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INTRODUCTION

Welcome to UAB HowToPay’s privacy notice for www.howtopay.com

UAB HowToPay. respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  • Important information and who we are
  • Purpose of this privacy notice
 

This privacy notice aims to give you information on how UAB HowToPay. collects and processes personal data we collect from you or that you provide to us or that we obtain from third parties through your use of this website, through providing you with our services in accordance with our terms and conditions and when you make an application to use of services through the website or when you lodge a query through the website.

This website and our services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with our terms of service and any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

  • Controller

UAB HowToPay. is the controller and responsible for your personal data (collectively referred to as “UAB HowToPay”, “we“, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

  • Contact details

Our details are:

Full name of legal entity:UAB HowToPayName or title of data privacy manager:Paul KnightEmail address:support@howtopay.comPostal address:Rigistrasse 2, Zug, 6300, Switzerland  

You have the right to make a complaint at any time. We would, however, appreciate the chance to deal with your concerns so please contact us in the first instance.

  • Changes to the privacy notice and your duty to inform us of changes
 

This version was last updated on 23 October 2020.

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.

  • Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  • 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:

§  Identity Data  includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

§  Contact Data  includes billing address, delivery address, email address and telephone numbers.

§  Financial Data  includes bank account and payment card details.

§  Transaction Data  includes details about payments to and from you and details of contracts you have entered into.

§  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.

§  Profile Data includes your username and password, preferences, feedback and survey responses.

§  Usage Data  includes information about how you use our website, products and services.

§  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 may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

We do not 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 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 goods or services). In this case, we may have to terminate the contract you have with us but we will notify you if this is the case at the time.

  • 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, Transaction and Financial Data by filling in forms or by corresponding with us via our website or API or by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply to use our services;
  • create an account on our website;
  • give us some feedback or lodge a query
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs 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.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Identity, Contact Transaction and Financial Data. Our client who shares your personal data with us so that (a) you can use our services on their behalf; and (b) they can pay money to you (for example, your salary if you are their employee or payment for goods and/or services if you are their supplier).
  • Technical Data from the following parties:
  • analytics providers such as Google based outside the EU;
  • advertising networks such as Google based inside OR  outside the EU; and
  • search information providers Google based inside OR  outside the EU.
  • Electronic Identity Verification providers from data brokers or aggregators such as Trulioo based inside OR  outside the EU.
  • We may also record and verify personal identity documents such as passports electronically including screen grabs 
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
  • In order to provide contracted services, we may need verify details with Credit Reference agencies, anti-Fraud agencies, Sanction screening and politically exposed persons listings. 
  • How we use your personal data

We will only use your personal data when the law allows us to. 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;

do not override those interests; and

2.    where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights

3.    where we need to comply with a legal or regulatory obligation.

Please see paragraph 4.2 (purposes for which we will use your personal data) to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party 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.

  • 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.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interestTo register you or your employer / company as a new client(a) Identity(b) ContactPerformance of a contract with your employer / companyTo process and deliver the services including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)To execute payments on your behalf (send money to beneficiaries).(a) Identity(b) Transaction(a) Performance of a contract with you.(b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(c) Necessary to comply with a legal obligation including Regulation (EU) 2015/847 on information accompanying transfers of funds (commonly referred to as the revised wire transfer regulation).To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey(a) Identity(b) Contact(c) Profile(d) Marketing and Communications(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)To enable you to partake in a prize draw, competition or complete a survey(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how clients use our services, to develop them and grow our business)To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity(b) Contact(c) Technical(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligationTo deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) TechnicalNecessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)To use data analytics to improve our website, products/services, marketing, client relationships and experiences(a) Technical(b) UsageNecessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity(b) Contact(c) Technical(d) Usage(e) ProfileNecessary for our legitimate interests (to develop our products/services and grow our business)
  • Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our website or by contacting us (see contact information at paragraph 1.3 above). You can also unsubscribe from any email marketing using the links provided in the emails we send to you.

  • 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).

  • Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the HTP group of companies for marketing purposes.

  • Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

  • Change of purpose

We will only use your personal data for the purposes for which we collected or received 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.

  • Disclosures of your personal data
  • We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.2 (purposes for which we will use your personal data) above.
  • Internal Third Parties as set out in the paragraph 10 (Glossary).
  • External Third Parties as set out in paragraph 10 (Glossary).
  • 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 notice.
  • 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.
  • International transfers
 
  1. Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
  1. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  1. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  1. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
  1. Please contact us  if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
 
  • Data security
  1. 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.
  2. 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.
  • Data retention
  • How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.

By law we have to keep basic information (including Contact, Identity, Financial and Transaction Data) about our clients, their directors, partners and ultimate beneficial owners and payees for five years after they cease being clients for the purpose of compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations.

In some circumstances you can ask us to delete your data: see “Request erasure ” below for further information.

In some circumstances we may 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.

  • Your legal rights

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

      1. Request Access to your personal data. 

      2. Request Correction of your personal data.

      3. Request erasure of your personal data.

      4. Object to processing of your personal data.

      5. Request restriction of processing your personal data.

      6. Request transfer of your personal data. 

      7. Right to withdraw consent. 

 

Paragraph 11 provides more detail about these rights.

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

  • 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 may refuse to comply with your request in these circumstances.

  • 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.

  • Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

  • Glossary
 

LAWFUL BASIS

Legitimate Interest  means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation  means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

1. Our banking providers and their compliance auditors who require access to your personal data to ensure that we and they are complying with each of our regulatory obligations; 

2. Other Payment service providers and intermediaries to comply with the Wire Transfer Regulations; 

3. Other service providers acting as payment processors based within the UK, EEA, Canada and the USA who provide IT and system administration services;

  • Your legal rights (further information)

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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.

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