Privacy Policy

This Privacy Policy was developed and approved in accordance with the Law and applies to the activities of Paycard when collecting and processing personal data in accordance with the provisions of this Policy.


Paycard is committed to ensuring the protection of personal information and takes all appropriate actions aimed at its secure processing, as well as compliance with the provisions of this Policy when collecting, using, storing and disclosing such information. This Policy (together with the Terms of Use that apply to any specific services you may purchase or use) applies to:


website/portal functionality and services provided to Clients when visiting our website, portals or payment panels that our clients can use on their websites;


the conditions when you apply to use and (or) use the products and services of Paycard, as well as when you send a request to make changes to the services you use;


your use of software, including terminals, mobile and desktop applications of Paycard;


email messages, other electronic messages, including SMS messages, web chats and other methods of interaction between you and Paycard.


For purposes of this Policy, the above are collectively referred to as the “Services.”



INFORMATION WE MAY RECEIVE FROM YOU

Personal and non-personal information


We collect and process your personal and non-personal information.


Personal data is information that allows one to clearly, directly or indirectly, identify an individual.


Paycard may collect non-personal information or anonymize personal data to reduce it to non-personal information. Non-personal information is information that does not directly or indirectly identify a specific person. Paycard may collect, create, maintain, use and disclose such non-personal information for any reasonable business purpose. For example, Paycard may use aggregated transaction information for business purposes, such as trend analysis and analytics to derive insights on transaction patterns and usage.



COLLECTING INFORMATION ABOUT YOU

We collect the following types of data in the ways described below:


Information you provide to us: We receive and store any personal information (including financial information) you provide to us, including when you (or your business) make a request for or apply for Services; register to use and/or use any Services; upload and/or store information on our servers while using the Services; and contact us by email, SMS, website or portal, telephone or other electronic means, for example in the context of contacting us in relation to your account or transactions. Such information may reference or relate to you or your clients and includes:


first and last name, date of birth, age, email address, billing address, username, password and/or photo, biometric information, address, job title, nationality and country of residence, copy of ID such as driver's license or passport, Your Social Security number and/or government-issued identification or registration information;


main card account number, card expiration date, secret card verification code (CVC), account numbers, account balances and the period of use of these accounts by you, bank and (or) issuer details;

information about any products purchased, including where they were purchased, cost, time and any evaluation of the purchase, including travel-related personal data that you or your customers provide when purchasing airline tickets or other travel-related services;

information about your use of the Services, such as the frequency of transactions made through us, the average size of your transactions, account balances, as well as information about the persons and merchants to whom you transfer or receive funds;

publications in our promotional materials for future events;


any other information that you or your clients transmit or generate in the context of using the Services.


Automatically collected information about you: Paycard automatically receives and stores certain information when you interact with our websites, such as through the use of cookies or similar technologies, whether you open an account with us or make transactions through us transaction. In addition, we receive certain information when you access the Services through your web browser or through advertising and other content provided by or on behalf of Paycard on other websites or when you read email messages. Collecting this information allows us to better understand the visitors and customers who use or interact with our services, determine where they came from, and how they use our services. We use this information for analytical purposes, as well as to improve the quality and relevance of our services for visitors and clients.


Such information includes:


technical information, including the Internet Protocol address (IP address) used to connect your computer or device to the Internet, your credentials, browser type and version, hardware type, time zone information, types of browser plug-ins and their versions , operating system platform, frequency and duration of visits and links followed;


information about your visit or that you opened an email message that includes your location, including Uniform Resource Locator (URL), clickstream history to, through, or away from our website (including date and time of visits); products or services you viewed or searched for; page response times, loading errors, length of visits to certain pages, page interaction information (such as scrolling, mouse clicks, and mouse-overs), as well as how to navigate away from a website page and any phone numbers used to dial and connect to our support number.


Information collected through our applications: If you download or use a mobile phone owned by Paycard, we may receive information about your location and the location of your device or the service you use (including the location of the payment transaction). Some devices allow apps to access real-time location information (such as GPS (Global Positioning System)). When you enable real-time location functionality, our mobile and desktop applications may collect such information from your mobile device or personal computer any time you download or use our applications. If necessary, we try to notify you of our intention




WHAT DO WE USE YOUR PERSONAL DATA FOR

We may use and share personal data we collect for the following purposes:


to provide you and your company with Services, including to fulfill the obligations of Paycard to you or to financial or other institutions arising in connection with the Services provided to you (and (or) your company). In this context, we record and track details of transactions carried out by you (and/or your customers) in relation to the Services; notify you about important changes or innovations to our website or our products and services;


to improve the quality and development of our activities, including to optimize our websites/portals, products and services. The above may include using information that you provide on forms but do not provide to us, such as using such information to optimize our website(s) and contacting you to provide support on such forms. In addition, we may use your personal data to develop and test new products and services, including in our secure and controlled testing environment or sometimes in similar environments from our suppliers;


to administer and exercise your rights, comply with the terms of use and enforce any other contracts with you (and/or your business), including to manage any circumstances arising in connection with the dispute of transactions, rewards or points; to manage, investigate and resolve complaints; to repay a debt or in the event of your insolvency;


In order to prevent and/or detect fraud, financial crime, manage risk and provide enhanced protection for ourselves, our clients and the integrity of the financial system, it may be necessary to process and disclose sensitive personal data (also known as “special personal data”);


to prevent, detect and prosecute fraud and other crimes and misuse of the financial system or to assist others in doing so, including failure to comply with any terms of engagement that may involve sharing with third parties any relevant or necessary information we collect for such purposes. Paycard  participates in anti-fraud initiatives that involve assessing you (and your customers) and monitoring your transactions and/or determining your location, identifying patterns that require investigation, or modeling and assessing the likelihood of fraud occurring. fraudulent activity or failure to comply with our or other terms of business. Solving such problems is possible through the use of third party products and services. In addition, if you provide false or misleading information about yourself, or we discover or suspect fraudulent or illegal activity, we may disclose such information to fraud prevention agencies and organizations, law enforcement agencies and similar agencies, and to us. a decision may be made to file a claim in court;

to communicate with you regarding your account to notify you of potential problems and to respond to your questions;

in order to prevent or reduce information security risks;


in pursuance of the provisions of the requirements of the current legislation;


to meet the requirements of law enforcement and regulatory authorities in the public interest or of commercial organizations with which you have or have had a trading relationship, to establish, exercise or defend legal claims or to protect your vital interests or those of others, for example, as part of the promotion the above-mentioned bodies or other organizations in the fight against crime and terrorism; to comply with the rules of payment systems or any terms of cooperation.


If you provide information that is to be published or displayed in public areas of the website/portal or transmitted to other users of the website/portal or to third parties, you understand that such information may be used by any third parties attempting to obtain such information for any purpose. goals. This information is published by you at your own risk and you are bound by the terms and conditions of use of such website.


DISCLOSURE OF YOUR PERSONAL DATA

We do not disclose information that could identify you personally to anyone except as described and specified in this notice, as permitted or required by law, and/or for the purposes described in this notice, including:


Paycard as part of assisting us in providing our services and for our internal management of customer relationships for the purpose of analysis and reporting;


recipients/senders of payments in the context of a specific transaction (usually limited to full name and email address);


Where we provide our services through third parties, such as banks or other organisations, we may be required to disclose your data (including any 'know your customer' or 'source of funds' information) to such organizations in order for them to comply with their regulatory obligations or risk assessments;


independent service providers, including suppliers who assist us in providing the Services, including processing and fulfilling orders, processing payments, managing credit, security, sector and fraud risks, market research and conducting surveys on behalf of the Paycard. From time to time, we may use third party vendors to assist us in providing services that may require the use of your personal data, including for intelligence testing purposes and for which security measures are in place;

In order to prevent and/or detect fraud, financial crime, manage risk and provide enhanced protection for ourselves and our clients, it may be necessary to process and disclose sensitive personal data (also known as “special personal data”), including biometrics data to third parties who assist us in managing such risks, as well as in verifying identity;


unless contrary to the provisions of the current legislation, Paycard, in accordance with them, may transfer information about you to regulatory and law enforcement authorities around the world, or we may otherwise determine the advisability or necessity of taking such actions. Such disclosures may be made in accordance with the requirements of government authorities or commercial organizations with which you may have a relationship and who wish to reduce fraud or credit risks or avoid non-compliance with terms of business, or as part of legal proceedings or legal proceedings, in the interests of national security or when we believe that such disclosure is in the national or public interest or that such action is lawful;


Except as necessary to provide services and as set forth above/in the attachment, Paycard does not sell, rent, lease, transfer or otherwise disclose information about its customers to third parties in their own advertising purposes without complying with any necessary legal obligations.



KEEPING YOUR PERSONAL DATA SECURE

We have taken a number of technical, physical and organizational/administrative measures aimed at protecting your personal data from accidental loss and unauthorized access, use, modification and disclosure. Such measures include:


a compiled information security program;


appointment of a Chief Information Security Officer (“CISB”) to oversee, implement and execute the information security program;


appointment of an information security officer (“IDS”) to oversee, implement and execute the information security program;


ongoing vulnerability assessment and monitoring;


developed policies and procedures for ensuring information security;


developed emergency response plan;


access to the management of information systems designed to authenticate users and providing access only to authorized persons;


providing access to physical storage of personal data only to authorized persons;


protection of all transmitted and stored personal data;


multi-factor authentication of all employees with access to personal data;


maintaining a log of audits of internal and external access to personal data and their changes;


accepted security practices for applications developed in-house;


comprehensive examination of the information security system of independent service providers;


Regular training on safety measures and rules.


You are also responsible for maintaining and protecting your information. If we have provided you (or you have created) a password or access code to access certain sections of our website/portal or mobile applications, etc., you are responsible for not disclosing this password and/or access code. You must not disclose your password and/or access code to anyone. You are responsible for preventing unauthorized use of your password and access code. Paycard acts in accordance with the instructions and information received from any person providing your user ID and password, and you understand that you are solely responsible for any use and any actions that may be taken using your account , unless otherwise provided by law. You must immediately notify Paycard if any data provided to us changes.


The transmission of information over the Internet is not completely secure. Although we strive to protect your personal data, we cannot guarantee the security of your data transmitted to our website unless you communicate with us through a secure channel we provide. Once we receive your personal information, we follow strict procedures and use security features designed to prevent unauthorized access.



STORAGE DURATION OF YOUR PERSONAL DATA

The storage period of personal data is determined by the date of achievement of the purposes of their collection and processing, unless otherwise provided by the legislation.


If you use the Services, we retain your personal data for as long as you are provided with the services you have chosen and for any legitimate business purposes. Typically this means that we retain your personal data for as long as you remain a customer (or apply to become one) and for a certain period thereafter. This also includes the use and storage of your personal data from the moment you complete an application to use the Services, regardless of whether you complete the application process or are authorized to use the services as a client.


The storage period may also depend on the legal and regulatory requirements of your country of residence. We retain your personal data as evidence of our relationship with you (including the existence or absence of financial transactions), to manage inquiries or disputes, and to defend or pursue legal claims.




YOUR RIGHTS IN THE FIELD OF DATA PROTECTION

You can exercise numerous rights you have in relation to your personal data.


Having provided us with your consent to the use of your personal data, you can withdraw it at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out by us prior to such withdrawal, nor will it affect the processing of your personal data carried out on the basis of law other than consent.



CHANGES TO THE PRIVACY POLICY

We may change our privacy notice from time to time. If we make significant changes to the way we process your information, we will notify you on this website/portal. The date of the last revision of the privacy notice is indicated in this document. We recommend that you visit our website/portal periodically to check this privacy notice for any changes. However, if we are required by law to inform you in advance of any changes to this privacy notice and/or obtain your consent to use your personal data, we will act accordingly.

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