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Privacy Policy

Last updated on 28 September 2018.

This website and any of our applications are operated by Paymentsense Limited ("Paymentsense", "we", "us", "our").

At Paymentsense, we understand that your privacy is very important and we are committed to safeguarding the privacy of all our visitors.

Our Privacy Policy, which is set out below, explains how we will look after the information, including personal data, that we collect from you or that you provide to us and what we will do with it. Nothing in this Privacy Policy limits your legal rights in relation to your personal data.

When you visit the website or use any of our applications or provide information to us via the website or any of our applications, you are accepting and consenting to our processing of your information in accordance with this Privacy Policy, our Cookie Policy, our Terms of Use and any other contract we may have with you including, without limitation, a Merchant Services Agreement. If you do not agree to the terms set out in these terms and policies, we do not give you permission to use the website or any of our applications and you must cease to do so immediately.

Please read each of the following sections carefully to understand our views and practices regarding your personal data. Reading this Privacy Policy will allow you to make informed decisions regarding your personal data.

Please contact us if you have any questions about this Privacy Policy or the information we hold about you:

  1.  What is Personal Data?
    1.  "Personal Data", means any information about you that could be used to help identify you. The term "Personal Data" is defined more fully in Article 9 of the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR")), which you can read here. Examples of Personal Data may include: names, addresses, phone numbers, but also computer log data and other types of electronic IDs (for example, your IP address) in so far as they can be associated with a physical person.
  2.  How is Personal Data processed?
    1.  Processing of Personal Data occurs whenever any action is taken in relation to that Personal Data, regardless of whether the action is automated or not. Some common examples of processing include collection, organisation, storing and deletion.
  3.  Does this Privacy Policy cover all our processing activities?
    1.  This Privacy Policy relates only to our activities as a data controller. Paymentsense are a data controller whenever we decide how, why, and by what means Personal Data is to be processed.
  4.  In relation to whom is Paymentsense a data controller?
    1.  Merchants (customers that are sole traders/individuals)
      1.  For the purposes of data protection we consider a physical person (as opposed to a company) that is a sole trader or individual and who registers for/uses our services or buys products from us (such as a card reader) to be a "Merchant". We will process Personal Data from a Merchant when they:
        • request a quote using our Free Quote
        • register for an account with us
        • log into their account via our Billing Portal
        • log into and use their account via our applications
        • submit a request or enquiry through our Help Centre
        • subscribe to receive our newsletter (only an email address is required for this) or request any other information from us
        • submit comments or feedback for publication on the website
        • complete any voluntary surveys we may ask them to participate in from time to time;
        • participate in any competition or prize draw that we may run on the website from time to time;
        • respond to our marketing communications
        • complete enquiry forms on the website
        • correspond with us by phone, email or otherwise; or
        • report a problem with the website or one of our applications.
      2.  In addition, the following information will also be collected automatically from Merchants:
        • technical information, including the internet protocol (IP) address used to connect the computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, unique device IDs, device attributes, network connection type, network and device performance, application version; and
        • information about the Merchant’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website and applications (including date and time); products or services viewed or searched for; location data and other communications data; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any telephone number used to call our customer service number.
    2.  Executives, directors, beneficial owners and authorised signatories of corporate customers
      1.  If a customer is not a sole trader or individual (i.e. they are a company), or a business has a beneficial owner of some kind, we will process information (as data controller) about the company or business. The information we process may include Personal Data about the individuals involved with that company or business. We may process Personal Data from executives, directors, beneficial owners and authorised signatories of customers when they:
        • request a quote using our Free Quote
        • register for an account with us
        • log into their account via our Billing Portal
        • log into and use their account via our applications
        • submit a request or enquiry through our Help Centre
        • subscribe to receive our newsletter (only an email address is required for this) or request any other information from us
        • submit comments or feedback for publication on the website
        • complete any voluntary surveys we may ask them to participate in from time to time
        • participate in any competition or prize draw that we may run on the website from time to time;
        • respond to our marketing communications
        • complete enquiry forms on the website
        • correspond with us by phone, email or otherwise; or
        • report a problem with the website or one of our applications.
      2.  In addition, the following information will also be collected automatically from executives, directors, beneficial owners and authorised signatories of customers:
        • technical information, including the internet protocol (IP) address used to connect the computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, unique device IDs, device attributes, network connection type, network and device performance, application version; and
        • information about the person’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website and applications (including date and time); products or services viewed or searched for; location data and other communications data; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any telephone number used to call our customer service number.
    3.  Customer Representatives
      1.  Customers and potential customers sometimes use a representative when communicating with us via our website or otherwise. We will process Personal Data from a customer representative when they:
        • request a quote using our Free Quote form
        • submit a request or enquiry through our Help Centre
        • log into and use their account via our applications
        • subscribe to receive our newsletter (only an email address is required for this) or request any other information from us
        • submit comments or feedback for publication on the website
        • respond to our marketing communications
        • complete enquiry forms on the website
        • correspond with us by phone, email or otherwise or
        • report a problem with the website or one of our applications.
      2.  In addition, the following information will also be collected automatically from customer representatives:
        • technical information, including the internet protocol (IP) address used to connect the computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
        • information about the customer representative’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products or services viewed or searched for; location data and other communications data; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any telephone number used to call our customer service number.
    4.  End-customers
      1.  When a customer of a Merchant chooses to pay using one of our payment gateways or when a customer requests a receipt for the services provided by any of our Merchants we will process Personal Data regarding that "End customer".
    5.  Individuals contacting our customer support team or Paymentsense generally via email, phone, online chat or any other communication channel
      1.  For existing customers visiting our website or using our applications, we will, in our role as data collector, process a variety of information including location data, the identity of the device used to access the website, behaviour patterns, IP address, cookie identifiers and personal preferences.
      2.  In addition, Personal Data will be processed by us when someone telephones us, uses our website, uses our applications or otherwise contacts us through one of the available channels. As a result, an individual who is not a customer will also have their Personal Data processed. For example we may process Personal Data from an individual when they:
        • subscribe to receive our newsletter (only an email address is required for this) or request any other information from us;
        • complete enquiry forms on the website
        • correspond with us by phone, email or otherwise or
        • apply for a job with us which you have seen on our Current Vacancies
      3.  In addition, the following information will also be collected automatically from the relevant individual:
        • technical information, including the internet protocol (IP) address used to connect the computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, unique device IDs, device attributes, network connection type, network and device performance, application version; and
        • information about the individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website and applications (including date and time); products or services viewed or searched for; location data and other communications data; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any telephone number used to call our customer service number.
  5.  What information do we collect from you, for what purposes and on what legal basis?
    1.  In the case of a Merchant we will collect and process the following information:
      Category of Personal Data Non-exhaustive examples of Personal Data from each category
      Account identification information Merchant ID number, passwords and equivalent account security information
      Contact details Name, address, phone numbers, email
      Financial information Bank details, transaction history, credit history and credit score, information relevant to invoices issued by us to a Merchant
      Information required to be obtained and kept by law Information required for customer identification and verification (e.g. government issued IDs)
      Technical and behavioural tracking data IP address, location data, pages viewed on our website or applications, cookie identifiers, the types of devices you are using to access or connect to our applications, unique device IDs, device attributes, network connection type and provider, network and device performance, browser type, operating system, and application version

      The purpose and legal basis for processing the Personal Data outlined above will be:

      Purpose of processing the Personal Data Legal basis for processing the Personal Data
      To administer any account or registration you may have with us
      • To fulfil our contractual agreement with you
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To carry out our obligations arising from any contracts entered into between you and us;
      • To fulfil our contractual agreement with you
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To provide you with the products and services that you request from us;
      • To fulfil our contractual agreement with you
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To administer your participation in any competitions or prize draws we may run from time to time;
      • To pursue the legitimate interests of Paymentsense
      To provide you with our newsletter, if you have subscribed to receive it, and any other information that you request from us from time to time;
      • To pursue the legitimate interests of Paymentsense
      To communicate with you (via the use of surveys or by other means) about any comments, queries or feedback you might have about us, the website or our applications;
      • To fulfil our contractual agreement with you
      • To pursue the legitimate interests of Paymentsense
      For publication on the website (for example, in connection with your listing or advertisement or for review or testimonial purposes), but only if you have either provided it to us for that purpose or if you have consented to this;
      • To pursue the legitimate interests of Paymentsense
      • When you have provided consent
      To enable you to participate in interactive features of our website or our applications, when you choose to do so;
      • To fulfil our contractual agreement with you
      • To pursue the legitimate interests of Paymentsense
      To ensure that content on the website or in our applications is presented in the most effective manner for you and for your computer;
      • To fulfil our contractual agreement with you
      • To pursue the legitimate interests of Paymentsense
      To provide you with information about products and services we offer that we feel may interest you by post, telephone, SMS, email or via in-application notifications;
      • To pursue the legitimate interests of Paymentsense
      • Where we are required by law to obtain your consent to provide this information, we will obtain your consent. If consent is not required we will provide you an option to opt-out of receiving this information each time that we send information to you.
      To administer our site and applications and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      • To pursue the legitimate interests of Paymentsense
      To keep the website or our applications safe and secure;
      • To fulfil our contractual agreement with you
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
      • To pursue the legitimate interests of Paymentsense
      To make suggestions and recommendations to you and other users of the website and our applications about goods or services that may interest you or them;
      • To pursue the legitimate interests of Paymentsense
      To verify your identity as well as your personal and contact information;
      • To fulfil our contractual agreement with you
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To record and prove that transactions have been executed;
      • To fulfil our contractual agreement with you
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To initiate, exercise and defend any legal claim or collection procedure;
      • To fulfil our contractual agreement with you
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To comply with internal compliance procedures;
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To prevent misuse of Paymentsense’s services;
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To carry out risk management and fraud prevention processes;
      • To fulfil our contractual agreement with you
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To comply with applicable "Know Your Customer" ("KYC"), "Anti-Money Laundering" ("AML"), book-keeping and capital adequacy laws and to report to tax authorities and other relevant law enforcement agencies;
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To communicate with you in relation to our services.
      • To fulfil our contractual agreement with you
      • To pursue the legitimate interests of Paymentsense
    2.  In the case of a party that is an End-customer we will collect and process the following information:
      Category of Personal Data Non-exhaustive examples of Personal Data from each category
      Contact details Name, address, phone numbers, email
      Financial information Card details, Transaction history
      Information required to be obtained and kept by law Bookkeeping relevant information
      Technical and Behavioural tracking data IP address, location data, pages viewed on our website, cookie identifiers

      The purpose and legal basis for processing the Personal Data outlined above will be:

      Purpose of processing the Personal Data Legal basis for processing the Personal Data
      To process a payment made by the End-customer via a card or through the use of any method that Paymentsense offers from time to time.
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To ensure that the payment transaction is carried out in a secure manner, mitigating the risk of fraud and other criminal acts.
      • To comply with applicable law
      • To pursue the legitimate interests of Paymentsense
      To enable the Merchant to fulfil the End-customer’s order and mitigate the risk of fraud and other criminal acts. The Personal Data will also be processed when handling potential complaints and disputes.  
      To provide a receipt to an End-customer. We will only use the End-customer’s e-mail address or mobile number to send receipts and will not use or share the contact details for any other purpose unless we obtain the End-customer’s consent in writing, or inform the End-customer prior to processing for a new purpose or for a purpose that is compatible with the purpose for which initially we collected the Personal Data.  
       
      1.  In the case of individuals contacting our customer support team or Paymentsense generally, via email, telephone, online chat, SMS or any other communication channel, we will collect and process the following information from:
        Category of Personal Data Non-exhaustive examples of Personal Data from each category
        Contact details Name, address, phone numbers, email
        Technical and Behavioural tracking data IP address, location data, pages viewed on our website, cookie identifiers, the types of devices you are using to access or connect to our applications, unique device IDs, device attributes, network connection type and provider, network and device performance, browser type, operating system, and application version

        The purpose and legal basis for processing the Personal Data outlined above will be:

        Purpose of processing the Personal Data Legal basis for processing the Personal Data
        To administer our site and applications and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
        • To pursue the legitimate interests of Paymentsense
        To verify your identity as well as your personal and contact information
        • To comply with applicable law
        • To pursue the legitimate interests of Paymentsense
        To provide and market services and products to the individual
        • To pursue the legitimate interests of Paymentsense
        • When you have provided consent
        To respond to the individual and provide any support that is required
        • To pursue the legitimate interests of Paymentsense
        To communicate with you in relation to our services
        • To pursue the legitimate interests of Paymentsense
        • When you have provided consent
      2.  In the case of an executive, director, beneficial owner or authorised signatory of a corporate customer that communicates with us we will collect and process the following information:
        Category of Personal Data Non-exhaustive examples of Personal Data from each category
        Account identification information Merchant ID number, passwords and equivalent account security information
        Contact details Name, address, phone numbers, email
        Information required to be obtained and kept by law Information required for customer identification and verification (e.g. government issued IDs)
        Technical and Behavioural tracking data IP address, location data, pages viewed on our website, cookie identifiers, the types of devices you are using to access or connect to our applications, unique device IDs, device attributes, network connection type and provider, network and device performance, browser type, operating system, and application version

        The purpose and legal basis for processing the Personal Data outlined above will be:

        Purpose of processing the Personal Data Legal basis for processing the Personal Data
        To administer our site and applications and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
        • To pursue the legitimate interests of Paymentsense
        To provide you with our newsletter, if you have subscribed to receive it, and any other information that you request from us from time to time;
        • To pursue the legitimate interests of Paymentsense
        To communicate with you (via the use of surveys or by other means) about any comments, queries or feedback you might have about us, the website or our applications;
        • To pursue the legitimate interests of Paymentsense
        To keep the website and our applications safe and secure
        • To comply with applicable law
        • To pursue the legitimate interests of Paymentsense
        To verify your identity as well as your personal and contact information
        • To comply with applicable law
        • To pursue the legitimate interests of Paymentsense
        To initiate, exercise and defend any legal claim or collection procedure
        • To comply with applicable law
        • To pursue the legitimate interests of Paymentsense
        To provide you with information about products and services we offer that we feel may interest you by post, telephone, SMS, email or via in-application notifications;
        • To pursue the legitimate interests of Paymentsense
        • Where we are required by law to obtain your consent to provide this information, we will obtain your consent. If consent is not required we will provide you an option to opt-out of receiving this information each time that we send information to you.
        To make suggestions and recommendations to you and other users of the website and our applications about goods or services that may interest you or them;
        • To pursue the legitimate interests of Paymentsense
        To comply with internal compliance procedures
        • To comply with applicable law
        • To pursue the legitimate interests of Paymentsense
        To prevent misuse of Paymentsense’s services
        • To comply with applicable law
        • To pursue the legitimate interests of Paymentsense
        To carry out risk management and fraud prevention processes
        • To comply with applicable law
        • To pursue the legitimate interests of Paymentsense
        To comply with applicable KYC, AML, book-keeping and capital adequacy laws and to report to tax authorities and other relevant law enforcement agencies.
        • To comply with applicable law
        • To pursue the legitimate interests of Paymentsense
        To communicate with you in relation to our services.
        • To pursue the legitimate interests of Paymentsense
        • When you have provided consent
  6.  Collecting Personal Data from third parties
    1.  In order to ensure that the services we provide are secure and efficient we process Personal Data from selected third parties. These third-party sources (and the categories of information) include:
      Category of Third Party Category of Personal Data
      Credit rating agencies
      • financial information
      • information required to be obtained and kept by law
      Fraud detection agencies
      • information required to be obtained and kept by law
      Financial institutions such as banks and card networks
      • financial information
      • information required to be obtained and kept by law
      Tax authorities
      • information required to be obtained and kept by law
      Publicly available registries maintained by or on behalf of national authorities
      • contact details
      • information required to be obtained and kept by law
      Companies in the same corporate group as Paymentsense
      • contact details
    2.  Please feel free to contact us if you have a question as to which specific third parties we process Personal Data from in a given circumstance.
  7.  Sharing Personal Data with third parties
    1.  We currently share Personal Data with the following named third parties for the following purposes:
      Name of Third Party Why we share Personal Data with them
      Ingenico Dispatch terminal to our customers
      Spire Dispatch terminal to our customers
      Lantec Dispatch terminal to our customers and arrange an engineer installation
      HMRC Personal information for payment of PAYE, student loan deductions, tax code notices and related matters
      ONS (Office of National Statistics) Sharing of corporate data, staff numbers, payroll totals
      Adobe Sign Adobe makes contracts that we autofill with our customer's data and Adobe sends the contracts to our customer's email addresses
      Talkdesk Provides contact centre software to us. This allows us to answer, transfer, monitor and record customer calls
      Sysnet Provides service to our customers to help them become PCI compliant. This includes phone based support, filling out questionnaires and related matters
      CIFAS Background checks as part of regulatory and other requirements
      Experian Background checks as part of regulatory and other requirements
      UKPR Dispatch till rolls to our customers
      Epay Provide mobile phone card top up service for our customers
      AI Corp Provide ecommerce and MOTO payment services
      GoCardless To set up direct debit payments for our services
      Lloyds Bank plc Personal banking details for the purpose of making payroll related payments and expense reimbursement. Corporate credits in the name of staff
      HSBC Bank plc Personal banking details for the purpose of making payroll related payments and expense reimbursement. Corporate credits in the name of staff
      Amex Corporate credit cards which are held in the name of senior staff in the business
      Pure Print To provide printed materials to our sales agents, customers and partners
      Jaden Press To provide printed materials to our sales agents, customers and partners
      UKPR To provide printed materials to our sales agents, customers and partners
      PHD Mail To provide printed materials to our sales agents, customers and partners
      Colour Company To provide printed materials to our sales agents, customers and partners and Provides our customers with a bag to return terminals to Paymentsense
      Emarsys An Email Service Provider that enables us to provide marketing and transactional emails to our customers, partners and prospects
      Mail Chimp An Email Service Provider that enables us to provide marketing and transactional emails to our customers, partners and prospects
      Reward Gateway Provides a rewards platform offered to our customers
      Golley Slater Provides telephony support for partners
      Google Enhanced targeting / exclusions from advertising
      Linkedin Enhanced targeting / exclusions from advertising
      Facebook Enhanced targeting / exclusions from advertising
      Twitter Enhanced targeting / exclusions from advertising
      Microsoft Enhanced targeting / exclusions from advertising
      ResponseTap Provides call tracking, call recording and campaign measurement through the allocation of bespoke phone numbers
      Contis Provides Gift Card services to our customers
    2.  We also, from time to time, share your Personal Data with the following third parties:
      • companies that are in the same corporate group as Paymentsense;
      • suppliers and sub-contractors who provide, for example, IT support, logistics, communication, customer support, marketing, acquiring and PCI compliance services and our business partners who we may share Personal Data with in order for them to provide you with information about similar goods and services;
      • advertisers and advertising networks that require anonymised data to select and serve relevant adverts to you and others. We shall provide them with aggregate information about our users (for example, we may inform them that 150 men aged 35-45 have clicked on their advertisement on any given day). We shall also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men in a particular location). We shall make use of the information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
      • user experience, service design and market research agencies that assist us in the improvement and optimisation of the products and services that we offer to customers as well as with other market research projects;
      • analytics and search engine providers that assist us in the improvement and optimisation of the website and our applications; and
      • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
    3.  In addition to the instances set out at 7.1 and 7.2 above, Paymentsense may also disclose your Personal Data to third parties:
      • in the event that we sell or buy any business or assets, to the prospective seller or buyer of such business or assets and their advisors;
      • if Paymentsense or substantially all of the company’s assets are acquired by a third party, in which case Personal Data held by the company about our customers will be one of the transferred assets;
      • if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our various terms, policies and other agreements; or to protect the rights, property, or safety of Paymentsense, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    4.  We shall share an End-customer’s Personal Data with a Merchant when it is to enable the Merchant to fulfil the End-customer’s order and mitigate the risk of fraud and other criminal acts. The Personal Data will also be processed when handling potential complaints and disputes. Personal Data shared with a Merchant will be subject to the Merchant’s data protection policy and not this Privacy Policy.
    5.  If a third party processes Personal Data on the instruction of Paymentsense they are likely to be a data processor. An example of this will be in relation to our suppliers of IT and marketing services. In such cases, we only share Personal Data for purposes that are compatible with the reasons contained in this Privacy Policy. All data processors are subject to written agreements that ensure the security of Personal Data and limit the transfer of Personal Data to third countries.
    6. If a third party is considered to be a data controller, Paymentsense are not able to dictate how that third party will process the data that have been provided. Examples of common third party data controllers would be credit rating agencies or financial institutions. In such cases, the data protection policies of the third party data controller will apply.
  8.  Links to third-party websites
    1.  Our website features third-party advertising which provides links to and from third-party websites. If you follow a link to any of these third-party websites, you should be aware that these websites have their own privacy policies and the operators of those websites will handle your information in accordance with such policies and not with this Privacy Policy. We have no control over such third parties or their websites or privacy policies. For example, such operators might contact you or permit third parties to contact you for marketing purposes in accordance with their own privacy policies, unless you opt out of such communications.
    2.  We do not accept any responsibility or liability for third-party websites or their privacy policies and we strongly advise you to check such policies and the reputation of the website before you submit your information to, or carry out any transaction on, any third-party website. We welcome any feedback you may have about third-party websites linked to from our website.
  9.  Securing and storing your information
    1.  Security
      1.  We have in place a level of security appropriate to the nature of the information stored and the harm that might result from a breach of security. Your information is stored on our secure servers. The transmission of any payment transactions will be encrypted using TLS technology.
      2.  All environments that are used in the transmission of payment transactions are hosted in an environment that has passed PCI-DSS Level 1 service provider accreditation, and are therefore required to adhere to all the requirements stated by the PCI Security Standards Council. To get more information about the different requirements of the PCI Security Standards Council please read more here.
      3.  Unfortunately, the transmission of information via the internet is not completely secure and, although we will do our best to protect your information, we cannot guarantee the security of any of your information transmitted via the website or our applications. Consequently, any transmission is at your own risk. If we become aware that the security of your information has been compromised, we will notify you by email or as otherwise required by law.
      4.  Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website or our applications, you are responsible for keeping this password confidential and you must not share it with anyone. If you have reason to believe that your password or any other aspect of your account has become compromised, you must inform us immediately using our contact details in section 19 below.
    2.  Storage
      1.  Personal Data will not be processed for a longer period than is necessary to fulfil the purpose of as set out in this Privacy Policy. Any Personal Data we hold will be anonymised and deleted once the purpose for which it was collected is no longer relevant.
      2.  The amount of data retained will be proportionate to the purpose for which the retention is required. Therefore, and always subject to applicable local law, the amount of Personal Data we retain when carrying out any contracts entered into between you and us is likely to differ from the amount of Personal Data retained for anti-money laundering or regulatory requirements.
      3.  We will retain Personal Data for 7 years after which it shall be deleted unless there is a valid purpose and legal basis for retaining it.
  10.  Transfers to a Third Country
    1.  The information that we collect from you may also be transferred to other destinations outside the European Economic Area ("EEA"). For example we do transfer information to the US (subject to the relevant protections below). If we do transfer your information outside the EEA we will take appropriate steps to protect that information, these include:
      • transferring to third parties in jurisdictions that the EU Commission has determined offers adequate protection for your information (information relating to Adequacy Decisions made by the European Commission are available here
      • entering into an agreement with a third party, which includes clauses that the EU Commission has determined offers adequate protection for your information, a template copy of which is available by going to www.eur-lex.europa.eu

        and searching for 32010D0087

      • transferring to third parties in the US that have agreed to comply with the Privacy Shield (information about the EU - US Privacy Shield is available here and here).
  11.  Your Rights
    1.  At Paymentsense, we believe that you should only have your data processed in ways that you expect and which are set out in this Privacy Policy. Under data protection law, you have rights in relation to our use of your information, including to:
      • request access to the information we hold by emailing us at gdpr@paymentsense.com. We will send you a copy of the Personal Data we hold on you. Please note that if you require additional copies of your data, we reserve the right to charge a reasonable fee to cover any administrative costs;
      • update or amend your information if it is inaccurate or incomplete
      • object to certain uses of your Personal Data (which includes direct marketing, and processing based on legitimate interests and processing for purposes of scientific or historical research and statistics) on grounds relating to your particular situation;
      • request the deletion of your information, or restrict its use, in certain circumstances (for example you can request that we erase your information where the information is no longer necessary for the purpose for which it was collected (unless certain exceptions apply)
      • to withdraw any consents you have provided in respect of our use of your information;
      • to object to the receipt of marketing information either by contacting us at opt-out@paymentsense.com or by opting out by following the instruction in the relevant marketing material;
      • to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk/global/contact-us/email/) [or other relevant supervisory authority].
      • more information about these rights can be found at https://ico.org.uk/. If you have any questions about these rights, or you would like to exercise any of them, please contact us gdpr@paymentsense.com – additional details of how to get in touch are set out in section 19 below.
    2.  If you wish to exercise your rights please contact us and we will treat your concerns with sincerity and respect.
    3.  Please note that Paymentsense does require a certain amount of Personal Data in order to provide customers with services or products. In the event that you request the deletion of Personal Data or for the use of Personal Data to be restricted, we reserve the right to no longer provide services and products to you under any applicable contract.
  12.  Cookies
    1.  Our website uses cookies to distinguish you from other website users. Cookies help to provide a more personalised experience when you browse the website and also allows us to improve the website. For detailed information on the cookies we use and the purposes for which we use them, please take a look at our Cookie Policy.
  13.  Children
    1.  We do not knowingly collect information from individuals who are under the age of 16. If you are under the age of 16, please do not register an account with our website or provide any information about yourself on our website. If you have already done so, please contact us.
  14.  Information about other people
    1.  Where you provide information about people other than yourself, you confirm that you have their consent to provide us with such information and that they have read, understand and agree to the terms of this Privacy Policy, including how we may use such information.
  15.  Changes to your information
    1.  If any of your information featured on our website (whether relating to your account or otherwise) is incorrect, please update it. Alternatively, if you believe that any of the information we hold about you is inaccurate, you may contact us to correct it using our contact details below. It is your responsibility to ensure that any information you have provided to us remains accurate and to notify us if there are any changes.
  16.  No waiver
    1.  If we fail to exercise, or delay in exercising, any right or remedy contained in this Privacy Policy, that does not mean we have waived that right or remedy and such failure or delay shall not be construed as a waiver.
  17.  Severance
    1.  This Privacy Policy is designed to comply with the GDPR and other applicable data protection laws. However, in the event that any provision or part-provision of this Privacy Policy is or becomes unlawful, invalid or otherwise unenforceable, the offending provision or part-provision shall be deemed severed from this Privacy Policy. In this event, the validity and enforceability of the rest of the Privacy Policy shall not be affected.
  18.  Changes to our Privacy Policy
    1.  By submitting your information to us, you consent to the use of that information as set out in this Privacy Policy. If we change our Privacy Policy, we will post the changes on this page and may place notices elsewhere within the website (such as the home page) for a reasonable period of time, so that you may be aware of the changes.
    2.  In the event of any changes, we will also update the "Last updated" date at the top of this Privacy Policy. Your continued use of the website following any changes to this Privacy Policy will mean you accept those changes.
  19.  Contact us
    1.  Please contact us if you have any questions about this Privacy Notice or the information we hold about you:

We will usually respond using the same means of communication as you used to contact us.