Payments Privacy Statement of Stripe

Last updated: January 24, 2023

This Privacy Policy includes important information about your personal data and we encourage you to read it carefully.

Welcome

We provide financial infrastructure for the internet. People use our services to enable their purchases and businesses of all sizes use our technology and services to accept payments, send payouts, and manage their businesses online. Stripe wants to be clear about our use of the Personal Data that is entrusted to us.

This Privacy Policy (“Policy”) describes the “Personal Data” that we collect about you, how we use it, how we share it, your rights and choices, and how you can contact us about our privacy practices. This Policy also outlines your data subject rights, including the right to object to some uses of your Personal Data by us. Please visit the Stripe Privacy Center for more information about our privacy practices.

“Stripe”, “we”, “our” or “us” means the Stripe entity responsible for the collection and use of Personal Data under this Privacy Policy. It differs depending on your jurisdiction. Learn More.

“Personal Data” means any information that relates to an identified or identifiable individual, and can include information that you provide to us and that we collect about you, such as when you engage with our Services (e.g. device information, IP address).

“Services” means the products and services that Stripe indicates are covered by this Policy, which may include Stripe-provided devices and apps. Our “Business Services” are Services provided by Stripe to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities. Our “End User Services” are those Services which Stripe provides directly to people (rather than entities) for their own use. 

“Sites” means Stripe.com and the other websites, apps and online services that Stripe indicates are covered by this Policy. Collectively, we refer to Sites, Business Services and End User Services as “Services”.

Depending on the context, “you” means End Customer, End User, Representative or Visitor:

• When you directly use an End User Service for your personal use (such as when you sign up for Link, or make a payment to Stripe Climate in your personal capacity), we refer to you as an “End User.”
• When you do business with, or otherwise transact with, a Business User (e.g. when you buy a pair of shoes from a merchant that uses Stripe Checkout for payment processing) but are not directly doing business with Stripe, we refer to you as an “End Customer.”
• When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, administer an account for a merchant who is a Business User, or receive an employee credit card from a Business User using Stripe Issuing), we refer to you as a “Representative.”
• When you visit a Site without being logged into a Stripe account or otherwise communicate with Stripe, we refer to you as a “Visitor.” (e.g. you send Stripe a message asking for more information because you are considering being a user of our products).

Depending on the activity, Stripe acts as a “data controller” and/or “data processor (or service provider)” and for more information about this and on the Stripe entity that is responsible under this Policy, see here.

1. Personal Data that we collect and how we use and share it

2. More ways we collect, use and share Personal Data

3. Legal bases for processing data

4. Your rights and choices

5. Security and retention

6. International data transfers

7. Updates and notifications

8. Jurisdiction-specific provisions

9. Contact us

1. Personal Data that we collect and how we use and share it

Our collection and use of Personal Data changes depending on whether you are acting as End User, End Customer, Representative or Visitor and our different Services.  For example, if you are the sole owner of a business (i.e., sole proprietorship), we may collect Personal Data to onboard your business, but you may also be an End Customer that purchased goods from another Business User that uses Stripe’s Services for payment processing and you may also be an End User who uses Link to make those purchases.  

“Transaction Data” as used in this Privacy Policy includes Personal Data, and may include the following: your name, email address, billing address, shipping address, payment method information (such as credit or debit card number, bank account information or payment card image selected by you), merchant and location, purchase amount, date of purchase, and in some cases, some information about what you have purchased and your phone number and past purchases.

1.1 End Users

We provide End User Services where we do not act as a service provider or processor to Businesses but instead provide the Services directly to you for your personal use (e.g. Link). We provide more information about our collection, use and sharing of Personal Data in our Privacy Center, including the legal bases which we rely on for using (processing) your Personal Data.

a. Personal Data that we collect about End Users

• Using Link or Connecting your Bank Account. Stripe offers you the opportunity to store your payment methods with Stripe so that you can conveniently use it across merchants who are our Business Users (“Link” was formerly known as “Remember Me”). When you opt in to Link, you agree to let us store your Personal Data such as your payment method so that you can more readily make purchases through Link with Business Users of our payment processing Business Services (e.g. name, contact information, payment method details (e.g. card number, cvc, and expiration date)). When you choose to pay with Link, we will also collect Transaction Data related to your transactions. Learn More.
  • If you choose to share bank account information (including for use in Link) with us, Stripe will periodically collect and process your account information (e.g. bank account owner information, account balances, account number and details, account transactions and, in some cases, credentials). With your separate permission, we will share this Personal Data with Business Users that you choose.  You can ask us to stop collecting and sharing this information.  Learn More.   
  • With your separate permission, we will share contact information (e.g. shipping address, billing address and phone number) with Business Users that you do business with. 
• Paying Stripe. If you are buying goods or services directly from Stripe, we receive Transaction Data. For example, when you make a payment to Stripe Climate, we will collect contact information, payment method information, and information about that transaction.
• Identity/Verification Services. We provide an identity verification service that automates comparing an identity document with your image (e.g., selfie).  You may choose to opt-in to allow us to store that verification for future use across other merchants and/or separately consent to letting us use your biometric data to improve our verification technology. You can also ask us to stop providing you these services.  Learn More. 
• More. Please see below for information about additional types of Personal Data that we may collect about End Users, including about your online activity and how you engage with our End User Services.  

b. How we use and share Personal Data of End Users

• Services. We use your Personal Data to provide the End User Service to you, including security, sanctions screening, delivery, support, personalization (e.g. language preferences and settings choices) and messages related to the End User Service (e.g. communicating Policy updates and information about our Services). For example, we will use Personal Data to assess whether your use of Link to make a payment with a merchant is authorized by you (and not a bad actor) and likely to be successfully authorized by the payment method you choose to use when you choose to make purchases with Link.
• Our Business Users. When you choose to connect your financial account with Stripe you may also choose to share account information with Business Users that you do business with. These Business Users will have their own privacy policies which describe how they use that information.
• Transactions. For payment transactions with Link, End User Personal Data is shared with others to enable or “process” the transaction. For example, when you choose to use a payment method for the transaction with Stripe or with Link (e.g. credit card, debit card, buy now pay later, or direct debit), the third party provider of your payment method will receive Transaction Data that includes your Personal Data. When you use Link, the merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and, with your separate consent, your bank account information. Please review the privacy policies of your payment method and the merchants who you choose to learn more about their processing of your Personal Data.  
• Fraud Detection and Loss Prevention. We use your Personal Data collected across our Services (e.g. Stripe Radar) to detect fraud and prevent financial losses for you, us, and our Business Users and financial partners, including to detect unauthorized purchases. Learn More. We may provide Business Users and financial partners (including card issuers, payment methods and others involved in payment processing activities) that use our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud or loss risk with a transaction. You can learn more about how we may use technology to assess the fraud risk associated with an attempted transaction and what information we share with Business Users here. 
• Advertising. We may use your Personal Data to assess your eligibility for, and offer you, other End User Services or promote existing End User Services. Where allowed by law (including with your opt-in consent where required), we use and share End User Personal Data with others so that we may market our End User Services to you, including through interest-based advertising. See our Cookie Policy. 
  • We do not sell or share End User Personal Data with third parties for marketing or advertising their products without your separate consent.
• More. Please see below for information about additional ways in which we may use and share your Personal Data.

1.2 End Customers

Stripe offers Business Services to our Business Users (e.g. payment processing through in-person or online checkout, or processing pay-outs for those Business Users). When we are acting as a Business User’s service provider (also known as a data processor), we will process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions (e.g. when we process a payment for a Business User because you bought a product from them) or they instruct us to send funds to you. 

Business Users are responsible for making sure that their End Customers’ privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their products and services. If you are an End Customer, please refer to the privacy policy or notice of the Business User you choose to do business with for information regarding their privacy practices, choices and controls.  We provide more information about our collection, use and sharing of Personal Data in our Privacy Center, including the legal bases which we rely on for using (processing) your Personal Data.

a. Personal Data that we collect about End Customers

• Transaction Data. If you are an End Customer, when you make payments to, get refunds from, begin a purchase, make a donation or otherwise transact with a Business User that uses us to provide payment processing Business Services, we will receive Transaction Data. We may also receive your transaction history with the Business User. Learn More. Moreover, we may obtain information typed into a checkout form, even if you choose not to complete the form or purchase with the Business User. Learn More.
• Identity/Verification Information. Stripe provides a verification and fraud prevention Service that allows a Business User to verify Personal Data about you, such as your age (when purchasing age restricted goods) or your authorization to use a payment method. As part of these Services, you will be asked to share Personal Data with us for this purpose (e.g., your government ID, your image (selfie), and Personal Data you input or that is apparent from the physical payment method (e.g. credit card image)). To protect against fraud, we may compare this information with information about you we collect from Business Users, financial partners, business partners, identity verification services, publicly available sources, and other third party service providers and sources so that we can assess whether the person is likely to be you or a person purporting to be you. Learn More.
• More. Please see below for information about additional types of Personal Data that we may collect, including your online activity.

b. How we use and share Personal Data of End Customers

To provide our Business Services to our Business Users, we use Personal Data, and share Personal Data of a Business User’s End Customers with the Business User.  Where allowed, we also use End Customers’ Personal Data for Stripe’s own purposes to secure, improve and provide our Business Services and prevent fraud, loss and other harms as described below.

• Payments and Accounting. We use your Transaction Data to provide our Payments related Business Services to Business Users, including to process online payment transactions, to calculate applicable sales tax, to invoice and bill, and to help them calculate their revenue, pay their bills and perform accounting tasks. Learn More. We may also use Personal Data to provide and improve our Business Services.
  • For payment transactions, your Personal Data is shared with a number of parties in connection with your transaction. Because we act as a service provider or processor, we share Personal Data to enable the transaction. For example, when you choose to use a payment method for the transaction (e.g. credit card, debit card, buy now pay later, or direct debit), your payment method will receive the Transaction Data that includes your Personal Data. Please review your payment method’s privacy policy to learn more about how they use and share this information.
  • The merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and the merchant may share that Personal Data with others. Please review your merchant’s privacy policy to learn more.
• Financial Services. Some of our Business Users use our Services in order to offer financial services to you, through Stripe or its financial partners. For example, they may provide a card product that enables you to purchase goods and services. These cards may carry the Stripe brand, bank partner brand and/or the brands of Business Users. In addition to any Transaction Data we may produce or receive when these cards are used for purchases, we will also receive and use your Personal Data in order to provide and manage these products. Please also see the privacy policies of the Business User and our bank partners, if applicable, associated with the financial service (whose brands may be shown on the card).
• Identity/Verification Services. We use Personal Data about your identity, including information provided by you and our service providers, to perform verification Services for Stripe or for the Business Users that you are doing business with, to reduce fraud and enhance security. If you provide a “selfie” along with an image of your identity document, we will use technology to compare and calculate whether they match and you can be verified. Learn More.
• Fraud Detection and Loss Prevention. We use your Personal Data collected across our Services (e.g. Stripe Radar) to detect and prevent losses for you, us, our Business Users and financial partners. We may provide Business Users (including card issuers, payment methods and others involved in payment processing activities) that use our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the fraud or loss risk associated with a transaction. You can learn more about how we may use technology to assess the fraud and loss risk associated with an attempted transaction and what information we may share with Business Users about such risks here and here.
• Our Business Users (their Authorized Third Parties). We share Personal Data of End Customers with their respective Business Users and with parties directly authorized by those Business Users to receive Personal Data. This includes sharing Personal Data of End Customers with Business Users when a Business User authorizes a third party application provider to access its Stripe account using Stripe Connect. For example, when the Business User uses Identity Services to verify an End Customer’s identity, Stripe shares with the Business User the information, documents or photos provided by the End Customer to verify their identity. The Business Users you choose to do business with may further share your Personal Data to third parties they authorize (e.g. other third party service providers). Please review their privacy policy to learn more.
• Advertising by Business Users. If you have begun a purchase, we share Personal Data with that Business User in connection with our provision of Services and that Business User may use your Personal Data to market and advertise their products or services, subject to the terms of their privacy policy. Please review your merchant’s privacy policy to learn more, including your rights to stop their use of your Personal Data for marketing purposes. 
  • We do not use, sell or share End Customer Personal Data for our marketing or advertising, or for marketing and advertising by third parties who are not the Business User with which you have transacted or attempted to transact.
• More. Please see below for information about additional ways in which we may use and share your Personal Data.

1.3 Representatives

To provide Business Services, we collect, use and share Personal Information from Representatives of Business Users (e.g. a business owner). We provide more information about our collection, use and sharing of Personal Data in our Privacy Center, including the legal bases which we rely on for using (processing) your Personal Data.

a. Personal Data that we collect about Representatives

• Registration and Contact Information. If you register for a Stripe account for a Business User (including incorporation of a Business), we collect your name and account log-in credentials. If you register for an event that Stripe organizes or attends or if you sign up for Stripe communications, we collect your registration and profile information. If you are a Representative or Representative of a potential Business User, we receive your Personal Data from third parties (including data providers) in order to advertise to, market and communicate with you as described further below and in Section 2. We may also associate a location with you in order to assess which Services or information may be useful to you. Learn More. 
• Identification Information. If you are an owner of a Business User or you are expected to be a shareholder, officer or director of a Business User, we require that you provide your contact details, such as name, postal address, telephone number, and email address to fulfill our financial partner and regulatory requirements. We will directly (and through others) collect Personal Data about you, such as your ownership interest in the Business User, your date of birth and government identifiers associated with you and your Business User (such as your social security number, tax number, or Employer Identification Number). You may also choose to provide bank account information.
• More. Please see below for information about additional types of Personal Data that we may collect, including about online activity.

b. How we use and share Personal Data of Representatives

We generally use Personal Data of Representatives to provide the Business Services to the associated Business Users, as well as for the purposes described below.

• Business Services. We use and share Personal Data of Representatives with Business Users to provide the Services you (or the Business User you are associated with) have requested. 
  • In some cases our Business Service will require us to submit your Personal Data to a government entity (e.g. incorporating a business, or paying applicable sales tax).  For our tax Business Services, we may use your Personal Data to file taxes on behalf of your associated Business User. For our Atlas business incorporation services, we may use your Personal Data to submit forms to the IRS on your behalf and to file documents with other governmental authorities (e.g. articles of incorporation in your state of incorporation).
  • We share data with parties directly authorized by a Business User to receive Personal Data (e.g. financial partners servicing the financial product, or third party apps or services the Business User uses in conjunction with our Business Services). For example, providers of payment methods (e.g., Visa, WeChat Pay) will require merchant onboarding information for the Business Users that accept their payment methods, and Stripe will provide required onboarding information (including Personal Data of Representatives) to those financial partners. In some cases, these payment method providers will be located outside your home country for example WCP, AliPay, Block, Klarna Bank AB.  Learn More.  
    • The use of Personal Data by a Business User’s authorized third party is subject to the third party’s privacy policy.
  • If you are a Business User and have chosen a name that includes Personal Data (e.g. a sole proprietorship or family name in a company name), we will share and use that information as any company name in connection with the provision of our Services (e.g. including it on receipts and other descriptions identifying financial transactions). 
• Advertising. Where allowed by applicable law, we use and share Representative Personal Data with others so that we may advertise and market our Services to you. Subject to applicable law (including any consent requirements), we may advertise to you through interest-based advertising and emails and seek to measure the effectiveness of our ads. See our Cookie Policy. We do not sell or share Representative Personal Data to others for their advertising purposes.
• More. Please see below for information about additional ways in which we may collect, use and share your Personal Data.

1.4 Visitors 

We collect, use and share Personal Data of Visitors (who are not End Users, End Customers or Representatives).  We provide more information about our collection, use and sharing of Personal Data in our Privacy Center, including the legal bases which we rely on for using (processing) your Personal Data.

a. Visitor Personal Data that we collect

When you visit our Sites, we will receive your Personal Data either from you providing it to us or through our use of cookies and similar technologies. See our Cookie Policy.

• Forms. When you choose to fill in a form on the Site or on third party websites featuring our advertising (e.g. LinkedIn or Facebook), we will collect the information included in the form (e.g. your contact information and other information about your question related to our Services).  We may also associate a location with your visit. Learn More.
• More. Please see below for information about additional types of Personal Data that we may collect, including about online activity.

b. How we use and share visitor Personal Data

• Personalization. We use information about you that we gather from cookies and similar technologies to measure engagement with the content on the Sites, to improve relevancy and navigation, to personalize your experience (e.g. language and relevant geography) and to tailor content about Stripe and our Services to you.  For example, because not all of our Services are available in all regions, so we may tailor our answers for your region.
• Advertising. As allowed by law, we use and share Visitor Personal Data with others so that we may advertise and market our Services to you.  Subject to applicable law (including any consent requirements), we may advertise our Services to you through interest-based advertising and emails, and seek to measure the effectiveness of our ads. See also our Cookie Policy.  We do not sell or share Visitor Personal Data to others for their advertising purposes.
• Engagement.  When visitors engage with our stripe.com site, we will use information we collect about and through your devices in order to provide the opportunity to engage in conversations or with chatbots to address your questions.
• More. Please see below for information about additional ways in which we may collect, use and share your Personal Data.

2. More ways we collect, use and share Personal Data

In addition to the ways we collect, use and share Personal Data that are described above, we also process your Personal Data as follows: 

a. Personal Data Collection

• Online Activity. Depending on the Service you use and the Business Users’ implementation of our Business Services, we will collect information about:
  • Devices and browsers across our Sites and third-party websites, apps and other online services (“Third-Party Sites”),
  • Usage data associated with those devices and browsers and how you’ve engaged with our Services, including IP address, plug-ins, language used, time spent on Sites and Third-Party Sites, pages visited, links clicked, payment methods used, and the pages that led or referred you to Sites and Third-Party Sites. For example, activity indicators, like mouse activity indicators, to help us detect fraud. Learn More. Please also see our Cookie Policy.
• Communication and Engagement Information. We will collect any information you choose to provide to us, for example, through support tickets, emails or social media. When you respond to Stripe emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Stripe, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Stripe events and other interaction with Stripe personnel.
• Forums and Discussion Groups. Where our Sites allow you to post content, we will collect Personal Data that you provide in connection with the post.

b. Personal Data Usage. In addition to the Personal Data usage described above, we use Personal Data in the following ways:

• Improving and Developing our Services. We use analytics on our Sites to help us analyze your use of our Sites and Services and diagnose technical issues. To learn more about the cookies that may be served through our Sites and how you can control our use of cookies and third-party analytics, please see our Cookie Policy. We also collect and process Personal Data through our different Services, whether you are an End User, End Customer, Representative or Visitor, to improve our Services, develop new Services and support our efforts to make our Services more relevant and more useful to you. Learn More.
• Communications. We will use the contact information we have about you to perform the Services, which may include sending codes via SMS to authenticate you. Learn More. If you are an End User, Representative or Visitor, we may communicate with you using the contact information we have about you (e.g. using email, phone, text message or videoconference) to provide information about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and include you on our marketing information campaigns.
• Social Media and Promotions. If you choose to submit Personal Data to us to participate in an offer, program or promotion, we will use the Personal Data you submit to administer the offer, program or promotion. We will also use that Personal Data and Personal Data you make available on social media to market to you unless we are not permitted to do so.
• Fraud Prevention and Security. We collect and use Personal Data to help us to detect and manage the activity of fraudulent and other bad actors across our Services, to enable our fraud detection Business Services, and to otherwise seek to secure our Services and transactions against unauthorized access, use, modification or misappropriation of Personal Data, information and funds. In connection with fraud and security monitoring, prevention, detection, and compliance activities for Stripe and its Business Users, we receive information from service providers (including credit bureaus), third parties, and the Services we provide. We may collect information from you, and about you, from Business Users, financial parties and in some cases third parties. For example, to protect our Services, we may receive information from third parties about IP addresses that malicious actors have compromised. Learn More. This Personal Data (e.g. name, address, phone number, country) helps us to confirm identities, run credit checks subject to applicable law and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by an End Customer or End User with a Business User or financial partner.
• Compliance with Legal Obligations. We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas and other legal obligations. Learn More.  We strive to make our Services safe, secure and compliant, and the collection and use of Personal Data is critical to this effort. For example, we may monitor patterns of payment transactions and other online signals and use those insights to reduce the risk of fraud, money laundering and other activity that is harmful to Stripe, our End Users and their End Customers.
• Minors. The Services are not directed to minors, including children under the age of 13, and we request that they not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law.

c. Personal Data Sharing. In addition to the ways described above, we share Personal Data in the following ways:

• Stripe Affiliates. We share Personal Data with other Stripe affiliated entities. When we share with these entities, it is for purposes identified in this Policy.
• Service Providers or Processors. In order to provide Services to our Business Users and End Users and to communicate, market and advertise to Visitors, Representatives and End Users regarding our Services, we will rely on others to provide us services. Service providers provide a variety of critical services, such as hosting (storing and delivering), analytics to assess the speed, accuracy and/or security of our Services, identity verification, customer service, email and auditing. We authorize such service providers to use or disclose the Personal Data that we make available to perform services on our behalf and to comply with applicable legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union, the United States of America and India. Learn More.
• Financial Partners. “Financial Partners” are financial institutions that we partner with to offer the Services (including payment method acquirers, banks and payout providers). We share Personal Data with certain Financial Partners to provide the Services to the associated Business Users and to offer certain Services in partnership with our Financial Partners. For example, we share certain Personal Data of Representatives (e.g. loan repayment data and contact information) with institutional investors who purchase or provide credit secured by the Capital loans that we have made to the associated Business Users.
• Others with Consent. In some cases we may not provide a service, but instead refer you to, or enable you to engage with, others to get services (e.g. professional services firms that we partner with to deliver Atlas). In these cases, we will disclose the identity of the third party and the information that will be shared with them and seek your consent to share the information.
• Corporate Transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Policy.

Compliance and Harm Prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, (ii) to comply with rules imposed by a payment method in connection with use of that payment method (e.g. network rules for Visa); (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Stripe, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

3. Legal bases for processing data

For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data. For more information, see here.

a. Contractual and Pre-Contractual Business Relationships. We process Personal Data for the purpose of entering into business relationships with prospective Business Users and End Users and to perform the respective contractual obligations with them. Activities include:

• Creation and management of Stripe accounts and Stripe account credentials, including the evaluation of applications to commence or expand the use of our Services;
• Creation and management of Stripe Checkout accounts;
• Accounting, auditing, and billing activities; and
• Processing of payments, including fraud detection, loss prevention, optimizing valid transactions, communications regarding such payments, and related customer service.

b. Legal Compliance. We process Personal Data to verify the identity of individuals and entities in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as "Anti-Money Laundering ("AML") and Know-Your-Customer ("KYC")" obligations, and financial reporting obligations. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law and may require us to report our compliance to third parties, and to submit to third party verification audits.

c. Legitimate Interests. Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes for which we have a legitimate interest in processing your data:

• Detect, monitor and prevent fraud and unauthorized payment transactions;
• Mitigate financial loss, claims, liabilities or other harm to End Customers, End Users, Business Users and Stripe;
• Determine eligibility for and offer new Stripe products and services Learn More;   
• Respond to inquiries, send Service notices and provide customer support;
• Promote, analyze, modify and improve our Services, systems, and tools, and develop new products and services, including reliability of the Services;
• Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets;
• Analyze and advertise our Services, and related improvements;
• Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
• Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business Learn More;
• Enable network and information security throughout Stripe and our Services; and
• Share Personal Data among our affiliates.

d. Consent. We may rely on consent to collect and process Personal Data as it relates to how we communicate with you and for the provision of our Services such as Link, Financial Connections, Atlas and Identity. When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn.

4. Your rights and choices

You may have choices regarding our collection, use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us

If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails or as described here. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, (i) we retain the right to communicate to you regarding the services you receive (e.g. support and important legal notices) and (ii) our Business Users may still send you messages and/or direct us to send you messages on their behalf. 

b. Your data protection rights

Depending on your location and subject to applicable law, you may have the following rights described here with regard to the Personal Data we control about you:

• The right to request confirmation of whether Stripe processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
• The right to request that Stripe rectify or update your Personal Data that is inaccurate, incomplete or outdated;
• The right to request that Stripe erase your Personal Data in certain circumstances provided by law. Learn More;
• The right to request that Stripe restrict the use of your Personal Data in certain circumstances, such as while Stripe considers another request that you have submitted (including a request that Stripe make an update to your Personal Data);
• The right to request that we export your Personal Data that we hold to another company, where technically feasible;
• Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; 
• Where we process your information based on our legitimate interests, you may also have the right to object to the processing of your Personal Data. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.  Learn More.
• The right not to be discriminated against for exercising these rights; and/or
• The right to appeal any decision by Stripe relating to these rights.

You may have additional rights regarding your Personal Data under applicable law. For example, see Jurisdiction-specific provisions section under California below.

c. Process for exercising your data protection rights

To exercise your data protection rights please also see the Stripe Privacy Center or contact us as described below.

5. Security and retention

We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

To help us protect Personal Data, where you have an account with Stripe, we encourage you to use a strong password, protect that password from unauthorized use and not use the same log-in credentials (e.g. password) for your Stripe accounts as you do with other services or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your Stripe account has been compromised), please contact us immediately. Learn More.

We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your Stripe account or complete a transaction with a Business User, we may retain your Personal Data: 

• to comply with our legal and regulatory obligations. 
• to enable fraud monitoring, detection and loss prevention activities. 
• to comply with our tax, accounting, and financial reporting obligations
• where required by our contractual commitments to our financial partners (and where data retention is mandated by the payment methods you used). 

In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. Learn More.

6. International data transfers

We are a global business. We may transfer your Personal Data to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from officials (such as law enforcement or security authorities). Learn More. 

If you are located in the European Economic Area (“EEA”), the United Kingdom ("UK") or Switzerland, please see Stripe Privacy Center for more information. Where applicable law requires a data transfer mechanism, we use one or more of the following: 

• Transfers to certain countries or recipients that are recognised as having an adequate level of protection for Personal Data under applicable law. 
• EU Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Addendum issued by the Information Commissioner’s Office. You can obtain a copy of the relevant Standard Contractual Clauses. Learn More. 
• or other legal methods available to us under applicable law. 

While Stripe, Inc. remains self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, it is not currently relying on these frameworks for the transfer of Personal Data to the United States.

7. Updates and notifications

We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective the latter of when we post the revised Policy on the Services or otherwise provide notice of the update as required by law.

We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are an End User or Representative, by contacting you through your Stripe Dashboard, email address and/or the physical address listed in your Stripe account.

8. Jurisdiction-specific provisions

• Australia. If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Policy, you may wish to contact the Office of the Australian Information Commissioner.
• Brazil.To exercise your rights, you may contact our DPO. Brazilian residents, to whom the Lei Geral de Proteção de Dados  Pessoais (“LGPD”) applies, have rights set forth in Article 18 of the LGPD.
• Canada. As used in this Policy, “applicable law” includes the Federal Personal Information Protection and Electronic Documents Act (PIPEDA) and “Personal Data” includes “personal information” as defined under PIPEDA.
• EEA and UK. To exercise your rights, you may contact our DPO. If you are a resident of the EEA or if we have identified Stripe Payments Europe Limited as your data controller, and you believe our  processing of your information is not in line with the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Irish Data Protection Commission. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. Where Personal Data is used for regulated financial activities in Europe, Stripe Payments Europe Limited and Stripe local regulated entities (defined as those who are licensed, authorized or registered by a Local Regulatory Authority) are considered joint controllers. Learn More.
• India. If you have any questions or complaints regarding the processing of your Personal Data in India, please contact our Nodal and Grievance Officer here. Learn More.
• Indonesia. As used in this Policy, “applicable law” includes Law No. 11 of 2008 as amended by Law No. 19 of 2016 on Electronic Information and Transactions, Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions, and Minister of Communication and Informatics Regulation No. 20 of 2016 on Personal Data Protection in Electronic Systems and “Personal Data” includes “personal data” as defined under such laws. 
• Japan.When we transfer Personal Data of data subjects in Japan to jurisdictions that are not recognized as ‘adequate’ by the Personal Information Protection Commission, we enter into written agreements with any third parties located outside of Japan. These written agreements provide rights and obligations equivalent to those provided under the Japanese Act on the Protection of Personal Information. For more information on how we ensure that third parties protect your data and where your data is located, please see above or contact us as described below. For a description of foreign systems and frameworks that may affect the implementation of equivalent measures by the third party, see here.
• Malaysia. If you have any questions or complaints about this Policy, please contact our DPO.
• Switzerland. As used in this Policy, “applicable law” includes the Swiss Federal Act on Data Protection (FADP), as revised. To exercise your rights under the FADP, please contact our DPO.
• Thailand. If we process your Personal Data due to a legal obligation or contractual right and you do not provide us with personal Information, we may not be able to lawfully provide you services.
• United States - California. If you are a consumer located in California, we process your personal information in accordance with California law (e.g. the "CCPA"). For specific details, please see here. Stripe uses cookies, including advertising cookies, as described in our Cookie Policy.
  • Your Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information (learn more about data subject rights metrics). In addition to the above rights (see here), please note these other California-specific rights:
    • Exercising the right to know: You have a right to request additional information about the categories of  personal information collected, sold, disclosed, or shared; purposes for which this personal information was collected, sold, or shared; categories of sources of personal information; and categories of third parties with whom we disclosed or shared this personal information.
    • Exercising the right to opt-out from a sale: We do not sell “Personal Information” as defined by the CCPA and have not done so in the past 12 months.
    • Exercising the right to limit the use or sharing of Sensitive Personal Information: we do not sell or share Sensitive Personal Information as defined by the CCPA and have not done so in the past 12 months. Learn more about our collection and use of Sensitive Personal Information here.
    • Right to opt-out of sharing of cross-context behavioral advertising. Learn more here and here.
  • To submit a request to exercise any of the rights described above, please contact us using the methods described in the Contact Us section below. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your identity, including name, address, transaction history, photo identification, and other information associated with your account.
  • You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Your agent may submit a request on your behalf by contacting us using the methods described in the Contact Us section below. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.
  • Do Not Track and signals. Learn more about how we honor “do not track” and other signals.

9. Contact us

If you have any questions or complaints about this Policy, please contact us. If you are an End Customer (i.e. an individual doing business or transacting with a Business User), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly.

 

 

Privacy Statement of myPOS

 

Privacy policy

Effective as of 25.05.2018

Last update: 23.03.2023

I. Why should you read this Privacy Policy?

myPOS is committed to the principles of personal data protection laid down in European and UK law and recognizes the importance of safeguarding its customers’ information. We are constantly improving our data processing activities and our privacy notices in order to provide you with as much transparency over the way we handle your data as we can. This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of myPOS Service.

If you have concerns about how we use your personal information, you can contact our data protection officer at [email protected].

If you are unsure about the meaning of any term used in this Privacy Policy (such as “myPOS Account” or “myPOS Card”), you may check the definition in the other legal documents regulating the myPOS Service to all of which this Privacy Policy is inseparable part.

If you see an undefined term in this Privacy Policy (such as “myPOS Account” or “myPOS Card”), it has the same definition as in our Legal Agreement for myPOS Account, Legal Agreement for myPOS Card, Merchant Agreement or other legal documents regulating myPOS Service to all of which this Privacy Policy is inseparable part.

1.1. About us.

When this policy mentions “we,” “us,” or “our,” it refers to myPOS or an Affiliate of myPOS, which are responsible for your information under this Privacy Policy. The specific responsible entity for your personal data may vary for the different services provided though the myPOS Service. The responsible entity in each case is referred to as the “Data Controller”.

1.2. The myPOS Service.

For the purposes of this documents myPOS Services consist of products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us or mobile apps, online platform, official social media platforms, or other online properties through which we provide payment and e-money services.

myPOS Service is designed for business purposes and may be used by individuals or entities. In case you are registering for and/or using myPOS Services on behalf of an entity we will treat you as authorized person and you may be obliged to disclose to us personal data of the legal representatives, the employees, the agents, the beneficial owners or any other third-party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person beside yourself you have received prior consent from that other person to provide their personal information to us.

Тhe present Privacy Policy grants rights which only natural persons, related in any way to a myPOS client, may benefit from. Whenever we use “you”, “your” or similar, the persons which we refer to are the natural persons which are involved in any way with the information of the myPOS Client, which may be the representatives, the beneficial owners, the authorized persons or other similar and in case the myPOS Client is a sole trader or similar.

This Privacy Policy also applies to the information that is collected and used in relation to myPOS Online Store pursuant to Conditions of Use myPOS Online Store.

This Privacy Policy also applies to the information that is collected and used in relation to provision of the myPOS Online functionality for establishing online shops on our domains pursuant to General terms and Conditions for myPOS Online.

When using myPOS Online, there are two main categories of data subjects that we process data for:

1. Merchants (when they are natural persons), who create their own online shops through the myPOS Online functionality for the purpose of selling their goods and services to customers online – the below table of processing activities applies for these types of data subjecfts; and

2. Visitors of the, who may visit and review the goods and services of the Merchants in their online shops created on myPOS.site. Please refer to the Specific data processing section below for further information about the data we are processing for visitors of the myPOS online sites of our merchants

II. How do we process your personal information?

2.1. What information do we process about you?

You are informed that there are two general categories of information that is collected from you differentiated on grounds as defined by the Regulation 2016/679 and other applicable data protection national laws.

a. Information which we collect when you use our payment and financial services;

b. Information that we collect for other purposes, such as operating our myPOS Store or providing you with any of our linked services.

III. Information that we process in relation to our Services.

We may ask for and collect from you the following personal information when you use the myPOS Service:

Type of personal dataPurpose of processingLegal grounds under GDPRWhat third-party processors can we use for this?Names (First Name, Surname, Last Name)Opening your account and maintaining our legal relationshipsOur contract with you or in order to take steps prior to entering into a contract; defense of our legal claimsOur auditors; legal or other similar counsels; debt collection agencies; accounting outsourcing providers; support outsourcing providers including our distributors.MarketingOur legitimate interestsMarketing services providers.Providing supportOur contract with youSupport outsourcing providers including our distributorsCross-sales marketingYour consentIn case there is a third-party processor, you will be provided with information about them in the consent form.Facilitating our social featuresOur legitimate interests in developing the Platform and drive user interactionOther users of the ServiceFacilitating your payment transactionsCompliance with legal obligations; Our contract with youCorrespondent banks; financial institutions that we have contracted to enable us to provide effectively myPOS Service to our customers; auditors; legal or other similar counsels; regulatorsDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsDate and place of birthOpening your account and maintaining our legal relationshipsOur contract with you or in order to take steps prior to entering into a contractOur auditors; legal or other similar counsels; accounting outsourcing providers; support outsourcing providers including our distributors.MarketingOur legitimate interestsMarketing services providers.Providing supportOur contract with youSupport outsourcing providers including our distributorsCross-sales marketingYour consentIn case there is a third-party processor, you will be provided with information about them in the consent form.Facilitating your payment transactionsCompliance with legal obligations; Our contract with youCorrespondent banks; financial institutions that we have contracted to enable us to provide effectively myPOS Service to our customers; auditors; legal or other similar counsels; regulatorsDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsPhone numberOpening your account and maintaining our legal relationshipsOur contract with you or in order to take steps prior to entering into a contract;Legal or other similar counsels; support outsourcing providers including our distributorsMarketingOur legitimate interestsMarketing services providersProviding supportPerformance our contractSupport outsourcing providers including our distributorsCross-sales marketingYour consentIn case there is a third-party processor, you will be provided with information about them in the consent form.Facilitating login to our platformOur contract with youNone;Risk and compliance analysis and actionCompliance with legal obligations.Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators;Customer authenticationCompliance with legal obligationsCommunication service providers; legal or other similar counsels; support outsourcing providers including our distributorsCommunicating important messages regarding the ServiceCompliance with legal obligationsCommunication service providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsEnforce our legal claims arising from any chargebacks, negative balance or similar obligation towards usExercise or defence of our legal claimslawyers; debt collection agencies; competent courts, arbitration tribunals and similarNationalityOpening your account and maintaining our legal relationshipsOur contract with you or in order to take steps prior to entering into a contractOur auditors; legal or other similar counsels; accounting outsourcing providers; support outsourcing providers including our distributorsDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsEmailOpening your account and maintaining our legal relationshipsOur contract with you or in order to take steps prior to entering into a contract;Legal or other similar counsels; email verification providers, support outsourcing providers including our distributorsMarketingOur legitimate interestsMarketing services providersProviding supportOur contract with youSupport outsourcing providers including our distributorsCross-sales marketingYour consentIn case there is a third-party processor, you will be provided with information about them in the consent formFacilitating login to our platformOur contract with youNoneDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsCommunicating important messages regarding the ServiceCompliance with legal obligationsCommunication service providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsEnforce our legal claims arising from any chargebacks, negative balance or similar obligation towards usExercise or defence of our legal claimslawyers; debt collection agencies; competent courts, arbitration tribunals and similarRegistered addressOpening your account and maintaining our legal relationshipsOur contract with you or in order to take steps prior to entering into a contract; defence of our legal claimsOur auditors; legal or other similar counsels; debt collection agencies; accounting outsourcing providers; support outsourcing providers including our distributors; competent authoritiesDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsFacilitating your payment transactionsCompliance with legal obligations; Our contract with youCorrespondent banks; financial institutions of your payee; top-up providers; auditors; legal or other similar counsels; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsOfficial ID Document, type of ID and all data contained in itOpening your account and maintaining our legal relationshipsOur contract with you or in order to take steps prior to entering into a contract; defence of our legal claimsOur auditors; legal or other similar counsels; debt collection agencies; accounting outsourcing providers; support outsourcing providers including our distributors; competent authoritiesDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsFacilitating your payment transactionsCompliance with legal obligations; Our contract with youCorrespondent banks; financial institutions of your payee; top-up providers; auditors; legal or other similar counsels; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsIdentity Verification Information (recordings of your video call (if applicable) with our staff and/or verification selfie; photographs of the user registering for myPOS Service; photographs of a passport or of the front and rear sides of any other official ID document – yours or the document of the person, who is opening the account)Due diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulators.Risk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsInformation about your tax statusDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsSource of income, annual estimate over the account, business activity detailsDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsMarketingLegitimate interestsMarketing services providers; marketing consultants; SEO and other similar software or consultancy providers; other similar providersRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsTurnoverDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsMarketingLegitimate interestsMarketing services providers; marketing consultants; SEO and other similar software or consultancy providers; other similar providersRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsDevice ID and log dataDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; regulatorsCustomer authenticationCompliance with legal obligationsCommunication service providers; legal or other similar counsels; support outsourcing providers including our distributorsDetect and prevent fraud, spam, abuse, security incidents, and other harmful activityLegitimate interestsSupport outsourcing providers including our distributors; software outsourcing providers; legal or other similar counsels; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsFacilitating use of our platformsOur contract with youNoneLocationDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsLogin credentialsCustomer authenticationCompliance with legal obligationsNoneFacilitating use of our platformOur contract with youNoneProviding supportOur contract with youSupport outsourcing providers including our distributorsContact listProviding you with an easy way to access certain features of the myPOS, like sending payment requests or payment links with myPOS ServiceYour consentNoneData, collected in relation to interactions with our AppFacilitating use of our platformOur contract with youNonePersonalize, Measure, and Improve our Advertising and MarketingOur legitimate interestsMarketing services providersOperate, protect, improve, and optimize the myPOS Service and your experience, such as by performing analytics and conducting researchOur legitimate interestsMarketing services providersProviding supportOur contract with youSupport outsourcing providers including our distributorsData, collected in relation to interactions with our support teamProviding supportOur contract with youSupport outsourcing providers including our distributorsRisk and compliance analysis and actionCompliance with legal obligations.Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsData, collected in relation to interactions with our Social media channelsPersonalize, Measure, and Improve our Advertising and Marketing; Review and use of public comments and opinions made on social networking sites (e.g. Facebook and Twitter) to better understand our customers and our provision and development of myPOS ServiceOur legitimate interestsMarketing services providers; marketing consultants; SEO and other similar software or consultancy providers; other similar providersData, provided in relation to participations in games, quizzes and completion of questionnaire or a contest entry form for promotional campaignsProvide you with the option to participate in the respective eventYour consentMarketing services providersPersonalize, Measure, and Improve our Advertising and MarketingYour consentMarketing services providersGeolocation (only if activated by you in the mobile app)Customer authenticationCompliance with legal obligationsCommunication service providers; legal or other similar counsels; support outsourcing providers including our distributors; regulatorsDetect and prevent fraud, abuse, security incidents, and other harmful activity by blocking myPOS Service or by applying other fraud prevention measuresLegal obligationsSoftware outsourcing providers; compliance outsourcing providers; PEN test and other similar auditors; PCI DSS auditors; legal counsels; other similar consultantsProviding you location-based servicesYour consentSupport outsourcing providers including our distributorsRisk and compliance analysis and actionCompliance with legal obligations.Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsUsage InformationCollection of crash reports and other statistical informationOur legitimate interestSupport outsourcing providers including our distributorsAnalysing our app’s performance and user experienceOur legitimate interestThird-party development or implementation providers (anonymized data only);Delivery addressDelivering of products/documents, such as POS terminals; MarketingOur contract with youCompetent Authorities, Auditors, Law Firms, Courier CompaniesProof of address or other verification data, which we may request depending on your particular situationDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsShareholding information in your organisationDue diligenceCompliance with legal obligationsOur auditors; legal or other similar counsels; compliance outsourcing providers; regulatorsRisk and compliance analysis and actionCompliance with legal obligationsBlacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulatorsPayment Transaction and other Account data, use of our e-money and payment service, including IBAN and Wallet IDs and balance.Initiate a payment, send or request money, acceptance of card payment, funding transaction of your myPOS accountOur contract with youOther participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; regulatorsAuthenticate your access to your myPOS Account or your payment instrumentOur contract with youOther participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; regulatorsCommunicate with you about your myPOS Account and payment instrumentsOur contract with youOther participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; regulatorsCreate an account connection between your Account and a third-party account or platform, if applicableOur contract with youOther participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; regulatorsPerform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposesLegitimate interests and in some situations – legal obligationCredit bureaus; database operators; legal consultants; regulatorsDetect and prevent fraud, abuse, security incidents, and other harmful activity by blocking myPOS Service or by applying other fraud prevention measuresCompliance with legal obligationsSoftware outsourcing providers; compliance outsourcing providers; PEN test and other similar auditors; PCI DSS auditors; legal counsels; other similar consultantsComply with any legal enforcement or authority requestCompliance with legal obligationsYour counterparties, bailiffs, courts, regulators, lawyers, insolvency practitioners, liquidators, debt collection agencies, arbitration tribunals and other similar persons that might have a claim or are servicing one against you, or have initiated a valid legal proceeding against youEnforce our legal claims arising from any chargebacks, negative balance or similar obligation towards usExercise or defence of our legal claimslawyers; debt collection agencies; competent courts, arbitration tribunals and similarInformation in relation to the provision, improvement and development of the myPOS Service and myPOS Online StoreAccept, process and administer online orders for myPOS TerminalsOur contract with youOur distribution network; outsourcing providers; our consultantsProcess purchase payments, issue invoices and or other kind of payment documents for the processed order;Our contract with you; Our legal obligationsOur distribution network; outsourcing providers; our consultantsTo organize shipment of ordered myPOS TerminalOur contract with youOur distribution network; outsourcing providers; our consultantsTo manage return procedure and refunds for defected devicesOur contract with youOur distribution network; outsourcing providers; our consultantsSpecific client identifiers, and, where applicable, other data such as registered address for a particular service and other similarInitiate a payment, send or request money, acceptance of card payments, top-up, payments toward specific merchants or entitiesOur contract with youOther participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; top-up providers; specific merchants or entities; regulatorsCookies and other tracking technologiesThe use of cookies and other tracking technologies is described in our Cookie Policy

IV. Specific data processing cases.

In any case, we may share any of your information for specific reasons, outlined below:

1. With other members of the myPOS or iCard AD’s corporate family: We may share your Personal Data with members of the myPOS or iCard Group of companies or within our extended family of companies that are related by common ownership or control, so that we may provide the Services you have requested or authorized or to manage the risk, or to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of myPOS Services and communications.

2. With our distributors: We may share information related to you or your company with our distributors, which help us to provide you with the best myPOS experience. Our distributors may help us in onboarding you or your company, with your transactions, myPOS terminal orders and other similar activities, for which they may process some of your personal information.

3. Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4. With our legal counsels for the purposes of protecting our legal rights. We may share any information which is necessary to protect our legal rights to legal counsels or similar parties.

5. Monitoring. We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes. When visiting our offices, CCTV, access control systems and/or other monitoring systems may be in operation.

6. Business Transfers. If any of the companies that provides myPOS Services is involved in any merger, acquisition, reorganization, sale of assets, transfer of portfolio, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred to a different legal person and/or becomes subject to a different privacy policy.

7. Credit offerings. In some markets, we may have provided the option to receive credits/loans from third-party loan provides through the myPOS platform.

Where we have shown a pre-approval for a specific loan in your myPOS account, this has been done solely on anonymized data shared to such third-party loan providers. Therefore, these loan providers do not hold any personal data about you or the persons related to your business at the pre-approval stage.

However, in case you decide to enter into a relationship with said third-party loan provides through the myPOS platform, we will share certain information about you and your use of the myPOS service to these loan providers, namely:

• any information that is required by the loan provider for “Know-your-customer” purposes, which may include any copies of official ID documents of you and the persons related to your business, UBO information, etc.
• in case you are operating your business as a as a natural person, certain transactional data, such as your historic transactional volumes and types of transactions or the transactions themselves, for the last 12 to 24 months. This data is not considered personal if you are operating as a legal entity.
• Other related information, as explained in the third-party loan provider’s own privacy policy or notice, which you will be provided with during the process of credit approvement.

Please be aware that after you have agreed with the relevant terms and conditions of the third-party loan provider and we have consequently forwarded the abovementioned personal data to such third-party loan provider, it will process your personal data as a data controller according to their own privacy policy or notice, which shall be made available to you as explained above. We are not responsible for any further processing done by such third-party loan provider(s) and you should address any complaints related to their use of your data to said third-party loan provider(s).

8. myPOS Online. We process information about the visitors and clients of the myPOS online website, which we provide for our merchants, by storing particular data that is being generated when said visitors and clients are accessing and using the website. These types of data may include:

a) Log data and Device ID;

b) Data, required for creating and maintaining an account – names, email, telephone number and other similar;

c) Data related to purchases;

d) Other types of data, as described in the particular myPOS Online website

The processing that is being carried by us in this regard, is made in our capacity of data processor, acting on behalf of the data controller – the respective myPOS merchant, for whom the myPOS Online website is generated and supported. The specific types of data, which are being processed by the controller, as well as any other legally required information, should be included in the privacy policy of the respective myPOS Online website, which is a responsibility of the particular data controller. We shall not bear any liability whatsoever for any omissions or non-compliance with the applicable legislation, for which the data controller (myPOS merchant) is responsible.

We do not process in any other way these types of data – we only store this information on behalf of the respective myPOS merchant.

V. Decisions based solely on automated processing.

Sometimes, our systems may take decisions based solely on automated processing. This does not mean that we will always use automated decision making for these processing activities. In case you believe that you have been unfairly treated by our automated decision-making systems you may ask that a person reviews the decision at all times by contacting us as described in the “How do I complain?” section. Such decisions may be done for processing activities that include:

Processing activityAutomated processing logic

Detect and prevent fraud, abuse, security incidents, and other harmful activity by blocking myPOS Service or by applying other fraud prevention measures.

Our fraud-prevention and monitoring systems may sometimes take automated decisions in regards to suspicious behavior. For example, we may block a certain transaction which was made in a remote part of the world just a few minutes after your last login from your home country.

VI. Information collected about you from third parties.

We may ask certain entities for information about you when you are enrolling for our services.

Such entities are generally fraud prevention agencies and Know Your Customer and Anti Money Laundering Checkup service providers which help us to fulfil our legal obligations for due diligence on our customers.

We may also collect information about you from public sources for Anti Money Laundering reasons or market research. This includes:

1. official public records, like your national Company register;
2. information published by the press or on social media.

In case you use any of the linked services, provided by one of our partners, such as the insurance services, they may share details with us about your deal.

VII. Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information to provide myPOS Service to you, you can request that we erase your personal information and close your myPOS Account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevent us by law to close your account or terminate the Service. In case the Data Controller is a regulated financial institution, such as credit institution, E-money institution or similar, such Data Controller is obliged under PSD and AML laws to keep your personal information and all transactions history for a period of 5 years after the termination of the relation with you (or where the laws of the United Kingdom of Great Britain and Northern Ireland are applicable – for a period of 6 years). Please note that if you request the erasure of your personal information:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing security. For example, if we suspend a myPOS Account for fraud or safety reasons, we may retain certain information from that myPOS Account to prevent that client from opening a new myPOS Account in the future. We are also obliged to retain personal data which we have collected for the purposes of complying with the relevant anti-money laundering and anti-terrorism financing for a period as defined under the applicable law.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, myPOS may keep some of your information for tax, legal reporting and auditing obligations.

Because we maintain our records in a manner protecting from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

In case you started bud did not finish an application for a myPOS account on the myPOS platform, we will retain your contact information for a period of 12 months after the creation, based on our legitimate interests. During this period, we will try to help you finish your application by sending you helpful emails, reminders and, in some cases, discounts. You can unsubscribe from these emails by clicking the unsubscribe button on any of them, found in the footer, or contacting us at [email protected]

VIII. Your rights.

You may exercise any of the rights described in this section before the respective Data Controller pursuant to the Legal Agreements by sending an email from your e-mail registered for myPOS Service to the respective Company providing the Service to you under the respective Legal Agreement stated below. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.

8.1. Managing Your Information.

You have the right to obtain the following:

• confirmation of whether and where we are processing your personal data;
• information about the purposes of the processing;
• information about the categories of data being processed;
• information about the categories of recipients with whom the data may be shared;
• information about the period for which the data will be stored (or the criteria used to determine that period);
• information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing;
• information about the existence of the right to complain to any Regulator;
• where the data was not collected from you, information as to the source of the data; and
• information about the existence of, and an explanation of the logic involved in, any automated processing.
• Additionally, you may request a copy of the personal data being processed.

8.2. Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to myPOS Account).

8.3. Data Access and Portability.

You have the right to:

• receive a copy of your personal data in a structured, commonly used, machine-readable format that supports re-use;
• transfer your personal data from one controller to another;
• store your personal data for further personal use on a private device; and
• have your personal data transmitted directly between controllers without hindrance.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.

Because we maintain the myPOS to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

8.4. Withdrawing Consent and Restriction of Processing.

Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.

8.5. Objection to Processing.

In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling for marketing purposes) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims. Please note that Data Controllers which are regulated financial institutions, such as credit institutions, E-money institutions or similar are obliged under AML laws to make risk profiling of their customers upon opening of the relationship and constantly during the relationship and this is a legitimate reason. In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, you shall have to close your account or we may have to stop providing you some or all of the Services, subject to all conditions for the closing of the account, specified above in this Section.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us.

Please bear in mind that irrespective of your opt-out, related to marketing messages, you will still continue to receive specific messages, which we are required to send you under the applicable legislation, insofar as you still have a legal relationship with us.

8.6. How do I complain?

You should in first place try to resolve the matter by sending an e-mail to the respective Data Controller under this Privacy Policy from your registered e-mail for the Service:

Where the responsible Data Controller (as outlined in the introduction of the Privacy Policy) is specified to be myPOS Payments Ltd, UK you may contact us at:

Data Protection Officer (DPO):
[email protected]
myPOS Payments Ltd
The Shard, Level 24
32 London Bridge Street
London,
SE1 9SG

Where the responsible Data Controller (as outlined in the introduction of the Privacy Policy) is specified to be iCard AD, Bulgaria, you may contact us at:

Data Protection Officer (DPO):
[email protected]
iCARD AD
Business Park Varna No B1, Varna 9023, Bulgaria

Where the responsible Data Controller (as outlined in the introduction of the Privacy Policy) is specified to be myPOS Services OOD you may contact us at:

Data Protection Officer (DPO):
[email protected]
myPOS Services OOD
Business Park Varna No B1, Varna 9023, Bulgaria

Competent Regulator. In case you are not satisfied with the reply or resolution of the respective Data Controller, you have the right to lodge complaints about the data processing activities carried out by us before the competent data protection supervisory authorities as described below.

If the Data Controller responsible for the respective data processing, subject to your complaint, is myPOS Payments Ltd. UK you have the right to file a complaint with its lead supervisory authority, the Information Commissioners Office, UK:

Address:
Wycliffe House
Water Lane
Willmslow
Cheshire
SK9 5AF
e-mail: [email protected]

If the Data Controller responsible for the respective data processing, subject to your complaint, is iCard AD, Bulgaria you have the right to file a complaint with its lead supervisory authority, Commission for Protection of Personal Data, Bulgaria:

Address:
Sofia 1592
2 Prof. Tsvetan Lazarov blvd.
e-mail: [email protected]

If the Data Controller responsible for the respective data processing, subject to your complaint, is myPOS Services OOD, Bulgaria you have the right to file a complaint with its lead supervisory authority, the Commission for Protection of Personal Data, Bulgaria:

Address:
Sofia 1592
2 Prof. Tsvetan Lazarov blvd.
e-mail: [email protected]

IX. Operating globally.

To facilitate our global operations we may be required to transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer store and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

X. International transfers.

10.1. Adequacy Decisions.

Where we disclose any of your collected personal information outside EEA, we shall comply with any relevant adequacy decision, where possible.

10.2. Other Means to Ensure an Adequate Level of Data Protection.

In case personal information is shared with corporate affiliates or third-party service providers outside the EEA in absence of an adequacy decision, we have - prior to sharing your information with such corporate affiliate or third-party service provider – established the necessary means to ensure an adequate level of data protection and a valid legal ground under the applicable data transfer rules. We will provide further information on the means to ensure an adequate level of data protection on request.

Protection of personal data transferred from or to the United Kingdom of Great Britain and Northern Ireland:

myPOS is a pan-European company, with operations both in the UK and EEA. Where we transfer any of your collected personal data from or to UK we shall comply with the Decision on the adequate protection of personal data by the United Kingdom - General Data Protection Regulation, dated 28 June 2021.

XI. Security.

We take the responsibility to ensure that your personal information is secure, kept in an encrypted from on servers, collocated in Special data centers in Class A jurisdictions in Europe. To prevent unauthorized access or disclosure of information we maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard non-public personal information. Once you are logged into your Account, all internet communication is secured using Secure Socket Layer (SSL) technology with High-grade security Encryption (AES-256, 256 bit keys, certified by StartCom Ltd). We restrict access to your personally identifiable information only to employees who need to know that information in order to provide products or services to you.

If you know or have reason to believe that your myPOS Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your myPOS Account, please contact us following the instructions in the Contact Us section below. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.

XII. Can Children Use Our Services?

myPOS Service is not designed to individuals under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use myPOS Service. If we obtain actual knowledge that we have collected Personal Data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.

XIII. Changes to this privacy policy.

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on myPOS Platform. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of myPOS Platform will be subject to the revised Privacy Policy.

XIV. Contact us.

If you have any questions or complaints about this Privacy Policy or our information handling practices, you may email us from your registered e-mail for the Services to the e-mails stated above in pt. 8.6 (How do I Complain).