Data security

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1. About us

Payleven is committed to ensuring that your privacy is protected and to processing your personal data in accordance with the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws. We will only collect and use your personal data in accordance with this data protection policy.

payleven.co.uk is owned by payleven holding GmbH. payleven holding GmbH operates www.payleven.co.uk website for its subsidiary, ZenPay UK, Ltd, a company registered in England and Wales under registration number 08016695. ZenPay UK, Ltd’s registered office is 11th Floor, Parker Tower, 43-49 Parker Street, London United Kingdom WC2B 5PS.

ZenPay UK, Ltd is registered as a data controller with the Information Commissioner’s Office (registration number Z3166921).

Unless otherwise noted in this Data Protection Policy, the terms “payleven”, “we”, “our” and “us” refer to ZenPay UK, Ltd.

2. Purpose of this Data Protection Policy

This Data Protection Policy sets out:

  1. the basis on which we collect, store, share, process and use personal data (such as information that identifies, relates to or describes you, or which is capable of being associated with you) from you when you use the website,  https://payleven.co.uk (“Website”) or any software, services or mobile application provided by us (“Application”) which enable you to initiate payment transactions;
  2. the types of Personal Data collected, stored, shared, processed and used by us and your right to control your Personal Data (“Personal Data”).

This Data Protection Policy does not apply to information that may be collected by third parties (other than payleven holding GmbH) who own or operate websites that link to the Website or are accessible by links from the Website or through the Application. While accessing those other websites or third parties, you will be subject to their terms and conditions of use and privacy policies.

If you are under the age of 18, you must not use the Application or Website or submit Personal Data to either of them.

You should read this Data Protection Policy carefully and we recommend that you print and keep a copy of it for your future reference. This Data Protection Policy was updated on 7 August 2012. We reserve the right to change and update this Data Protection Policy from time to time. We recommend that you revisit this page regularly to keep informed on the current Data Protection Policy and ensure that you are happy with any changes. If there are material changes to this Data Protection Policy, then we will notify you by email or through posting a notice on the Website or through an update to the Application.

By continuing to use the Website and Application, you confirm that you have read, understood and agree with the entire Data Protection Policy in effect at the time of your use. If you do not agree to the entire Data Protection Policy in effect at the time of your use, then you must not use the Website or the Application.

3. Personal Data Collected

We do not knowingly collect information from children under the age of 18.

When you use the Website and Application (including by registering to our Website or processing transactions through the Application, browsing or by communicating with us via email or by signing up for newsletters or other communications), we may collect all or some of the following Personal Data from or about you:

  1. the Personal Data that you provide by registering with us or filling in forms on or via the Website or Application, including:
    1. your name, title, gender and date of birth;
    2. your company name or affiliation and legal form of organisation trading name, business type/category, business address and proprietor information;
    3. your contact information including phone/mobile number/fax and email address;
    4. other demographic information such as home or other addresses and postcode;
    5. your communication preferences and interests;
  2. other information relevant to marketing, customer or research surveys which you may choose to complete or relevant to offers which we may make available to you;
  3. your browsing activities including, but not limited to, information on your location, weblogs and other communication (whether for billing purposes or otherwise), information on Website and Application resources accessed, your IP address or other unique identifiers for computers, mobile devices, technology or other devices used to access our Website or Application, information on your browser type and operating system, and the date, time and duration of your Website or Application access;
  4. where you have registered with us, your user name and password; and
  5. records of your correspondence, communications and telephone calls (including those that we may record) with us.

We may also collect some or all of the above types of information from our business partners or third parties who have your consent to pass that information on us or who may be authorised by you to authenticate or identify you to us. This may include obtaining information about you from third party verification services and credit reference agencies (including, but not limited to, your credit rating, risk class, risk forecast, credit limit, legal form, share capital, VAT number, domicile, places of business, calculated annual revenue, date of registration, board of directors, summary of annual accounts and key ratio, record of non-payment and debt with the enforcement service).

If your business has been referred to us by a partner organisation or other third party, we may disclose personal data to the partner or other third party in order to fulfil our commercial obligations under the referral arrangement.

4. How we use your Personal Data

We (and third party data processors, third party payment processors, vendors and hosting partners who may be acting on our behalf) may collect, store and process your Personal Data for the following reasons:

  1. to make the Website and Application available, to customise it, to provide content tailored to individual requirements; to understand your needs and provide you with improved products and services, newsletters and other communications and to enable others to view submissions of users;
  2. for purposes related to providing our products and services to you, including verifying and authenticating your account and identity, processing your payments and payment system or card details in order to complete transactions with us or our business partners made through the Website or Application or obtaining further information about you from third party verification services and credit reference agencies and to perform credit checks against you;
  3. to notify you about new or changes to our products and services or policies and procedures;
  4. to maintain the registered account that you may hold with us and to provide you with updates or notifications of changes to your account;
  5. for our internal record keeping requirements including collection of anonymised details about visitors to our Website or Application to compile aggregate statistics or to produce internal reports on the use of the Website and Application and to track how users navigate through them so that we may evaluate and improve the Website and Application;
  6. with your agreement, to contact you about our or our business partners’ promotions, products and services or other information which we think you may find interesting, offers, or for customer satisfaction purposes (including contact by email or SMS);
  7. for market research, analysis, testing, monitoring, risk management and administrative purposes (including diagnosing technology problems which may be reported to us);
  8. to carry out our obligations arising under any agreements between us and you; and
  9. for any purposes related to the above or where we have a legal right or duty to use or disclose your Personal Data (including for abuse, crime and fraud prevention and related purposes).

We reserve the right to retain your Personal Data, any other information which we have collected and any content that you have submitted to us via the Website or the Application to the extent required by applicable laws and as we may require for operational and legal purposes.

5. Disclosure of your Personal Data

In terms of sharing, disclosing or transferring your Personal Data to third parties (together, “Disclose” or “Disclosing”), except as set out in this Data Protection Policy, we will not Disclose your Personal Data unless we have your permission or unless we are required to do so to:

  1. comply with applicable law or an order of a governmental or law enforcement body; or
  2. investigate, prevent or take action against credit risks or suspected illegal activities (including fraud or where the personal safety of another person may be threatened) or breaches of our Terms and Conditions related to the provision of our Services; or
  3. establish or exercise our legal rights or defend against legal claims or take precautions against liability; or
  4. protect our rights, property, or safety or the rights and property of our customers, business partners or other members of our corporate group.

We may Disclose your Personal Data to other companies that are members of our corporate group (including our and their subsidiaries and ultimate holding companies, as those terms are defined in section 1159 of the UK Companies Act 2006).

We may also Disclose your Personal Data to third parties in the following circumstances:

  1. to the extent necessary to provide you with our products and services, we may Disclose your Personal Data to third party payment processors, banks or card schemes (such as MasterCard International Inc.) or other financial institutions;
  2. following their agreement with us to keep your Personal Data confidential, we may Disclose your Personal Data to third party service providers to us (including, without limitation, call centre staff);
  3. following our careful screening and assessment of them, we may Disclose your Personal Data to selected third parties who we think may be suitable to offer you information about products and services which we think may be of interest to you; and
  4. In the event that a third party proposes to acquire all or some of our business and/or assets (including by assignment or transfer of business or assets by means of corporate merger, consolidation or restructuring or any other such changes in our corporate group that may affect us), we may disclose your Personal Data to that third party in connection with their proposed or actual acquisition.
  5. In the event that there is a distribution partner in place, you authorize us to provide the distribution partner with information about your application, the date of your registration, as well as information about the acceptance or refusal of your application, as the case may be. You further authorize us to provide the distribution partner with your name, address, phone number, e-mail, date of birth and the sum of the transaction volume and the date of the second transaction. The distribution partner undertakes to use the data only in compliance with applicable data protection legislation and strict and solely for the purpose of performing its contractual and regulatory obligations. The distribution partner shall not forward the data to any third parties.

6. How we use Cookies

The Website and Application uses cookies. A cookie is a small data file which asks permission to be placed on your computer’s hard drive or other mobile or handheld device as you browse the Website or Application or their advertisements, videos or other types of content and which ‘remembers’ that your computer or device accesses the Website or Application.

If you accept the cookie, the file is added to your computer’s hard drive or other mobile or handheld device. Most web browsers automatically accept cookies but you may modify your browser settings to decline cookies or to be notified of cookies being placed.

Cookies may be used by us to do the following:

  1. enable us to respond to you as an individual and to tailor our operations to your needs by gathering and remembering Personal Data about your preferences;
  2. assist the effective operation of the Website or Application;
  3. enable traffic to the Website or Application and their pages to be logged to identify pages used and browsing and purchasing behaviour of users of the Website or Application for statistical purposes and to monitor which pages users find useful or not; or
  4. identify you as an account holder or user and assist with account or user security (such as by obliging you to re-set passwords if the password has lapsed).

The cookies do not give us access to any other Personal Data on your computer or device other than the Personal Data you choose to share with us.

Rejecting cookies used by the Website or Application may prevent you from taking full advantage of them and may stop them from operating properly when you use them. You may be unable to complete a transaction with us via the Website or Application.

If you do not consent to use of the cookies, you must disable the cookies by deleting them or amending your cookie settings on your computer or you must stop using the Website or Application. You can also deny us the right to analyse your use of the Website or Application at any time by sending us an email at queries@payleven.co.uk.

This Website also uses Google Analytics as a cookie. You can disable the collection of the data concerning your use of the website (including your IP address), as well as the treatment of these data by Google Analytics, if you download and install the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

For further questions, please contact Customer Service at queries@payleven.co.uk.

7. Transfers of your Personal Data internationally

We may transfer Personal Data that we collect from you to third party data processors, third party payment processors, vendors or hosting partners acting on our behalf located in countries outside of the European Economic Area (“EEA”) or to other entities in the Payleven group of companies in connection with the purposes set out in How we use your Personal Data. Countries outside the EEA may not offer the same level of data protection as those inside the EEA, although our collection, storage, and use of your Personal Data will continue to be governed by this Data Protection Policy.

8. Information Security

We are committed to ensuring that your Personal Data is secure.

In order to minimise the risk that there is unauthorised access to or Disclosure of your Personal Data, we put in place where practicable appropriate physical, electronic and managerial procedures to safeguard and secure it. Personal Data you provide to us in electronic format is stored on secure servers. The relevant Personal Data will only be stored in a PCI compliant environment, i.e. in accordance with a set of standards designed to ensure that the processing, storing and transmission of card information is secure and payment transactions will be encrypted.

Although we take appropriate measures to safeguard the Personal Data that you provide to us, no transmission over the internet is guaranteed to be secure. For your security, you should:

  1. ifusing a computer in a public location, always log out and close the website browser when you complete your online session;
  2. keep your account details and passwords private;
  3. frequently change your password;
  4. avoid using the same password for multiple online accounts.

In the event that there is unauthorised access to or transfer of all or part of your Personal Data as a result of a breach of our information security measures, we will notify you of the breach by email to the email address which you last provided to us or we will place a notice on our Website.

9. Links to third-parties websites

Your use of other websites which are owned and operated by third parties (other than Payleven GmbH) and accessed by links from the Website or Application is not governed by this Data Protection Policy and we do not control any of those other websites. Once you use the links from the Website or Application to access those other websites, we are not responsible for the privacy of any data that you provide while using them. You should review the privacy policies applicable to those other websites and ask any questions or raise any concerns about their collection or use of your Personal Data with that website operator.

10. Your rights in relation to your Personal Data

You have the right to a copy of the Personal Data we hold about you (for which we may charge a small administration fee) and to have any inaccurate or incomplete information about you corrected.

You also have the right to restrict our collection or use of your Personal Data and may do so by the following ways:

  1. when you are asked by us to accept a cookie or to fill in a form via the Website or Application, look for your cookie settings and the area that you can click to indicate your preference as to use of your Personal Data for marketing or other purposes;
  2. if you have previously agreed to accept a cookie, then you may change your mind at any time disabling or deleting the cookie or amending your cookie settings; or
  3. if you have consented to our use of your Personal Data to send you promotional or other information about third parties or us, but you change your mind, you may contact us and we will cease such activity.

if you have any questions or concerns regarding the protection or our use of your Personal Data, please contact us via the customer service hotline at 020-7602015 or via email to the address listed on the Contact page of the Website.

11. General

The Data Protection Policy shall be governed by and construed in accordance with English law and any matter or dispute arising out of or in connection with use of the Website, the Application or this Data Protection Policy (including any contract entered by you with us through the Website, Application or Data Protection Policy) is subject to the exclusive jurisdiction of the courts of England and Wales. All contracts shall be concluded in English.

This Data Protection Policy (including, where applicable, our Terms and Conditions) set out the entire agreement between you and us and supersede any and all prior terms, conditions, warranties and/or representations to the fullest extent permitted by law.

No third party shall be entitled to enforce any of this Data Protection Policy, whether by virtue of the Contracts (Rights of Third Parties) Act 1999 (UK) or otherwise.

The English language version of this Data Protection Policy shall be binding. Any translation or other language version of this Data Protection Policy shall be provided for informational purposes only. In the event of inconsistency or discrepancy between the English version and any translation or other language version of this Data Protection Policy, the English-language version shall prevail.

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