Payz Privacy Policy

This document was last updated on May 10, 2023.

This is the Payz Privacy Policy applicable to Payz Services, as defined below. PSI-Pay provides Payz Services to both Users and Business Entities (as defined below), thus this Privacy Policy applies to both and should be read and interpreted accordingly.

This Privacy Policy applies to PSI-Pay Ltd.

Our Privacy Policy may be made available in several languages; all versions are legally binding, but in the event of inconsistency between English version and a translated version, English version prevails.

1. Definitions

“Business Entity” – a legal person, commercial or business entity that meets all the eligibility requirements set in the Terms of Use for the Business Entity Account and that opens and holds a Payz account and is enabled to use Payz Services.

“customer” – means a User or Business Entity.

“Payz” – Our (PSI-Pay) brand name.

“eMoney” – monetary value stored in electronic form issued by PSI-Pay under the relevant national laws of the United Kingdom and applicable regulations of the European Union and the Terms of Use.

“Payz Services” – innovative payment services provided by PSI-Pay and based on eMoney issued by PSI-Pay upon demand and for the account of Users and Business Entities and including activities required for operations with a Payz account, identity verification and security checks, execution of Transactions, receipt of eMoney transfers, issuance and redemption of eMoney and other activities, as described in the Terms of Use.

“EEA” – the European Economic Area.

“Mobile Application” – an information technology solution available on Mobile Devices exclusively to Users for accessing and partly using Payz Services. We may make this service available to Business Entities in the future.

“Mobile Device” – a portable computing device such as a smartphone or tablet computer.

“non-personal information” – information on which basis an individual is not distinguishable from other individuals, including anonymised personal information.

“personal information” – information that relates to an individual and on that basis makes the individual distinguishable from other individuals.

“process” or “processing” – means collecting, storing, using, disclosing or transferring of personal information and non-personal information.

“PSI-Pay”, “We”, “Us” or “Our” – PSI-Pay Ltd., a company incorporated under the laws of England and Wales and authorised by the Financial Conduct Authority of the United Kingdom to issue electronic money and to provide payment services as described in the Terms of Use.

“Privacy Policy” – this Privacy Policy concerning Payz Services and Website, as may be amended from time to time.

“Terms of Use” – the Terms of Use for the User Account or the Terms of Use for the Business Entity Account, as may be amended from time to time.

“User” – an individual who meets all the eligibility requirements set in the Terms of Use for the User Account and that opens and holds a Payz account and is enabled to use Payz Services.

“Website” – the website branded as Payz and referring to domain https://test.payz.com/. The term “Website” also includes reference to a Mobile Application in this Privacy Policy, when applicable.

“You”, “Your” or “Yourself” – an individual who is applying, accessing or using Payz Services either on his or her own account or on behalf of a Business Entity. This includes, an individual acting as a User or as a prospective User, or an individual acting on behalf of a Business Entity, including any principals (the managing and financial directors, other directors and officers, shareholders, partners and beneficial owners of the Business Entity), as well as any member of staff or an employee accessing or using Payz Services on behalf of a Business Entity.

Other terms not provided in the preceding paragraphs are used in this Privacy Policy, too. Please check the Terms of Use for the meaning of capitalized terms that are not provided in this Privacy Policy.

What We use Your personal information for	Our reasons	Our legitimate interests
To provide Payz Services and to manage Our business needs:
– To manage Our relationship with You (or with the Business Entity You represent) and Our customers. – To provide advice or guidance about Payz Services. – To collect and recover funds that are owed to Us. – To respond to complaints and seek solutions for them. – To communicate with You and to tell You about changes to Payz Services. – To manage how We work with Our business partners and other organisations providing services to Us and Our customers. – To exercise Our rights and obligations set out in the Terms of Use and other contracts concluded between Us and You (or the Business Entity You represent). – To run Our business in an efficient and proper way. This includes managing Our financial situation, corporate governance, and audit.	– Fulfilling contract. – Our legitimate interests. – Our legal duty.	– Being efficient about how We fulfil Our legal and contractual duties. – Keeping Our records up to date. – Complying with applicable laws. – Managing Our everyday business needs.
To manage Our relationship with You (or the Business Entity You represent):
– To provide Payz Services to You (or to the Business Entity You represent) and Our customers. – To process or execute Transactions, eMoney transfers sent to You (or to the Business Entity You represent), to process Your (or the Business Entity’s You represent) request to purchase eMoney or redeem eMoney from Your (or the Business Entity’s You represent) Payz account. – To manage Fees, charges and currency exchange rates due on Our customer accounts. – To facilitate the collection or redemption of any points or other rewards in respect of any of Our loyalty programme.	– Fulfilling contract. – Our legitimate interests. – Our legal duty.	– Being efficient about how We fulfil Our legal and contractual duties. – Keeping Our records up to date. – Complying with applicable laws.
To manage risks and protect Payz Services:
– To authenticate Your (or the Business Entity’s Your represent) access to Payz account. – To keep Payz Services safe and secure. – To carry out Our identity and security validation and verification checks. – To detect, investigate, report and prevent financial crime, fraud and money-laundering. – To detect and prevent abuse of Payz Services. – To manage risk for Us, Our customers and Our business. – To obey any applicable law requirements.	– Fulfilling contract. – Our legitimate interests. – Our legal duty.	– Developing and improving how We deal with financial crime, fraud and money-laundering, as well as doing Our legal duties in this respect. – Complying with applicable laws. – Being efficient about how We fulfil Our legal and contractual duties. – Managing Our everyday business needs.
To administer Payz Services and Our Website:
– To allow Our customers to participate in interactive features of Payz Services and the Website. – To administer Payz Services and Payz accounts. – To administer the Website and to improve its performance. – To analyse Our customer behaviour and preferences, to analyse trends and to manage the load on Our servers.	– Fulfilling contract. – Our legitimate interests. – Our legal duty.	– Being efficient about how We fulfil Our legal and contractual duties. – Developing new products and services. – Managing Our everyday business needs.
To render, develop and improve Our business:
– To develop, manage and enhance Our brand and Payz Services, and the Website. – To develop new ways to meet Our customers’ needs and to grow Our business. – To test new products and services. – To conduct market analysis and strategic planning. – To study how Our customers use Payz Services and other services similar to or connected with Payz Services. – To measure and understand the effectiveness of advertising of Payz Services.	– Fulfilling contract. – Our legitimate interests. – Our legal duty.	– Developing new products and services, and what We charge for them. – Defining types of customers for new products or services. – Being efficient about how We fulfil Our legal and contractual duties. – Keeping Our records up to date. – Assessing which of Our products or services may interest Our customers. – Managing Our everyday business needs.
Marketing:
– To develop and carry out marketing activities. – To establish Our customer eligibility to receive special features, promotions, products and services. – To deliver relevant advertising to Our customers.	– Your consent. – Fulfilling contract. – Our legitimate interests. – Our legal duty.	– Keeping Our records up to date. – Assessing which of Our products or services may interest Our customers and telling about them. – Seeking Your consent when We intend to inform You about special features, promotions, products and services.

Group	Description	Type of personal information that could be included within the group
Financial data	Our customers’ financial position, status and history.	– Financial information. – Payment instrument details (credit/debit card details, card number, card expiry date, CVC details, bank and/or card issuer details, bank account details). – Information that We receive from Our business partners, sub-contractors and other organisations providing services to You (or the Business Entity You represent), for example, financial data and data received from credit reference and fraud prevention agencies.
Contact	Our customers’ contact information.	– First name/last name. – Date of birth. – Nationality. – Country of residence. – E-mail address. – Address (residence, postal address), including copies of proof of address. – Phone number (landline/mobile phone number. – Photograph.
Transaction data	Details about Transactions, eMoney transfers sent to Our customers, information on Our customer requests to purchase eMoney or redeem eMoney from their Payz accounts.	– Type, amount and time of a Transaction, eMoney transfer, purchase of eMoney or redemption of eMoney. – Transaction details (geographical location, IP address and country, recipient’s e-mail address, phone number). – Additional commercial information and identification information. – Fingerprint of the device used to access Payz account. – Any other information You provide.
Contractual	Details about You and Payz Services provided.	– First name/last name. – Date of birth. – Nationality. – Country of residence. – E-mail address. – Address (residence, postal address), including copies of proof of address. – Phone number (landline/mobile phone number. – Payment instrument details (credit/debit card details, card number, card expiry date, CVC details, bank issuer details, bank account details). – Information about login details (login user name, password, authentication data (if a two-step verification system (strong customer authentication) is used) and other security credentials (i.e. secure identification, security questions and answers)).
Locational	Information We get about where You, such as may come from the device You use to access Your (or the Business Entity’s You represent) Payz account, including the address from which You connect the said device to the Internet.	– Geographic location, including access real-time location based information. – IP address and country. – Fingerprint of the device used to access Payz account.
Behavioural and Technical (collected by cookies. Please see Our Cookie Policy)	Details about how You (or the Business Entity You represent) use Payz Services and the Website and details on the devices and technology You (or the Business Entity You represent) use.	– IP address and country. – Information about login details (login user name, password, authentication data (if a two-step verification system (strong customer authentication) is used) and other security credentials (i.e. secure identification, security questions and answers)). – Access time of the Website. – Website response times. – Length of visits of certain pages of the Website. – The internet browser type, version, time zone setting, plug in types and versions, operating system and platform. – Full Uniform Resource (URL) clickstream. – Fingerprint of the device used to access Payz account.
Communications	Information that We learn from You (or from the Business Entity You represent) letters, emails, and conversations, either textual or oral, with Us.	– Your comments and opinions disclosed in Your communications, for example, content of a complaint or question submitted to Us.
Social Relationships	Information about Your family members, friends and other relationships.	– First name/last name. – Date of birth. – Nationality. – Country of residence. – E-mail address.
Open data and Public Records	Details about You that are in public records and information about You openly available on the Internet.	– Your comments and opinions made on social network sites (i.e. Facebook or Twitter) about Us, Payz Services, other services similar to or connected with Payz Services, and other products and services that are or may be provided by Us. – Public records.
Usage data	Other information about Your (or the Business Entity’s You represent) use of Payz Services, other services similar to or connected with Payz Services, and other products and services that are or may be provided by Us.	– Information that We receive from Our business partners, sub-contractors and other organisations providing services to You (or the Business Entity You represent), for example, financial data and data received from credit reference and fraud prevention agencies.
Documentary data	Details about You that are stored in documents in different formats, or copies of them.	– Government issued photo identification. – Details of passport/ identity card/ drivers licence or birth certificate.
Special types of data	Applicable laws treat some types of personal information as special. We will only collect and use these types of information if it is permitted under the applicable laws.	This includes information on Your: – Trade union membership. – Health data, including gender. – Criminal convictions and offences.
Consents	Any permissions, consents or preferences that You give Us.	– Consent to receive offers for special features, promotions, products and services from Us. – Consent to collect real-time location based information.
National identifier	A number or code given to You by a government to identify who You are.	– Social security number/tax code. – Details of passport/ identity card/ drivers licence or birth certificate.

Payz Privacy Policy

1. Definitions

2. About PSI-Pay

3. Privacy statement

4. Collection of personal information

5. The purpose and legal basis for processing personal information

6. Personal information that We may process and groups of the personal information

7. Disclosure of collected personal information

8. Credit reference agencies

9. Fraud prevention agencies

10. Automated decision making

11. Transfer of personal information to other countries

12. Marketing

13. Retaining collected personal information

14. Your rights

15. Your consent and how to withdraw it

16. Children

17. If You choose not to give personal information

18. Use of "cookies"

19. Third party websites

20. Security

21. Changes to this Privacy Policy

22. Contacting Us and how to make a complaint