Privacy Policy

Effective Date: 29 November 2023

Version 2.0

For our recruiting privacy notice, please see here

IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy is issued on behalf of the Paydock Group so when we use the terms “Paydock”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Paydock Group responsible for processing your data, which is identified in the section “Country Specific Notices” and will depend on your location and the services you receive from Paydock. The following information applicable to all Paydock Group companies is complemented by the specific provisions described in the section “Country Specific Notices”.

Paydock is committed to adequately protecting your personal data regardless of where it is processed and regardless of your location.

Paydock is the processor of personal information collected and processed for the Services, unless stated otherwise.

OUR DATA PROTECTION OFFICER

Email address: [email protected]

Postal Address:
Data Protection Officer 

Paydock Ltd
Arquen House, 4-6 Spicer Street, 

St. Albans, England, AL3 4PQ

WHAT PERSONAL DATA DO WE COLLECT?

We use different methods to collect data from and about you. Data is collected through the following:

OUR WEBSITE

When you use our website, we may collect, use, store and transfer the following data:

• Information you give us while using our website. We may ask you to provide us with personally identifiable information while you use our website. This includes your full name, e-mail address, phone number and your website.
• Automated technologies or interactions. We may use cookies, server logs and other technologies, such as web beacons, to collect information that your browser sends us when you are using our website. This includes your computer’s internet protocol, browser type, browser version, the country from which you visited our website, how you arrived at our website, length of your visit and which pages you viewed. Please refer to our cookie policy for further information about how we use cookies and similar technologies.

OUR SERVICES

When you use our Services, we may collect, use, store and transfer the following personal data:

• Information you give us. We may collect personal data directly from you, as set out below:
  – Personal data collected from our customers. You will be required to provide us with personal data when you apply to become our customer. We may require you to provide us with additional personal data as you use our Services. If you are a customer applying to use our Services, we will collect, store and process personal data relating to you and other individuals associated with you, such as full name, email address, and other information as required to on-board you and meet applicable legal requirements. If you do not provide this data we will be unable to provide the Services to you.
• Information provided by third parties. We may collect personal data about you from third parties, as set out below:
  – When required for compliance with applicable laws, we may verify your information and collect information from publicly available sources, credit reference or fraud prevention agencies or check data against government sanction lists, either directly, or using identity verification providers or due diligence and screening information providers.
  – When marketing our Services, we may collect identity and contact data from publicly available sources.

HOW AND FOR WHAT PURPOSES WILL WE USE YOUR PERSONAL DATA

We have set out a description of the purposes we plan to use your personal data and the lawful basis for our processing activities below:

Purpose Activity	Type of Data	Legal basis for processing including basis of legitimate interest
Marketing activities and communications	Identity and contact details	Consent
To provide our services to you, including managing our relationship with you as a user of our services	Identity and contact details	Performance of a contract with you
To manage access to our services and ensure our platform is secure	Identity and contact details	Legitimate interest – to provide the services to you in a secure way which safeguards your data
To use data analytics to improve our website, marketing, customer relationships and experiences	Technical, device and usage details	Consent

We do not use automated decision making as part of our processing of your data.

For details about the purposes for which we plan to use your personal data and the lawful basis for the processing activities in connection with our recruitment activities, please see our recruiting privacy notice here.

If you are an employee of the Paydock group, for details about the purposes for which we plan to use your personal data and the lawful basis for the processing activities in connection with employment in the Paydock group, please see our employee privacy notice which is available to you via our employee handbook.

NOTICE TO OUR CUSTOMERS

As part of our Services, you will transfer data to us about your customers (the end users of our services) and may instruct us to collect, use, transfer and disclose certain personal data about the end users when we act as your service provider. You are responsible for making sure that end users’ privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. You must comply with the personal data protection laws of your country of origin and of those countries in which you offer products or services and, in particular when processing and sending personal data to us in the context of using the Services and submitting transactions. If you entered into an agreement with us, you are also responsible for compliance with the requirements set out in our agreement.

DISCLOSURES OF YOUR PERSONAL DATA

Affiliates. Your information may be shared with our affiliates within the Paydock Group, to provide you with our Services. The relevant Paydock entity is the party responsible for overall management and use of your personal data.

Third-party service providers. We may also use third-party service providers acting on our behalf. These service providers help us with data and cloud services, website hosting, data analysis, application services, advertising networks, information technology and related infrastructure, customer service, communications and auditing.

Other third parties. We will share your personal data with third parties in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.

Safety, Legal Purposes and Law Enforcement. We may share your personal data with third parties to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of Paydock, our users, customers, employees or the public or as otherwise required by law. We also use and disclose your personal data as we believe necessary (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions, or our agreement and other agreements, as applicable; (iii) to protect our rights, privacy safety or property, and/or that of our affiliates, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

All our third-party service providers and other entities in the group are required to process the data in accordance with applicable data protection regulations and to take appropriate security measures to protect your personal information in line with UK/EU data protection standards and our policies.

We do not allow our third-party service providers to use your personal data for their own purposes.

In addition, when a third-party entity processes your personal data on our behalf and according to our instructions, we sign a written agreement with it that specifically describes its obligations with regard to security and data protection, in accordance with UK/European data protection laws. We only permit them to process your personal data for specified purposes.

WHEN WE PROCESS YOUR PERSONAL DATA AT THE DIRECTION OF OUR CUSTOMERS

When we are providing our Services to our customers, our customers will transfer personal data to us and will instruct us to collect, use, transfer and disclose certain personal data about their customers, the end users of our Services. In these circumstances we act as data processor and our customer acts as data controller.

When we receive end user data as part of our Services, we may collect, use, store and transfer the following personal data at the instruction of our customer:

• If the end user is a card-holder making a payment to a merchant using our Services to process the payment, we may, at the direction of the merchant using our payment optimization service, collect, store and process financial and transaction related personal data about you and your transaction. This may include the end user’s billing address, purchase amount, date of purchase, payment method, credit or debit card number, bank account information and additional necessary information required to process your transaction. The customer is the data controller and is responsible for providing appropriate privacy information to the end user about Paydock’s processing of the end user data on the customer’s behalf. If this data is not provided to us, we will be unable to provide complete transaction information to the payment service providers.
• When required for compliance with applicable laws, we may verify end user information and collect information from publicly available sources, credit reference or fraud prevention agencies or check data against government sanction lists, either directly, or using identity verification providers or due diligence and screening information providers.
• We may collect details about the end user device, transaction, computer’s internet protocol and other technical information, through our data security and firewall providers.

We have set out a description of the purposes we plan to use end user personal data below:

Purpose Activity	Type of Data
To process end user transaction data as part of our services	Identity, contact details and transaction details
To provide support services as part of our services	Identity, contact details and transaction details

In addition to the third parties listed in the section labeled “Disclosures of Your Personal Data”, we may share end user personal data with the following trusted third parties:

Business partners, payment industry suppliers and participants to end user transactions.  When we receive end user personal data and transaction data at the instruction of our customers, we may share end user personal data with our customers’ and our service providers, payment service providers and acquirers, as necessary to process payments or provide our Services. The information shared includes:

• Personal data necessary to facilitate the transaction and activities related to your transaction;
• Personal data to help resolve disputes and detect and prevent fraud; and
• Personal data and performance analytics to help our customers better understand the uses of their platform and to help our merchants enhance their customers’ experiences.

TRANSFER OF DATA OUTSIDE THE UNITED KINGDOM AND EUROPEAN ECONOMIC AREA (EEA)

We may share your personal data with members of the Paydock Group who are based outside of the UK/EEA. We may share your personal data with partners, suppliers or sub-processors based in countries outside of the UK/EEA.

We have taken specific steps, in accordance with UK/European data protection law, to protect your personal data. 

When your information is shared with affiliates within the Paydock Group in order to provide you with our Services, employees located in the United Kingdom, Australia and in other jurisdictions may have access to your personal data. These employees are subject to Paydock’s privacy policy and our internal controls over personal data.  Only employees who have a need to access personal data in the course of their employment have access to personal data.

Where data is transferred from the EEA to the UK, the transfer is covered by an adequacy decision of the European Commission.  Certain transfers of data from the EEA to the US are covered by the EU-US Data Privacy Framework. Where data is transferred from the EEA to Australia, the transfer is not supported by an adequacy decision of the European Commission.

Where data is transferred from the UK to EEA, the transfer is covered by an adequacy regulation.  Certain transfers from the UK to US are covered by the UK Extension of the EU-US Data Privacy Framework. Where data is transferred from the UK to Australia, the transfer is not supported by an adequacy regulation.

Transfers of personal data outside of the UK/EEA will take place only where the organisation receiving the personal data has provided us with adequate safeguards, and subject to a written agreement, in line with the requirements of European data protection law applicable to processors and data transfers.

If you transact with parties outside the UK/EEA we may be required to transfer your personal data to those parties in order to provide the Services you requested.

DATA SECURITY

We are PCI DSS (Payment Card Industry Data Security Standard) Level 1 compliant, which is the highest standard set by the payment card industry to ensure that credit card data is processed, stored or transmitted in a secure environment.

In addition, we limit access to your personal information to those employees and third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

RETENTION OF YOUR INFORMATION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, tax, regulatory 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.

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

In some circumstances we may anonymise your personal data for statistical purposes in which case we may use this information indefinitely without further notice to you.

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.

YOUR RIGHTS

• 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 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 your personal data. 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, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please be aware that we may have to keep some of your data to comply with the law or for tax purposes but we will evaluate your request within applicable data protection laws.
• Object to processing of your personal data. You may object to our processing of your personal data, however objecting to our processing of your personal data may impact our ability to provide services or otherwise have a relationship with you. You have the absolute right to object where we are processing your personal data for direct marketing purposes. You can exercise this right at any time by contacting us.
• 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 and we are considering 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. This right applies to information which you have 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. When you have given us your consent to process your data, you may withdraw that consent at any time. Please note that if you withdraw your consent, we may not be able to have a relationship with you or otherwise provide certain products or services to you.

If you wish to exercise any of the rights set out above, please contact [email protected] or use the postal address mentioned at the beginning of this privacy policy. 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.

COUNTRY-SPECIFIC NOTICES

Paydock is based in the United Kingdom and our customers are businesses located outside the EEA.

Paydock is providing the following supplemental information for individuals located in the European Economic Area (EEA) whose personal information is collected or held by the Paydock Group.

Where you are such an individual:

• When processing personal data of data subjects who are in the EEA or in connection with the Services, Paydock will act either as data controller or data processor. When Paydock determines the purpose and the manner of processing of your personal data, Paydock is deemed to be a data controller. Paydock will apply a similar approach to protecting your data whether acting as a data processor or a data controller.

Notice relating to our operations in the United Kingdom

Paydock is providing the following supplemental information for individuals whose personal information is collected or held by Paydock Ltd or any of its affiliated companies.

Where you are such an individual:

• When processing personal data of data subjects who are in the United Kingdom or in connection with Paydock Ltd’s Services, Paydock Ltd will act either as data controller or data processor. When Paydock Ltd determines the purpose and the manner of processing of your personal data, Paydock Ltd is deemed to be a data controller. We apply a similar approach to protecting your data whether acting as a data processor or a data controller.
• Paydock Ltd is registered in the United Kingdom under Company Number 11791392, with its registered address at Arquen House, 4-6 Spicer Street, St. Albans, England, AL3 4PQ Paydock Ltd is registered with the UK Information Commissioner’s Office (ICO) under number ZB410379.
• You have the right to make a complaint at any time to the ICO, however, please consider contacting us in the first instance so that we may address your concerns directly.

Notice relating to our operations in Australia

Paydock is providing the following supplemental information for individuals whose personal information is collected or held by Paydock Ltd, Paydock AUNZ Pty Limited, or any of their affiliated companies, at a time when the collecting or holding entity has an ‘Australian link’ within the meaning of the Australian Privacy Act 1988.

Where you are such an individual:

• You may make a complaint to us about a breach of the Australian Privacy Principals by using the contact details of our DPO, as set out above. We will investigate your complaint and endeavour to resolve any issue to your satisfaction. If we do not adequately answer your concerns, you will have the right to make a complaint in writing to the Office of the Australian Information Commissioner.
• It is likely that personal information about you will be collected and held in countries within the EEA or the United Kingdom. It may also be disclosed to persons in other counties in the circumstances described in this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

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.

Previous versions of our privacy policy are available here