Privacy policy
Effective as of 25.05.2018
Last update: 01.10.2022
I. Why should you read this Privacy Policy?
myPOS is committed to the principles of personal data protection laid down in European law and recognizes the importance of safeguarding its customers’ information. We are constantly improving our data processing activities and our privacy notices in order to provide you with as much transparency over the way we handle your data as we can. This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of myPOS Service.
If you have concerns about how we use your personal information, you can contact our data protection officer at [email protected].
If you are unsure about the meaning of any term used in this Privacy Policy (such as “myPOS Account” or “myPOS Card”), you may check the definition in the other legal documents regulating the myPOS Service to all of which this Privacy Policy is inseparable part.
If you see an undefined term in this Privacy Policy (such as “myPOS Account” or “myPOS Card”), it has the same definition as in our Legal Agreement for myPOS Account, Legal Agreement for myPOS Card, Merchant Agreement or other legal documents regulating myPOS Service to all of which this Privacy Policy is inseparable part.
1.1. About us.
When this policy mentions “we,” “us,” or “our,” it refers to myPOS or an Affiliate of myPOS, which are responsible for your information under this Privacy Policy. The specific responsible entity for your personal data may vary for the different services provided though the myPOS Service. The responsible entity in each case is referred to as the “Data Controller”.
1.2. The myPOS Service.
For the purposes of this documents myPOS Services consist of products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us or mobile apps, online platform, official social media platforms, or other online properties through which we provide payment and e-money services.
myPOS Service is designed for business purposes and may be used by individuals or entities. In case you are registering for and/or using myPOS Services on behalf of an entity we will treat you as authorized person and you may be obliged to disclose to us personal data of the legal representatives, the employees, the agents, the beneficial owners or any other third-party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person beside yourself you have received prior consent from that other person to provide their personal information to us.
Тhe present Privacy Policy grants rights which only natural persons, related in any way to a myPOS client, may benefit from. Whenever we use “you”, “your” or similar, the persons which we refer to are the natural persons which are involved in any way with the information of the myPOS Client, which may be the representatives, the beneficial owners, the authorized persons or other similar and in case the myPOS Client is a sole trader or similar.
This Privacy Policy also applies to the information that is collected and used in relation to myPOS Online Store pursuant to Conditions of Use myPOS Online Store.
This Privacy Policy also applies to the information that is collected and used in relation to provision of the myPOS Online functionality for establishing online shops on our domains pursuant to General terms and Conditions for myPOS Online.
The myPOS Online is designed for the use of two main categories of data subjects:
1. Merchants, who create their own online shops through the myPOS Online functionality for the purpose of selling their goods and services to customers online; and
2. Users of the domain mypos.site, who may visit and review the goods and services of the Merchants in their online shops created on myPOS.site. For this category of data subjects the only data that we collect is Device ID and log data for facilitation of out platform mypos.site.
II. How do we process your personal information?
2.1. What information do we process about you?
You are informed that there are two general categories of information that is collected from you differentiated on grounds as defined by the Regulation 2016/679 and other applicable data protection national laws.
a. Information which we collect when you use our payment and financial services;
b. Information that we collect for other purposes, such as operating our myPOS Store or providing you with any of our linked services.
III. Information that we process in relation to our Services.
We may ask for and collect from you the following personal information when you use the myPOS Service:
| Type of personal data | Purpose of processing | Legal grounds under GDPR | What third-party processors can we use for this? |
|---|---|---|---|
| Names (First Name, Surname, Last Name) | Opening your account and maintaining our legal relationships | Our contract with you or in order to take steps prior to entering into a contract; defense of our legal claims | Our auditors; legal or other similar counsels; debt collection agencies; accounting outsourcing providers; support outsourcing providers including our distributors. |
| Marketing | Our legitimate interests | Marketing services providers. | |
| Providing support | Our contract with you | Support outsourcing providers including our distributors | |
| Cross-sales marketing | Your consent | In case there is a third-party processor, you will be provided with information about them in the consent form. | |
| Facilitating our social features | Our legitimate interests in developing the Platform and drive user interaction | Other users of the Service | |
| Facilitating your payment transactions | Compliance with legal obligations; Our contract with you | Correspondent banks; financial institutions that we have contracted to enable us to provide effectively myPOS Service to our customers; auditors; legal or other similar counsels; regulators | |
| Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators | |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Date and place of birth | Opening your account and maintaining our legal relationships | Our contract with you or in order to take steps prior to entering into a contract | Our auditors; legal or other similar counsels; accounting outsourcing providers; support outsourcing providers including our distributors. |
| Marketing | Our legitimate interests | Marketing services providers. | |
| Providing support | Our contract with you | Support outsourcing providers including our distributors | |
| Cross-sales marketing | Your consent | In case there is a third-party processor, you will be provided with information about them in the consent form. | |
| Facilitating your payment transactions | Compliance with legal obligations; Our contract with you | Correspondent banks; financial institutions that we have contracted to enable us to provide effectively myPOS Service to our customers; auditors; legal or other similar counsels; regulators | |
| Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators | |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Phone number | Opening your account and maintaining our legal relationships | Our contract with you or in order to take steps prior to entering into a contract; | Legal or other similar counsels; support outsourcing providers including our distributors |
| Marketing | Our legitimate interests | Marketing services providers | |
| Providing support | Performance our contract | Support outsourcing providers including our distributors | |
| Cross-sales marketing | Your consent | In case there is a third-party processor, you will be provided with information about them in the consent form. | |
| Facilitating login to our platform | Our contract with you | None; | |
| Risk and compliance analysis and action | Compliance with legal obligations. | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators; | |
| Customer authentication | Compliance with legal obligations | Communication service providers; legal or other similar counsels; support outsourcing providers including our distributors | |
| Communicating important messages regarding the Service | Compliance with legal obligations | Communication service providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Enforce our legal claims arising from any chargebacks, negative balance or similar obligation towards us | Exercise or defence of our legal claims | lawyers; debt collection agencies; competent courts, arbitration tribunals and similar | |
| Nationality | Opening your account and maintaining our legal relationships | Our contract with you or in order to take steps prior to entering into a contract | Our auditors; legal or other similar counsels; accounting outsourcing providers; support outsourcing providers including our distributors |
| Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators | |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Opening your account and maintaining our legal relationships | Our contract with you or in order to take steps prior to entering into a contract; | Legal or other similar counsels; support outsourcing providers including our distributors | |
| Marketing | Our legitimate interests | Marketing services providers | |
| Providing support | Our contract with you | Support outsourcing providers including our distributors | |
| Cross-sales marketing | Your consent | In case there is a third-party processor, you will be provided with information about them in the consent form | |
| Facilitating login to our platform | Our contract with you | None | |
| Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators | |
| Communicating important messages regarding the Service | Compliance with legal obligations | Communication service providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Enforce our legal claims arising from any chargebacks, negative balance or similar obligation towards us | Exercise or defence of our legal claims | lawyers; debt collection agencies; competent courts, arbitration tribunals and similar | |
| Registered address | Opening your account and maintaining our legal relationships | Our contract with you or in order to take steps prior to entering into a contract; defence of our legal claims | Our auditors; legal or other similar counsels; debt collection agencies; accounting outsourcing providers; support outsourcing providers including our distributors; competent authorities |
| Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators | |
| Facilitating your payment transactions | Compliance with legal obligations; Our contract with you | Correspondent banks; financial institutions of your payee; top-up providers; auditors; legal or other similar counsels; regulators | |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Official ID Document, type of ID and all data contained in it | Opening your account and maintaining our legal relationships | Our contract with you or in order to take steps prior to entering into a contract; defence of our legal claims | Our auditors; legal or other similar counsels; debt collection agencies; accounting outsourcing providers; support outsourcing providers including our distributors; competent authorities |
| Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators | |
| Facilitating your payment transactions | Compliance with legal obligations; Our contract with you | Correspondent banks; financial institutions of your payee; top-up providers; auditors; legal or other similar counsels; regulators | |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Identity Verification Information (recordings of your video call (if applicable) with our staff and/or verification selfie; photographs of the user registering for myPOS Service; photographs of a passport or of the front and rear sides of any other official ID document – yours or the document of the person, who is opening the account) | Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators. |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Information about your tax status | Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Source of income, annual estimate over the account, business activity details | Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators |
| Marketing | Legitimate interests | Marketing services providers; marketing consultants; SEO and other similar software or consultancy providers; other similar providers | |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Turnover | Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators |
| Marketing | Legitimate interests | Marketing services providers; marketing consultants; SEO and other similar software or consultancy providers; other similar providers | |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Device ID and log data | Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; regulators |
| Customer authentication | Compliance with legal obligations | Communication service providers; legal or other similar counsels; support outsourcing providers including our distributors | |
| Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity | Legitimate interests | Support outsourcing providers including our distributors; software outsourcing providers; legal or other similar counsels; regulators | |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Facilitating use of our platforms | Our contract with you | None | |
| Location | Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators |
| Login credentials | Customer authentication | Compliance with legal obligations | None |
| Facilitating use of our platform | Our contract with you | None | |
| Providing support | Our contract with you | Support outsourcing providers including our distributors | |
| Contact list | Providing you with an easy way to access certain features of the myPOS, like sending payment requests or payment links with myPOS Service | Your consent | None |
| Data, collected in relation to interactions with our App | Facilitating use of our platform | Our contract with you | None |
| Personalize, Measure, and Improve our Advertising and Marketing | Our legitimate interests | Marketing services providers | |
| Operate, protect, improve, and optimize the myPOS Service and your experience, such as by performing analytics and conducting research | Our legitimate interests | Marketing services providers | |
| Providing support | Our contract with you | Support outsourcing providers including our distributors | |
| Data, collected in relation to interactions with our support team | Providing support | Our contract with you | Support outsourcing providers including our distributors |
| Risk and compliance analysis and action | Compliance with legal obligations. | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Data, collected in relation to interactions with our Social media channels | Personalize, Measure, and Improve our Advertising and Marketing; Review and use of public comments and opinions made on social networking sites (e.g. Facebook and Twitter) to better understand our customers and our provision and development of myPOS Service | Our legitimate interests | Marketing services providers; marketing consultants; SEO and other similar software or consultancy providers; other similar providers |
| Data, provided in relation to participations in games, quizzes and completion of questionnaire or a contest entry form for promotional campaigns | Provide you with the option to participate in the respective event | Your consent | Marketing services providers |
| Personalize, Measure, and Improve our Advertising and Marketing | Your consent | Marketing services providers | |
| Geolocation (only if activated by you in the mobile app) | Customer authentication | Compliance with legal obligations | Communication service providers; legal or other similar counsels; support outsourcing providers including our distributors; regulators |
| Detect and prevent fraud, abuse, security incidents, and other harmful activity by blocking myPOS Service or by applying other fraud prevention measures | Legal obligations | Software outsourcing providers; compliance outsourcing providers; PEN test and other similar auditors; PCI DSS auditors; legal counsels; other similar consultants | |
| Providing you location-based services | Your consent | Support outsourcing providers including our distributors | |
| Risk and compliance analysis and action | Compliance with legal obligations. | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Usage Information | Collection of crash reports and other statistical information | Our legitimate interest | Support outsourcing providers including our distributors |
| Analysing our app’s performance and user experience | Our legitimate interest | Third-party development or implementation providers (anonymized data only); | |
| Delivery address | Delivering of products/documents, such as POS terminals; Marketing | Our contract with you | Competent Authorities, Auditors, Law Firms, Courier Companies |
| Proof of address or other verification data, which we may request depending on your particular situation | Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Shareholding information in your organisation | Due diligence | Compliance with legal obligations | Our auditors; legal or other similar counsels; compliance outsourcing providers; regulators |
| Risk and compliance analysis and action | Compliance with legal obligations | Blacklist and/or sanction list database providers; compliance and risk outsourcing providers; legal or other similar counsels; regulators | |
| Payment Transaction and other Account data, use of our e-money and payment service, including IBAN and Wallet IDs and balance. | Initiate a payment, send or request money, acceptance of card payment, funding transaction of your myPOS account | Our contract with you | Other participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; regulators |
| Authenticate your access to your myPOS Account or your payment instrument | Our contract with you | Other participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; regulators | |
| Communicate with you about your myPOS Account and payment instruments | Our contract with you | Other participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; regulators | |
| Create an account connection between your Account and a third-party account or platform, if applicable | Our contract with you | Other participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; regulators | |
| Perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes | Legitimate interests and in some situations – legal obligation | Credit bureaus; database operators; legal consultants; regulators | |
| Detect and prevent fraud, abuse, security incidents, and other harmful activity by blocking myPOS Service or by applying other fraud prevention measures | Compliance with legal obligations | Software outsourcing providers; compliance outsourcing providers; PEN test and other similar auditors; PCI DSS auditors; legal counsels; other similar consultants | |
| Comply with any legal enforcement or authority request | Compliance with legal obligations | Your counterparties, bailiffs, courts, regulators, lawyers, insolvency practitioners, liquidators, debt collection agencies, arbitration tribunals and other similar persons that might have a claim or are servicing one against you, or have initiated a valid legal proceeding against you | |
| Enforce our legal claims arising from any chargebacks, negative balance or similar obligation towards us | Exercise or defence of our legal claims | lawyers; debt collection agencies; competent courts, arbitration tribunals and similar | |
| Information in relation to the provision, improvement and development of the myPOS Service and myPOS Online Store | Accept, process and administer online orders for myPOS Terminals | Our contract with you | Our distribution network; outsourcing providers; our consultants |
| Process purchase payments, issue invoices and or other kind of payment documents for the processed order; | Our contract with you; Our legal obligations | Our distribution network; outsourcing providers; our consultants | |
| To organize shipment of ordered myPOS Terminal | Our contract with you | Our distribution network; outsourcing providers; our consultants | |
| To manage return procedure and refunds for defected devices | Our contract with you | Our distribution network; outsourcing providers; our consultants | |
| Specific client identifiers, and, where applicable, other data such as registered address for a particular service and other similar | Initiate a payment, send or request money, acceptance of card payments, top-up, payments toward specific merchants or entities | Our contract with you | Other participants in your transactions and their financial institutions; correspondent banks; payment scheme operators; support outsourcing providers including our distributors; legal counsels; our auditors; top-up providers; specific merchants or entities; regulators |
| Cookies and other tracking technologies | The use of cookies and other tracking technologies is described in our Cookie Policy | ||
IV. Specific data sharing.
In any case, we may share any of your information for specific reasons, outlined below:
1. With other members of the myPOS and iCard AD’s corporate family: We may share your Personal Data with members of the myPOS and iCard Group of companies or within our extended family of companies that are related by common ownership or control, so that we may provide the Services you have requested or authorized or to manage the risk, or to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of myPOS Services and communications.
2. With our distributors: We may share information related to you or your company with our distributors, which help us to provide you with the best myPOS experience. Our distributors may help us in onboarding you or your company, with your transactions, myPOS terminal orders and other similar activities, for which they may process some of your personal information.
3. Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. With our legal counsels for the purposes of protecting our legal rights. We may share any information which is necessary to protect our legal rights to legal counsels or similar parties.
5. Monitoring. We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes. When visiting our offices, CCTV, access control systems and/or other monitoring systems may be in operation.
6. Business Transfers. If any of the companies that provides myPOS Services is involved in any merger, acquisition, reorganization, sale of assets, transfer of portfolio, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred to a different legal person and/or becomes subject to a different privacy policy.
7. Credit offerings. In some markets, we may have provided the option to receive credits/loans from third-party loan provides through the myPOS platform.
Where we have shown a pre-approval for a specific loan in your myPOS account, this has been done solely on anonymized data shared to such third-party loan providers. Therefore, these loan providers do not hold any personal data about you or the persons related to your business at the pre-approval stage.
However, in case you decide to enter into a relationship with said third-party loan provides through the myPOS platform, we will share certain information about you and your use of the myPOS service to these loan providers, namely:
- any information that is required by the loan provider for “Know-your-customer” purposes, which may include any copies of official ID documents of you and the persons related to your business, UBO information, etc.
- in case you are operating your business as a as a natural person, certain transactional data, such as your historic transactional volumes and types of transactions or the transactions themselves, for the last 12 to 24 months. This data is not considered personal if you are operating as a legal entity.
- Other related information, as explained in the third-party loan provider’s own privacy policy or notice, which you will be provided with during the process of credit approvement.
Please be aware that after you have agreed with the relevant terms and conditions of the third-party loan provider and we have consequently forwarded the abovementioned personal data to such third-party loan provider, it will process your personal data as a data controller according to their own privacy policy or notice, which shall be made available to you as explained above. We are not responsible for any further processing done by such third-party loan provider(s) and you should address any complaints related to their use of your data to said third-party loan provider(s).
V. Decisions based solely on automated processing.
Sometimes, our systems may take decisions based solely on automated processing. This does not mean that we will always use automated decision making for these processing activities. In case you believe that you have been unfairly treated by our automated decision-making systems you may ask that a person reviews the decision at all times by contacting us as described in the “How do I complain?” section. Such decisions may be done for processing activities that include:
| Processing activity | Automated processing logic |
|---|---|
|
Detect and prevent fraud, abuse, security incidents, and other harmful activity by blocking myPOS Service or by applying other fraud prevention measures. |
Our fraud-prevention and monitoring systems may sometimes take automated decisions in regards to suspicious behavior. For example, we may block a certain transaction which was made in a remote part of the world just a few minutes after your last login from your home country. |
VI. Information collected about you from third parties.
We may ask certain entities for information about you when you are enrolling for our services.
Such entities are generally fraud prevention agencies and Know Your Customer and Anti Money Laundering Checkup service providers which help us to fulfil our legal obligations for due diligence on our customers.
We may also collect information about you from public sources for Anti Money Laundering reasons or market research. This includes:
- official public records, like your national Company register;
- information published by the press or on social media.
In case you use any of the linked services, provided by one of our partners, such as the insurance services, they may share details with us about your deal.
VII. Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information to provide myPOS Service to you, you can request that we erase your personal information and close your myPOS Account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevent us by law to close your account or terminate the Service. In case the Data Controller is a regulated financial institution, such as credit institution, E-money institution or similar, such Data Controller is obliged under PSD and AML laws to keep your personal information and all transactions history for a period of 5 years after the termination of the relation with you (or where the laws of the United Kingdom of Great Britain and Northern Ireland are applicable – for a period of 6 years). Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing security. For example, if we suspend a myPOS Account for fraud or safety reasons, we may retain certain information from that myPOS Account to prevent that client from opening a new myPOS Account in the future. We are also obliged to retain personal data which we have collected for the purposes of complying with the relevant anti-money laundering and anti-terrorism financing for a period as defined under the applicable law.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, myPOS may keep some of your information for tax, legal reporting and auditing obligations.
Because we maintain our records in a manner protecting from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
In case you started bud did not finish an application for a myPOS account on the myPOS platform, we will retain your contact information for a period of 12 months after the creation, based on our legitimate interests. During this period, we will try to help you finish your application by sending you helpful emails, reminders and, in some cases, discounts. You can unsubscribe from these emails by clicking the unsubscribe button on any of them, found in the footer, or contacting us at [email protected]
VIII. Your rights.
You may exercise any of the rights described in this section before the respective Data Controller pursuant to the Legal Agreements by sending an email from your e-mail registered for myPOS Service to the respective Company providing the Service to you under the respective Legal Agreement stated below. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.
8.1. Managing Your Information.
You have the right to obtain the following:
- confirmation of whether and where we are processing your personal data;
- information about the purposes of the processing;
- information about the categories of data being processed;
- information about the categories of recipients with whom the data may be shared;
- information about the period for which the data will be stored (or the criteria used to determine that period);
- information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing;
- information about the existence of the right to complain to any Regulator;
- where the data was not collected from you, information as to the source of the data; and
- information about the existence of, and an explanation of the logic involved in, any automated processing.
- Additionally, you may request a copy of the personal data being processed.
8.2. Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to myPOS Account).
8.3. Data Access and Portability.
You have the right to:
- receive a copy of your personal data in a structured, commonly used, machine-readable format that supports re-use;
- transfer your personal data from one controller to another;
- store your personal data for further personal use on a private device; and
- have your personal data transmitted directly between controllers without hindrance.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.
Because we maintain the myPOS to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
8.4. Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.
8.5. Objection to Processing.
In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling for marketing purposes) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims. Please note that Data Controllers which are regulated financial institutions, such as credit institutions, E-money institutions or similar are obliged under AML laws to make risk profiling of their customers upon opening of the relationship and constantly during the relationship and this is a legitimate reason. In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, you shall have to close your account or we may have to stop providing you some or all of the Services, subject to all conditions for the closing of the account, specified above in this Section.
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us.
Please bear in mind that irrespective of your opt-out, related to marketing messages, you will still continue to receive specific messages, which we are required to send you under the applicable legislation, insofar as you still have a legal relationship with us.
8.6. How do I complain?
You should in first place try to resolve the matter by sending an e-mail to the respective Data Controller under this Privacy Policy from your registered e-mail for the Service:
Where the responsible Data Controller (as outlined in the introduction of the Privacy Policy) is specified to be myPOS Payments Ltd, UK you may contact us at:
Data Protection Officer (DPO):
[email protected]
myPOS Payments Ltd
The Shard, Level 24
32 London Bridge Street
London,
SE1 9SG
Where the responsible Data Controller (as outlined in the introduction of the Privacy Policy) is specified to be iCard AD, Bulgaria, you may contact us at:
Data Protection Officer (DPO):
[email protected]
iCARD AD
Business Park Varna No B1, Varna 9023, Bulgaria
Where the responsible Data Controller (as outlined in the introduction of the Privacy Policy) is specified to be myPOS Services OOD you may contact us at:
Data Protection Officer (DPO):
[email protected]
myPOS Services OOD
Business Park Varna No B1, Varna 9023, Bulgaria
Competent Regulator. In case you are not satisfied with the reply or resolution of the respective Data Controller, you have the right to lodge complaints about the data processing activities carried out by us before the competent data protection supervisory authorities as described below.
If the Data Controller responsible for the respective data processing, subject to your complaint, is myPOS Payments Ltd. UK you have the right to file a complaint with its lead supervisory authority, the Information Commissioners Office, UK:
Address:
Wycliffe House
Water Lane
Willmslow
Cheshire
SK9 5AF
e-mail: [email protected]
If the Data Controller responsible for the respective data processing, subject to your complaint, is iCard AD, Bulgaria you have the right to file a complaint with its lead supervisory authority, Commission for Protection of Personal Data, Bulgaria:
Address:
Sofia 1592
2 Prof. Tsvetan Lazarov blvd.
e-mail: [email protected]
If the Data Controller responsible for the respective data processing, subject to your complaint, is myPOS Services OOD, Bulgaria you have the right to file a complaint with its lead supervisory authority, the Commission for Protection of Personal Data, Bulgaria:
Address:
Sofia 1592
2 Prof. Tsvetan Lazarov blvd.
e-mail: [email protected]
IX. Operating globally.
To facilitate our global operations we may be required to transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer store and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.
X. International transfers.
10.1. Adequacy Decisions.
Where we disclose any of your collected personal information outside EEA, we shall comply with any relevant adequacy decision, where possible.
10.2. Other Means to Ensure an Adequate Level of Data Protection.
In case personal information is shared with corporate affiliates or third-party service providers outside the EEA in absence of an adequacy decision, we have - prior to sharing your information with such corporate affiliate or third-party service provider – established the necessary means to ensure an adequate level of data protection and a valid legal ground under the applicable data transfer rules. We will provide further information on the means to ensure an adequate level of data protection on request.
Protection of personal data transferred from or to the United Kingdom of Great Britain and Northern Ireland in the absence of an adequacy decision:
In the absence of an adequacy decision after the United Kingdom of Great Britain and Northern Ireland leaves the European Union, we shall enter into Data processing agreements, including Standard contractual clauses for data transfers between EU and non-EU countries, with our new or existing vendors or similar parties from the United Kingdom of Great Britain and Northern Ireland.
XI. Security.
We take the responsibility to ensure that your personal information is secure, kept in an encrypted from on servers, collocated in Special data centers in Class A jurisdictions in Europe. To prevent unauthorized access or disclosure of information we maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard non-public personal information. Once you are logged into your Account, all internet communication is secured using Secure Socket Layer (SSL) technology with High-grade security Encryption (AES-256, 256 bit keys, certified by StartCom Ltd). We restrict access to your personally identifiable information only to employees who need to know that information in order to provide products or services to you.
If you know or have reason to believe that your myPOS Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your myPOS Account, please contact us following the instructions in the Contact Us section below. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.
XII. Can Children Use Our Services?
myPOS Service is not designed to individuals under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use myPOS Service. If we obtain actual knowledge that we have collected Personal Data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.
XIII. Changes to this privacy policy.
We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on myPOS Platform. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of myPOS Platform will be subject to the revised Privacy Policy.
XIV. Contact us.
If you have any questions or complaints about this Privacy Policy or our information handling practices, you may email us from your registered e-mail for the Services to the e-mails stated above in pt. 8.6 (How do I Complain).