6. YOUR RIGHTS
- You are granted the rights regarding the protection of your Personal Data as follows:
- The right to request access information we process about you: this right enables you to receive a copy of the personal data we hold about you;
- The right to request to correct incorrect / inaccurate information about you: this right enables you to have any incomplete or inaccurate Personal data we hold about you to be corrected;
- The right to request to transfer all or part of the Personal data: this right enables you to ask us to provide you with your Personal data in a structured, commonly used, machine-readable format, which you can then transfer to other appropriate data controller (this right only applies to automated information which you initially provided for us to use and consented for it use or where we used the information to perform a contract with you);
- The right to request erasure of Personal data: this right enables you to ask us to delete or remove personal data where there is no good reason for us to process it, or if you have successfully exercised your right to object to processing
- The right to request restriction of data processing: This right enables you to ask us to suspend the processing of your personal data in the following cases: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- The right to object to processing of Personal Data when processing is carried out on the basis of legitimate interest: this right can be exercised in a situation where we are relying on our legitimate interest (or those of a third party) but in your particular situation such processing impacts on your fundamental rights and freedoms.
- To exercise any of the rights mentioned above, please reach out to our Merchant’s support team via email of by filling request form on our Website or contact our Data Protection Officer as indicated below.
7. HOW LONG DO WE KEEP YOU DATA
- Platform is obligated under the applicable laws regarding prevention of money laundering and terrorist financing of the Republic of Estonia to retain your Personal data for a number of years:
- Merchant identification data and verification data – eight years after termination of the contract relations;
- History of transactions – five years after terminations of the contract relations.
- We therefore use this retention requirement as a benchmark for all Personal data that we receive from you. In order to not hold your information for longer than is strictly necessary we will not hold any of your personal data for more than 8 years after the termination of our business relationship.
- You have the right to lodge a complaint to the national Data Protection Agency (DPA) in the country of residence in the event where your rights may have been infringed. We would, however, appreciate the chance to deal with your concerns before you approach the DPA and find a solution at your satisfaction. So please contact us in the first instance.
- Please be noticed that Platform identify you by Personal data and e-mail, which you have provided to Platform when you signed up for the Services. When you submit your request, always provide your personal details and send your request via e-mail you have submitted when you signed up for the services. In other case we will not be able to identify you properly and submit the information requested by you or to fulfil your request.
9. PLATFORM’S DATA PROTECTION OFFICER
If you have any further questions regarding the Personal data that Platform collects and uses, please feel free to contact Data Protection Officer which is responsible for matters relating to privacy and data protection by email: email@example.com.