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Data privacy and Cookies Policy

Date: ��24/08/2023

Version: ����1.45

1 Important information and who we are

1.1 Purpose of this privacy policy

This privacy policy aims to give you information on how ��������, operating as �������� Technology Ltd collects and processes your personal data through your use of this website and/or our mobile application, including any data you may provide through this website and/or our mobile application when you sign up to be a member.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.2 Controller

�������� Technology Ltd is the controller and responsible for your personal data (referred to as "�������� Technology", "we", "us" or "our" in this privacy policy). We are a company registered in England and Wales. Our company registration number is 12739942 and our registered office is at 69 Old Street, London, United Kingdom, EC1V 9HX.

Please note that our partner, Transact Payments Limited (“TPL”), is the issuer of your payment card and is the independent Data Controller for the personal data which you provide to us in relation to processing undertaken to enable you to use the card. TPL is an e-money institution, authorised and regulated by the Gibraltar Financial Services Commission. TPL’s registered office address is 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA and its registered company number is 108217. When you apply for a �������� Credit Card, you agree to TPL’s Cardholder Terms and Conditions and Privacy Policy which are provided to you when you sign up for a card. They are also available within the �������� mobile application and the Privacy Policy is available at the bottom of this document. We encourage you to read the TPL Privacy Policy.
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1.3 Contact details‍

If you have any questions about this privacy policy or our privacy practices, please contact us by email on help@yondercard.com
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2 Why we collect data

We need to collect certain types of information to allow us to make a decision on your request for financial products. We also need to comply with legal and regulatory requirements relating to anti-fraud, anti-money laundering, know your customer and responsible lending obligations.

We will only collect the information we need to be able to provide you with the service you have requested. You need to make sure that the information you provide is accurate, complete and not misleading. Your personal information may need to be disclosed when we are obliged to by law, for purposes of national security, taxation, defence of a legal claim or criminal investigations.

3 The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

1. "Identity Data" includes first name, last name, date of birth, username or similar identifier, title, nationality, visa type and expiry date, marital status, number of dependents, employment status, occupation, employment industry, and residential status;
2. "Contact Data" includes billing address, email address and telephone numbers;
3. "Financial Data" includes account number, sort code and bank name for direct debit purposes;
4. "Transaction Data" includes details about payments to and from you, other details of products and services you have purchased from us and day of month to take payments;
5. “Credit Risk Data” includes information about you that we receive from credit reference agencies and also information about your credit card, bank and savings statements, spending habits, regular payments, monthly earnings before and after tax, monthly rent or mortgage payments and other financial data that, with your permission, we receive from your credit card provider, bank or building society;
6. "Technical Data" includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
7. "Profile Data" includes your username and password, credit made to you, desired credit amount and duration, borrowing purpose, your interests, preferences, feedback and survey responses;
8. "Usage Data" includes information about how you use our website, our mobile application, products and services; and
9. "Marketing and Communications Data" includes your preferences in receiving marketing from us and our third parties and your communication preferences.
   

We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not generally collect any "Special Categories of Personal Data" about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If we do collect sensitive personal information, we will ask for your explicit consent to our proposed use of that information at the time of collection.
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3.1 If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.‍

3.2 Changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

4 How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1. create an account on our mobile application;
2. enquire about our products;
3. request marketing to be sent to you; and/or
4. give us feedback or contact us.
   

We may also request a scan of an identity document if this is required for “know your customer” or anti-money laundering purposes.

Automated technologies or interactions. As you interact with our website or mobile application, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, visit statistics such as Google Analytics and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details. We may also record within the browser information necessary for the functioning of the website, for example whether cookie consent has been agreed to or progress through online forms.

Third parties. We also collect personal information received from other sources such as data from credit reference agencies, open banking data (including name, address, bank account number, sort codes, balance, overdraft limit and statement information) and results of “politically exposed persons” or sanction checks.

5 How we use personal data

We will only use your personal data if we have a legal basis for doing so. Most commonly, we will use your personal data in the following circumstances:

1. where we need to perform the contract we are about to enter into or have entered into with you;
2. where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests; and/or
3. where we need to comply with a legal obligation.
   

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5.1 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

5.2 Fraud prevention

As part of our financial services products, we may use your information in order to be able to:

1. search your record with credit reference and fraud prevention agencies to check and verify your identity (and the identity of any other individual named on your application) and collect your credit report (and that of any other individual named on your application). Credit reference agencies will keep a record of our enquiries, which may also be used by other organisations with access granted by the credit reference agencies. This may affect your ability to get credit. Please see sections 7 and 8 for further details about how your personal data may be used by credit reference and fraud prevention agencies; and
2. undertake appropriate checks to prevent or detect crime, money-laundering and or fraud.
   

5.3 Automated decision-making

When you apply for a credit card, we have an automated decision-making process which will decide whether to:

1. accept your credit card application;
2. decline your credit card application; or
3. refer your credit card application for further checks and additional consideration by us.
   

5.3.1 How the automated processes make decisions

We will use automated processes to verify your identity and to carry out fraud, credit reference agency and affordability checks on you in order to assess your credit card application. These automated decisions are made in order to perform the contract between us, and also to comply with our legal and regulatory requirements.

Your personal data will be used to obtain information about you from, and carry out checks with,  credit reference agencies.. Your annual gross income and monthly housing expenses will be used to enhance our affordability assessment. We also use open banking data to perform affordability and anti-fraud assessments, collected and provided to us by third parties.

We may also collect and process additional proof of identity information, such as a scanned copy of your passport or other form of identification.

The creditworthiness and affordability checks use your personal information to evaluate the risk that you will not (or will not have sufficient income to) repay your credit card borrowings. These automated processes enable a decision to be made as to whether it is appropriate for us to offer you a credit card, in accordance with �������� Technology’s legal and regulatory obligations.

The fraud and identity checks are carried out so that we can comply with our regulatory obligations to detect and prevent fraud and other crime.

If you do not pass all of these checks then your credit card application will either be refused or will be referred for further checks and additional consideration by us.

5.3.2 Your rights relating to automated decision-making

You have the right to request that we review or reconsider any decision that we make about your application which is based solely on automated processes. If you wish to exercise this right, please contact us as above.

5.4 Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.

5.5 Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

5.6 Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product/service experience or other transactions.

5.7 Cookies

For information about the cookies we use, please see our Cookie Policy.

5.8 Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6 Disclosures of your personal data

WE WILL NOT SELL, RENT, LEASE OR OTHERWISE SHARE YOUR PERSONAL INFORMATION OTHER THAN AS OUTLINED IN THIS PRIVACY POLICY OR WITHOUT OBTAINING YOUR CONSENT BEFOREHAND.

We may share your personal data with the parties set out below for the purposes set out in the table above.

1. Credit Reference Agencies (“CRAs”) and Fraud Prevention Agencies (“FPAs”).
2. Firms and businesses that help us provide you with the right product and services.

Service providers and business partners who assist with the operation of our business including hosting providers and payment processors.

1. Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
2. HM Revenue & Customs, regulators and other authorities acting as processors or controllers who require reporting of processing activities in certain circumstances.
3. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
   

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7 How do credit reference and fraud prevention agencies use your data?

When you apply to us for membership, we will check the following records about you:

1. any records we may already have about you;
2. those held by CRAs; and
3. those held by FPAs.
   

CRAs supply us with public information (including from the electoral register, county court judgments and bankruptcies registers) and shared credit and fraud prevention information, including information about previous applications and the conduct of accounts in your and your financial associate(s)' name(s).

You should be aware, when CRAs receive a search from us they will place a soft search footprint on your credit file, which is not visible to other lenders. This will occur during your initial eligibility check. If you agree to apply after the eligibility check, a hard search will be recorded with the CRAs, which may be seen by other lenders. If you agree to the credit terms we offer, we will continue to exchange information about you with CRAs, whilst you have a relationship with us.

We will send the information that you submit through our website and/or mobile application to CRAs. This information will be recorded by them. We and other organisations may access and use this information to prevent fraud and money laundering and CRAs and FPAs may use your information for statistical analysis. Information held by CRAs and FPAs will be disclosed to us and to other organisations in order to (for example):

1. prevent fraud and money laundering and to check and assess applications for credit, credit related facilities or other facilities;
2. recover debts that you owe and trace your whereabouts;
3. manage credit accounts and other facilities and decide appropriate credit limits;
4. verify your identity;
5. make decisions on credit and other facilities for you or your business;
6. check details on proposals and claims for all types of insurance; and
7. check details of job applicants and employees.
   

When you borrow from us, we will give details of your credit card and how you manage it to the CRAs. If you borrow and do not repay in full and on time, the CRAs will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding. Other organisations may see these updates, and this may affect your ability to obtain credit in the future.

If you fall behind with your payments and a full payment or satisfactory proposal is not received within 14 Days of a “Notice of Default” being issued, then a “Formal Demand” will be issued, and a default registered on your Credit File with CRA’s.

This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe.

If you give us false or inaccurate information and we have reasonable grounds to suspect fraud or we identify fraud we may record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention including law enforcement agencies who may then access this information.

If you have any further questions about our use of Credit Reference Agencies (or would like to receive details of these agencies) please email us using the contact details provided above in this Privacy Policy.

Equifax, Experian and TransUnion, the ICO and the major financial services trade associations have developed a common statement, Credit Reference Agency Information Notice (CRAIN). This defines the standards that all three Credit Reference Agencies will apply across all products and services in relation to processing consumer data. These can be found at , , and .

8 How do we work with fraud prevention agencies?

We undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity before we make a decision about your application. These checks require us to process personal information about you.

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by

9 International transfers

Personal data is stored on secure servers hosted in the UK. We do not transfer your personal data outside the UK or the European Economic Area.

10 Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11 Data retention

11.1 How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

12 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

"Request access" to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

"Request correction" of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

"Request erasure" of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

"Object to processing" of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

"Request restriction of processing" of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. if you want us to establish the data's accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
   

"Request the transfer" of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information which you initially provided consent for us to use or where we used the information to perform a contract with you; and

"Withdraw consent at any time" where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us as above.

12.1 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

12.2 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

12.3 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13 Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

14 Changes to this privacy policy

We keep our privacy policy under regular review. This version was last updated on September 15^th, 2021.

TPL’s Privacy Policy

1 Purpose

This policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

TPL is committed to safeguarding the privacy of your information. By “your data”, "your personal data”, and “your information” we mean any personal data about you which you or third parties provide to us.

We may change this Policy from time to time so please check this page regularly to ensure that you’re happy with any changes.

2 Who are we?

Transact Payments Limited (“TPL”, “we”, “our” or “us”) is the issuer of your card and is the Data Controller for the personal data which you provide to us in relation to the credit card only. TPL is an e-money institution, authorised and regulated by the Gibraltar Financial Services Commission. Our registered office address is 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA and our registered company number is 108217.

�������� Technology Limited manages your card program and is the Data Controller for any personal data which you provide which is not related to the card. �������� Technology Limited is incorporated in England and Wales under company number 2739942 with its registered office at 69 Old Street, London, United Kingdom, EC1V 9HX.

3 How do we collect your personal data?

We collect information from you when you apply online or via a mobile application for a payments card which is issued by us. We also collect information when you use your card to make transactions. We also obtain information from third parties (such as fraud prevention agencies) who may check your personal data against any information listed on an Electoral Register and/or other databases.

4 On what legal basis do we process your personal data?

Contract

Your provision of your personal data and our processing of that data is necessary for each of us to carry out our obligations under the contract (known as the Cardholder Agreement or Cardholder Terms & Conditions or similar) which we enter into when you sign up for our payment services. At times, the processing may be necessary so that we can take certain steps, at your request, prior to entering into that contract, such as verifying your details or eligibility for the payment services. If you fail to provide the personal data which we request, we cannot enter into a contract to provide payment services to you or will take steps to terminate any contract which we have entered into with you.

Legal/Regulatory

We may also process your personal data to comply with our legal or regulatory obligations.

Legitimate Interests

We, or a third party, may have a legitimate interest to process your personal data, for example:

• To analyse and improve the security of our business;
• To anonymise personal data and subsequently use anonymized information.

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5 What type of personal data is collected from you?

When you apply for a card, we, or our partners on our behalf, collect the following information from you: full name, physical address, email address, mobile phone number, phone number, date of birth, gender, login details, IP address, identity and address verification documents.

When you use your card to make transactions, we store that transactional and financial information. This includes the date, amount, currency, card number, card name, account balances and name of the merchant, creditor or supplier (for example a supermarket or retailer). We also collect information relating to the payments which are made to/from your account.

6 How is your personal data used?

We use your personal data to:

- maintain and administer your account, including processing your financial payments, processing the correspondence between us, monitoring your account for fraud, facilitating the provision of insurance and other services provided via Mastercard and providing a secure internet environment for the transmission of our services.

- comply with our regulatory requirements, including anti-money laundering obligations.

improve our services, including creating anonymous data from your personal data for analytical use, including for the purposes of training, testing and system development.

7 Who do we share your information with?

When we use third party service providers, we have a contract in place that requires them to keep your information secure and confidential.

We pass your information to the following categories of entity:

• companies and organisations that assist us in processing transactions you make (including but not limited to payment processing service providers) and in providing services that you have requested;
• companies and organisations that run and manage the card program;
• identity verification agencies to undertake required verification, regulatory and fraud prevention checks;
• information security services organisations, web application hosting providers, mail support providers, network backup service providers and software/platform developers;
• payment networks, payment service providers and mobile payments providers (i.e. Mastercard, Visa or any third parties involved in processing the financial transactions that you make);
• document destruction providers;
• anyone to whom we lawfully transfer or may transfer our rights and duties under this agreement;
• any third party as a result of any restructure, sale or acquisition of TPL or any associated entity, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us.
• regulatory and law enforcement authorities, whether they are outside or inside of the EEA, where the law requires us to do so.
  

8 Sending personal data outside of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• with service providers located outside the EEA (such as Mastercard);
• if you are based outside the EEA;
• where there is an international dimension to the services we are providing to you.
  

These transfers are subject to special rules under European and Gibraltar data protection law.

These non-EEA countries do not have the same data protection laws as Gibraltar and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. We will send your data to countries where the European Commission has made an adequacy decision, meaning that it has ruled that the legislative framework in the country provides an adequate level of data protection for your personal information. You can find out more about this .

Where we send your data to a country where the European Commission has not made an adequacy decision, our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses, please go to the European Commission’s website. Mastercard uses Binding Corporate Rules which you can access at:

If you would like further information please contact our Data Protection Officer on the details below.

9 How long do we store your personal data?

We will store your information for a period of five years after our business relationship ends in order that we can comply with our obligations under applicable legislation such as anti-money laundering and anti-fraud regulations. If any changes to applicable legislation require us to retain your data for a longer period of time, we shall retain it for that period. We will not retain your data for longer than is necessary.

10 Your rights regarding your personal data?

You have certain rights regarding the personal data which we process:

• You may request a copy of some or all of it.
• You may ask us to rectify any data which we hold which you believe to be inaccurate.
• You may ask us to erase your personal data.
• You may ask us to restrict the processing of your personal data.
• You may object to the processing of your personal data.
• You may ask for the right to data portability.
• If you would like us to carry out any of the above, please email the Data Protection Officer at DPO@transactpaymentsltd.com.

11 How is your information protected?

We implement security policies and technical measures in order to secure your personal data and take steps to protect it from unauthorised access, use or disclosure.

While we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

12 Complaints

We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your personal information.

The also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Gibraltar is the Gibraltar Regulatory Authority. Their contact details are as follows:

Gibraltar Regulatory Authority,

2nd floor, Eurotowers 4, 1 Europort Road, Gibraltar.

(+350) 20074636/(+350) 20072166   info@gra.gi

13 Changes to our Privacy Policy

We keep our Privacy Policy under review and we regularly update it to keep up with business demands and privacy regulation. We will inform you about any such changes. This Privacy Policy was last updated on 25th May 2018.

14 How to contact us

If you have any questions about our Privacy Policy or the personal information which we hold about you or, please send an email to our Data Protection Officer at DPO@transactpaymentsltd.com.

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��������’s Cookie Policy

1 What are cookies

Cookies and other similar tracking technologies are small text files or code placed on your device (e.g. computer, smartphone or other electronic device) when you use our website or app or view a message. Cookies allow a website or app to recognise a particular device.

2 Our use of cookies

We use cookies and other similar tracking technologies on our website and mobile application. These help us recognise you and your device and store some information about your preferences or past actions.

For example, we may monitor how many times you visit our website or use our mobile application, which pages you go to, traffic data, location data and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

You can set your browser not to accept cookies and the websites below tell you how to remove cookies from your browser. However, some of our website features may not function as a result.

For further information on our use of cookies and other similar tracking technologies, including a detailed list of your information which we and others may collect through cookies, please see below.

3 Why do we use cookies?

We use cookies and other similar tracking technologies to:

1. recognise you whenever you visit our website or app (this speeds up your access to this as you do not have to log in each time);
2. obtain information about your preferences and use of our website and app;
3. carry out research and statistical analysis to help improve our content and services and to help us better understand our users’ requirements; and
4. make your online experience more efficient and enjoyable.
   

4 Types of cookies

The cookies we place on your device fall into the following categories:

1. Strictly necessary cookies. These cookies are essential for you to be able to navigate our website and app and use its features. Without these cookies, the services you have asked for could not be provided.
2. Analytical / performance cookies. These cookies collect information about how you use our website and app, e.g. which pages you go to most often. These cookies do not collect personally identifiable information about you. All information collected by these cookies is aggregated and anonymous and is only used to improve how our website works.
3. Functionality cookies. These cookies allow our website to remember the choices you make (such as your username, language, last action and search preferences) and provide enhanced, more personal features. The information collected by these cookies is anonymous and cannot track your browsing activity on other websites.
4. Targeting cookies. Also known as advertising cookies, these cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement on our website and help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with this Website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers.
   

5 The cookies we use

At �������� Technology Ltd we set and use some cookies ourselves but only on our site. We refer to these as first party cookies. When cookies are served by another domain or by one of our service providers we refer to them as third party cookies. Please see what cookies and other similar tracking technologies we use below:

• Google Analytics Cookies
• Facebook Pixel Cookies
  

We may also use pixels or web beacons in direct marketing emails that we send to you. These pixels track whether our email was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as your IP address, browser, email client type and other similar details. We use this information to measure the performance of our email campaigns, and for analytics.

6 Consent to cookies

We will ask for your permission (consent) to place cookies or other similar tracking technologies on your device, except where these are essential for us to provide you with a service that you have requested.

There is a notice on our home page which describes how we use cookies and requests your consent before we place any non-essential cookies on your device.

7 How to turn of cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.

To find out more about cookies, including how to see which cookies have been set and how to manage and delete them, you can visit the third-party website: