Privacy Policy

We are committed to protecting the privacy of the users of our services. We respect your personal information and for this reason, we have developed this policy to govern our processing of your personal information. This document sets out:

How we collect personal information;
What types of personal information we collect and hold about you;
The purposes for which we use such personal information;
Your rights with respect to the personal information held by us.

Who we are

When we refer to “we”, “us” or “our” herein we are referring to companies forming part of the Paypump Group of companies globally, or any of them, as the context requires, and, specifically, any company within the Paypump Group that is involved in providing services to you. You can find out more about us at www.paypump.net.

Whose information we protect

When we refer to “you” or “your” herein we are referring to you, the applicant for, user or past user of our services.

How we collect information

We collect information about you directly from you as well from third parties and publicly accessible sources in certain cases. The means and sources we use to collect information about you is as follows:

From you, including when you enquire about or apply for or use our services;
From public registers, credit bureaus, money laundering, fraud prevention and law enforcement agencies;
From business partners that introduce you to us and from service providers and other persons that are involved in enabling or engaged during the performance of our services, which may include your bank and beneficiaries, verification service providers, card schemes, credit reference agencies, debt collection agencies and providers of data services;
From other persons or entities which may be legally entitled to provide us with information about you; and
From persons or entities which you may consent to providing us with information about you.

Information we hold about you

We may record and hold the following types of information about you:

Details of when you contact us and when we contact you, including your residential address, IP address, email address and telephone numbers as well as the content of the communications between us, which we may record;
All information contained in the forms, documents, requests or instructions you submit to us, whether online, via electronic mail, telephonically or using other means, including all regarding the transactions executed on your accounts;
Details about you and your beneficiaries which you provide to us to register with us or that are collected or arise in the course of our services, including names, places of residence and nationality, national identifiers, account details, sources of funds and payment details;
Information received pursuant to our enquiries with our business partners that introduced you to us, your bank, verification service providers, regulatory authorities, public registers, card schemes, credit reference agencies, money laundering, fraud prevention and/or law enforcement agencies, including regarding your financial and criminal status, record and history and whether you or your designated beneficiary has been sanctioned or a politically exposed person; and
Details of your usage and preferences regarding our services and offerings, including regarding how you access and use our services and your service-related enquiries.

We may hold your personal information for up to 5 years from the date of collection, or during the term of your subscription to our services and for up to 5 years thereafter, as the case may be. We may keep your personal information for longer periods if it is necessary to do so for legal or technical reasons. In any case we shall not hold your personal information for a period which exceeds the maximum permitted by law.

The purposes for which we use your personal information

Some of the information that we collect about you, as may be identified below, we need to process your application for or instructions in using our services, comply with our legal obligations or exercise our legal rights under the arrangements we have with you. If we do not have the right to use such information it will not be possible for you to make use of our services or for us to process your requests related thereto and we may have to cancel our services to you. Such information includes:

Your name, date of birth, place of residence, nationality, national identification numbers, contact details, bank account details, tax identification number, legal status and source of funds;
Your preferences regarding our services which you make use of or have made enquiries about;
Account details, beneficiary details and details of the service instructions that you submit;
Detail of all payments facilitated for you via our services, including amounts and beneficiaries involved;
The information about you which we have received from business partners that introduced you to us or from your bank, or from regulatory authorities, public registers, card schemes, credit reference agencies, money laundering, fraud prevention and/or law enforcement agencies, including regarding your financial and criminal status, record and history and whether you or your designated beneficiary has been sanctioned or a politically exposed person; and
The information that verification service providers and other business partners provide to us to confirm that the information which we hold about you and your beneficiaries is accurate, complete and up to date.

Other information about you which we hold and that we do not need for purposes of providing our services to you, and which we make use of based on your consent, will be used by us only for the purposes as consented to by you and for such other purposes as may be provided for under applicable law.

You consent that we may collect and process your information for the following purposes:

To assess your application for and register you for our services and making related decisions, including to open, maintain, manage and close service accounts for you, and to verify and update the details you have provided to us, and to confirm that you are and remain eligible for our services;
To manage our relationships with you and communicate with you and with third parties designated by you such as your bank and service beneficiaries;
To deliver our services and process and execute service-related instructions, which may involve cross border transfers of your personal information and the processing of your personal information in different jurisdictions;
To prevent our services from being used in an unlawful or prohibited manner, including through monitoring and compliance checks;
To comply with legal and regulatory requirements, including for reporting to regulatory authorities and supporting law enforcement;
To protect our interests and your interests and/or that of our group members, business partners and/or service partners;
To exercise our legal rights and comply with our legal obligations, including by maintaining records for evidentiary purposes for use in any legal process;
By sharing your personal information with our group entities, business partners and service partners, who may be located outside the countries where you reside or we are established. We require our partners to protect your personal information at least to the same extent as we do;
To improve our service offerings, and for training and quality assurance;
To conduct market research and business analysis and generate information that does not identify you, but that tells us more about client preferences and trends, which we may share with business partners;
To inform and provide you with the opportunity to make use of products, services and benefits that we offer and that we believe may be of interest to you unless you elect not to receive such communications; and
For such other purposes as you may consent to or may otherwise be lawfully permitted.

Please note that we will not contact you telephonically for unsolicited marketing purposes or send unsolicited marketing communications to you if you have objected to receiving such communications by way of a public register recognised for such purposes by law or by notifying us of your objection in the prescribed manner. We will provide you with the opportunity to object to receiving marketing communications, including upon your application for services and when we send you such communications.

Sharing your information

Keeping your personal and financial information secure is one of our most important responsibilities. We cannot disclose your information unless legally permitted thereto. Save as set out below, we will not transfer your information to a third party without your consent unless legally obliged thereto. You agree that we may transfer your information to the following people and organisations, who may be located in different jurisdictions, for the purposes set out in this policy:

To all persons employed or contracted by us, including to the directors, employees, contractors, agents, auditors, officers, debt collectors, legal and other professional advisors of any of our group companies;
To governmental, judicial, regulatory and law enforcement bodies and agencies, including tax authorities, regulators of our services and central banks;
To persons designated by you for purposes of your use of the services such as your designated beneficiaries and your bank;
To our partner banks, card schemes and our other business partners and service partners involved in facilitating the services, including in executing your service requests, monitoring the services and reporting on the services to regulatory authorities;
To service providers that are engaged by us to assist us in rendering the services, including the communications providers and data processors used by us and the providers we use to verify your details or status or that of a beneficiary, including financial or criminal status and whether you or your designated beneficiary is a sanctioned or politically exposed person;
To any person to whom we subcontract, cede, delegate, transfer or assign any of our rights or obligations pertaining to the services provided to you;
To credit reference and fraud prevention agencies;
To any person that acts as your legal guardian, executor of your estate, curator or in a similar capacity;
To such other persons as may be permitted by applicable law or that you may consent to.

If we share your personal information with our group entities, business partners or service partners that are located in other jurisdictions, we require them to protect your personal information at least to the same extent as we do in compliance with applicable law.

Security

We will strive at all times to ensure that your records will always be protected against unauthorised or accidental access, processing or loss. We maintain this commitment to data security by implementing suitable technical and organisational measures to safeguard and secure your information. If we use a third party to process your data on our behalf we will require that such third party also commit to implementing suitable technical and organisational measures to safeguard and secure your information. If we are not prevented by law, we will notify you without undue delay if we believe that unauthorised access to your information may have occurred, providing you with such information as you may reasonably require to take mitigating steps.

Web Sites

When you visit our web site we may collect certain information about your usage preferences and history. Such information may be stored in a cookie on your computer’s hard drive by your web browser. Cookies are intended to assist and improve your use of our web sites. Most browsers accept cookies automatically, but usually you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you may not be able to use all of the features of our site.

Every time you connect to our web sites we store web server logs which show your IP address (the unique number which your machine uses when it is connected to the Internet); what you looked at; whether the page request was successful or not, and which browser you used to view the pages. The use of this data is strictly for statistical and personalisation purposes only. This helps us understand which areas of the site are of particular interest and also which pages are not being requested. It also tells us how many hits and page requests we get.

Your rights regarding your information

Provided that you give us suitable and adequate proof of your identity, you have the right:

To know which records we hold about you and be provided with access to a copy thereof;
If our right to process your personal information is based on your consent, to withdraw such consent at any time, on the understanding that this shall not affect processing which occurred prior to such withdrawal, and that we may be unable to continue rendering services to you that are affected by such withdrawal;
To object to the further collection, use, sharing or processing of your personal information by us if such activities are not required by us to comply with our obligations under any agreement we have with you, to exercise our rights, or for such other purposes as may be required or permitted by applicable law; and
To require us to correct, erase or cease processing information or records we hold about you based on your consent, or that we are no longer permitted to retain, or which are inaccurate, irrelevant, excessive, out of date, incomplete, misleading or have been unlawfully obtained;
To request us to provide digital copies of records of your personal information for your own personal use;
To be informed of any profiling of you and of any automated decisions we may make about you, and you may challenge any such automated decisions and require a human to review such decisions;

Any of the above can be done by contacting us directly by any means provided by us, including by submitting a written request to us via email at info@paypump.net. We will notify you of the steps taken as a result of your request. We will not be obliged to provide you with information or agree to your request to the extent that we are prohibited thereto by applicable law, if compliance would unreasonably prejudice our legitimate interests or that of a third party, or if we have a legal basis upon which to deny your request. Please note that we may require a reasonable period to comply with your request.

Complaints

Please notify us immediately at info@paypump.net or call us at ___________________________ if you have any concerns about the processing of your personal information or wish to exercise your rights regarding your information. We may monitor or record your calls. You can contact our Group Data Protection Officer by writing to the following address: __________________________.

If your concerns are not satisfactorily resolved, you may lodge a complaint with the regulator having jurisdiction, which shall be the Information Commissioner for the Isle of Man.