Welcome to TicknPay Technology Europe Limited’s privacy notice.
TicknPay Technology Europe Limited (TTL) 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 www.TicknPay.com (Site) (regardless of where you visit it from);
Use any of the services we offer (the Services); and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
The nature of the business is the processing of personal and sensitive data in relation to the use and management of pre-paid cards for clients.
TICKNPAY TECHNOLOGY EUROPE LIMITED a company registered in Malta under company registration number C79656 and having its registered address at Suite 5, Valley Towers, Valley Road Birkirkara BKR9022.
Malta Corp Registration Details 17022601. VAT number for TicknPay Technology Europe Limited has been issued and its MT2410-3824
1.1 Purpose of this privacy notice
This privacy notice aims to give you information on how TTL, collects and processes your personal data through your use of our pre-paid card, including any data you may provide when you subscribe to our Services, search for a product, take part in a competition, promotion, or survey or sign up to our newsletter.
It is important that you read this privacy notice together with 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.
1.2 Controller & Processor
TicknPay Limited is the controller and processor and responsible for your personal data (referred to as “TicknPay”, “we”, “us” or “our” in this privacy notice) .
TicknPay have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to their processing of personal data in accordance with this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
1.3 Contact details
Our full details are: Full name of legal entity: TICKNPAY TECHNOLOGY EUROPE LIMITED a company registered in Malta under company registration number C79656 and having its registered address at Suite 5, Valley Towers, Valley Road Birkirkara BKR9022. Malta Corp Registration Details 17022601. DPO: Data Protection Officer for TicknPay Limited Email address: DPO@TicknPay.com Postal address Suite 5, Valley Towers, Valley Road Birkirkara BKR9022.
You have the right to make a complaint at any time to the Information Data Protection Commissioner (IDPC) Office of the Information and Data Protection Commissioner Airways House, Second Floor, High Street, Sliema SLM 1549, MALTA. We would, however, appreciate the chance to deal with your concerns before you approach the IDPC, so please contact us in the first instance.
1.4 Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 1st September 2018. 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.
2. 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 your full name, username or similar identifier, date of birth, gender, nationality, personal description, photograph and video.
Contact Data may include contact address, email address and telephone numbers.
Contractual Data includes details about the contractual agreement we have in place with you.
Financial Data includes information related to your TicknPay pre-paid card.
Transaction Data includes details about the use of your TicknPay Account
Due Diligence Data includes information we are required by law to process about you to comply with our obligations in relation to illegal activities involving money (for example, fraud, money laundering and terrorist financing) or in compliance with international sanctions, which processing data about the origin of funds and/or transaction parties, the purpose of our business relationship, account usage behaviour, political exposed status (i.e. are you a politically exposed person or PEP).
Technical Data includes browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, your login data, unique device identifier, the MAC address of the Service’s wireless network interface, or the mobile phone number used by the Device) and other technology on a Device.
Contractual Data includes details about the products and Services we provide to you and the terms under which we provide these.
Usage Data includes information about how you use our Services.
2.1 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or Services In this case, we may have to cancel a product or Service you have with us, but we will notify you if this is the case at the time.
3. 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, Financial and Due Diligence Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
request marketing to be sent to you;
communicate with us via email, on-line chat, video call and/or phone call or give us some feedback.
Third parties or publicly available sources.
We work closely with third parties who may provide us with Identity, Contact and Due Diligence Data (including, for example, business partners based inside and outside the EU, sub-contractors in delivery services and advertising networks based inside and outside the EU, analytics providers based inside and outside the EU, search information providers such as Google based outside of the EU, fraud prevention agencies based inside and outside the EU, customer service providers based inside and outside the EU, social media organisations such as Facebook or Twitter based outside of the EU). We will also receive Identity, Contact and Due Diligence Data about you from third parties we use to screen you for PEP status, screen sanctions lists, perform criminal history checks and verify your identity based inside and outside the EU.
Technical Data from the following parties: a) analytics providers such as Google based outside the EU; b) advertising networks such as Google based outside the EU; and c) search information providers such as Google based outside the EU.
Identity, Contact, Diligence, Financial and Transaction Data from providers of technical and payment services (including domestic, European and international payment systems), such as SWIFT based inside and outside of the EU.
Identity, Contact Data and Due Diligence Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is in our legitimate interests to detect, prevent and investigate fraud, money laundering, terrorist financing and other crimes.
Where we need to comply with a legal or regulatory obligation, for example, to cooperate with our regulators and/or law enforcement bodies.
In the case of Special Categories of Personal Data, where processing of such data is in the substantial public interest (for example, for us to comply with our regulatory requirements).
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to certain marketing activities. You have the right to withdraw consent to marketing related processing at any time by sending an unsubscribe email to DPO@TicknPay.com
4.1 Purposes for which we will use your personal data
We use your personal data in the following ways:
personal data that you provide to us is used to:
provide you with the information, products and Services that you request from us (including access to your TicknPay Account
perform payment transactions requested by you on your TicknPay Account via both national and international payment systems - comply with rules and obligations specified in card certification schemes such as when a chargeback request is filed or a card related dispute has been lodged
to protect against fraud and comply with our regulatory and anti-financial crime regulations manage and administer our business
perform customer surveys, market analyses and statistics so we can improve our Services and user experience, and develop new offerings based on our customers preferences and feedback
notify you about changes to our Services and help you to solve any difficulties you may encounter while using our products and Services
assess the quality of our customer services and to provide staff training. Calls to our customer support may be recorded and monitored for these purposes perform analysis on customer complaints for the purposes of preventing errors and process failures and rectifying negative impacts on customers
provide you with information about new products and Services including personalised offers and information about upcoming campaigns
personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
Fraud Prevention Agencies
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.
We will always tell fraud prevention agencies if you give us false or fraudulent information. They will also allow other organisations (in the UK or abroad), including law enforcement agencies, to access this information to prevent and detect fraud or other crimes.
You can ask us for the details of the fraud prevention agencies we share information with.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your personal data and location 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.
You may receive promotional communications from us via email, SMS, in-app messages, telephone or post if you have requested information from us or signed up to use our Services, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that communication.
We will get your express opt-in consent before we share your personal data with any company outside the TicknPay group of companies for marketing purposes
Sometimes we use social media sites to retarget/remarket our products and Services to a similar audience as that of our existing customer base. Some of the data that we disclose to social media sites is Aggregated Data or anonymised data. We will only disclose your Aggregated Data or anonymised personal data to social media sites if we have your consent or it is in our legitimate interests to do so.
You can ask us or third parties to stop sending you our marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/Service purchase, product/Service experience or other transactions.
4.4 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dpo@TicknPay.com
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.
5. 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 paragraph 4 above.
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.
If we are under a duty to disclose or share your personal data to comply with any legal or regulatory obligation, we will only disclose to the extent required to comply with such obligation.
6. International transfers
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.
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:
Subject to the following paragraphs, 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 (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)
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.
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.
Where we share data with fraud and crime prevention agencies and fraud and/or criminal history checking service providers in the EEA, they may transfer your data outside of the EEA, in this case they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA and/or they may require the recipient to subscribe to certain standards, intended to enable secure data sharing.
Please contact us at dpo@TicknPay.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate physical and technological security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
HOW WILL YOU USE MY PERSONAL DATA?
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. In practice this means that we will keep:
basic information about our customers (including Contact, Identity, Due Diligence, Financial and Transaction Data) for 6 years after they cease being customers (unless we are required to keep it longer; for example, due to a court order or investigation by law enforcement agencies or regulators)
complaint records for 3 years
your communications with us are retained for the period of our contractual relationship and deleted 6 months after the business relationship between us has come to an end
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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at dpo@TicknPay.com
9.1 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.2 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.3 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.
10.1 Lawful Basis
Performance of a 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.
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 at privacy@TicknPay.com.
10.2 Special Categories of Personal Data
Includes data 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).
10.3 Third Parties
External Third Parties
Service providers acting as processors based in the EU and US who provide:
IT and system administration services such as analytics and search engine providers
data storage, server, hosting and security providers
delivery service providers
payment service providers and processors and providers of technical and payment services (including domestic, European and international payment systems).
card manufacturers, suppliers of identity validation services
customer service and support systems providers, so we can communicate with you via email, chat, video or phone call.
third parties who assist with our marketing communications and who provide automation and analytics platforms
criminal history check providers and verification of identity providers
We also disclose personal data to authorities to the extent we are under a statutory obligation to do so. Such authorities include tax authorities, police authorities, enforcement authorities and supervisory authorities in relevant countries. We may also be required to provide competent authorities information about your use of our services, e.g. revenue or tax authorities, as required by law, which may include personal data such as your name, address and information regarding card transactions processed by us on your behalf through your use of our services.
If you ask us to, we will share information with any third party that provides you with account information or payment services. Where you ask us to do this, you are allowing that third party to access information relating to your account. We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.
10.4 Your Legal Rights
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.