Data Privacy Policy
In this Data Privacy Notice (“Privacy Notice”) we explain how we collect and use your personal information that we obtain when you use our services, visit, or use our websites or mobile applications or otherwise interact with us in the European Economic Area (“EEA”), how we share your information and the steps we take to protect your information.
Intellectual property and acceptable use
This Privacy Notice applies to Pagotec Consultancy Ltd (“we”, “our”; or “us”), We are committed to the privacy and security of your Personal Data (as defined in section 2 below).
This Privacy Notice describes how we collect and use Personal Data, in accordance with applicable law and our standards of ethical conduct.
Pagotec Consultancy Ltd at 4/4A Bloomsbury Square, London, WC1A 2RP, will be the “data controller” in relation to any Personal Data provided to us directly in person, or via email, phone, and post or via the following website https://pagotec.io (the “Website”). This means that Pagotec Consultancy Ltd is responsible for deciding how it will hold and use Personal Data about you.
Our Pagotec Consultancy Ltd Data Protection Officer can be contacted:
• By email at: compliance@pagotec.io
• By post to: Pagotec Consultancy LTD Pagotec Data Protection Officer 4/4A Bloomsbury Square, London, WC1A 2RP
By using or navigating the Website or any product or service offered by us (collectively, the “Services”), you acknowledge that you have read, understand, and agree to be bound by this Privacy Notice. You should not provide us with any of your information if you do not agree with the terms of this Privacy Notice.
We encourage you to review and check the Website regularly for any updates to this Privacy Notice. We will publish the updated version on the Website and by continuing to deal with us, you accept this Privacy Notice as it applies from time to time.
Data Protection principles
“Personal Data” means any information that enables us to identify you or the beneficiary of your transaction with us, directly or indirectly, such as name, email, address, telephone number, any form of identification number or one or more factors specific to you or your beneficiary’s physical, physiological, mental, economic, cultural, or social identity.
We are committed to complying with applicable data protection laws and will make sure that Personal Data is:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have explained to you clearly and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about; and kept securely.
What Personal Data do we collect and how do we collect it?
Personal Data you give us. We may collect Personal Data when you give it to us, including when you indicate that you would like to receive any of our Services, when you register with us, when you complete forms online, when you speak to us over the telephone, when you speak to us in person, when you write to us and when you visit the Website and, in certain circumstances as set out in this Privacy Notice, We will also collect details of transactions you carry out through the Website and of the fulfilment of such transactions.
The types of Personal Data we collect will depend on the products or services you have requested from us. Any Personal Data collected is necessary for us to perform a contract and without such data, we may not provide the desired Services.
We may collect and process the following Personal Data:
• Personal details, such as data which may identify you and/or the beneficiary of your transaction with us. This may include name, title, residential and/or business address, email, telephone and/or fax numbers and other contact data, date of birth, sex, images, signature, passport/visa details.
• Financial details, such as data relating to you and your beneficiary’s payment data and bank account obtained for the purposes of money transfers; and/or
• Additional details requested by law enforcement or requested pursuant to our compliance procedures in connection with efforts to prevent money laundering, terrorist financing and criminal activity, such as relationship to the beneficiary of the transaction, the purpose of the transaction and proof of funds.
• Cookies and similar technologies. When you use our website, we collect information via cookies and similar technologies, including the IP address of visitors, browser type and version, time zone setting, screen resolution settings, browser plug-in types and versions, operating system and platform. We may use this data for the following purposes:
• To measure the use of our Website and Services, including number of visits, average time spent on a website, pages viewed, page interaction data (such as scrolling, clicks, and mouse-overs) etc., and to improve the content we offer;
• To administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
• As part of our efforts to keep the Website safe and secure.
How do we use your Personal Data?
• We use Personal Data and other data you provide to us only for the following purposes permitted by applicable laws:
• When necessary for the performance of a contract with you: we may use your data based on our need to perform our obligations under a contract with you, to complete your transactions or other requests made by you, to respond to and process your queries or requests, or to contact you as necessary in connection with our performance of a contract with you. For example, if you enter a contract for our Global Business Payments services, your data will necessarily be shared with the payment service provider that will pay out funds to your designated beneficiary in the Global Business Payments destination country and it may be used if we find it necessary to contact you in connection with our contract.
• When necessary to comply with a legal or regulatory obligation: we may use your data to comply with legal requirements and/or regulations specific to our business. For example, when you contract with us for Global Business Payments, we are required to perform a certain level of due diligence prescribed by law and/or commensurate with any assessed risk which may result in the reporting of your data to legal and/or regulatory authorities and/or a request from us for additional information from you to assist in our risk assessment and/or to satisfy our compliance obligations.
• When necessary, in the pursuit of a legitimate interest of Pagotec Consultancy Ltd: if you provide information to us online or transact with us online, we may use your data to improve the content of our Website and Services to enhance your experience. We may use data, such as IP addresses and anonymous demographic data, to tailor your experiences with our Services by showing content in which we think you will be interested and displaying content according to your preferences. We may use aggregate data for a variety of purposes, including analyzing user behavior and characteristics to measure interest in (and use of) the various portions and areas of our Services. We also may use the data collected to evaluate and improve our Services and analyze traffic to our Services.
If in the future we use your Personal Data in the pursuit of our legitimate interest, we will strive to align our interests with yours such that under no circumstances will your data be used except as consented to by you or as otherwise permitted by applicable laws. In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such data without further notice to you.
Is data collected shared with third parties?
Third-party service providers
We may share your Personal Data with the following third-party service providers to manage, enable or facilitate certain aspects of the Services (including the maintenance of our servers and processing or fulfilling orders for transactions):
• Compliance verification service providers
• Financial services providers, such as banks
• Credit control agencies
Corporate process
We may transfer your Personal Data to a third party because of a sale, acquisition, merger or reorganization, we will take reasonably appropriate steps to make sure that your information is properly protected.
Legal and regulatory
We may also disclose your Personal Data in special cases if required to do so by law enforcement agencies, law, court order, or other governmental authority, or when we believe in good faith that disclosing this data is otherwise necessary or advisable, such as to identify, contact, or bring legal action against someone who may be causing injury to–or interfering with–; the rights or property of Pagotec Consultancy Ltd, the Services, another user, or anyone else that could be harmed by such activities (for example, identify theft or fraud).
Sharing Personal Data outside the United Kingdom
The nature of our products and Services means that we may need to share your Personal Data with recipients based in countries outside of the United Kingdom, including in the EEA and outside the EEA. The countries to which we may need to send your information would normally be obvious to you based on your requested transaction.
As explained above, we may share your personal data with our payment processing partners, which may involve transferring your data outside the EEA. Where we do so, we will ensure a similar level of protection to that afforded in the EEA; for example, on the basis the relevant recipient country has been deemed by the European Commission to provide an “adequate” level of protection for Personal Data or by contractual provisions that seek to ensure a level of protection and safeguarding of Personal Data.
If our use of third-party service providers involves sharing your Personal Data outside the EEA, we will make sure the service provider provides safeguards and assurances regarding the protection of your Personal Data.
How long is Personal Data retained?
Personal Data is used for different purposes and is subject to different standards and regulations. In general, Personal Data is retained for as long as necessary to provide you with the Services you request, to comply with applicable legal, accounting or reporting requirements and to make sure that you have a reasonable opportunity to access the Personal Data.
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 unauthorized 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. For example:
• Legal and Regulatory Requirements. Pagotec Consultancy Ltd shall retain Personal Data and transactional data for those periods required to comply with all retention and reporting obligations under applicable laws, including without limitation commercial, tax and anti-money laundering laws and regulations. Generally, this retention period will be a minimum of five years from the date of your transaction or the date our business relationship with you is terminated.
• Customer Service (administration of customer relationship, complaint handling, etc.). Pagotec Consultancy Ltd may process and retain your Personal Data for as long as we have an on-going relationship with you. Once our relationship has ended (for example because the Services have been delivered and paid for in full, or you have exercised your right to withdraw from the contract), we will, subject to any retention requirements under applicable laws, erase or anonymize your Personal Data.
Is the correspondence that you sent to us saved?
Yes. If you send us correspondence, including emails and faxes, we may retain such data along with any records of your account. We may also retain customer service correspondence and other correspondence involving you, us, our partners, and our suppliers. We will retain these records in line with our Retention Policy.
Data Security
We are committed to maintaining the security of your Personal Data and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorized individuals, and we upgrade our security regularly as better methods become available.
Our data centers and those of our partners utilize state-of-the-art physical security measures to prevent unauthorized access to the facility. In addition, all Personal Data is stored in a secure location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access.
All Pagotec Consultancy Ltd employees who have access to, or are associated with, the processing of Personal Data is contractually obliged to respect the confidentiality of your data and abide by the privacy standards we have established.
Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry-standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of Personal Data.
Does this Privacy Notice apply to other websites?
No. Our Website may contain links to other internet websites. By clicking on a third-party advertising banner or certain other links, you will be redirected to such third-party websites. We are not responsible for the privacy policies of other websites or services. You should make sure that you read and understand any applicable third-party privacy policies, and you should direct any questions or concerns to the relevant third-party administrators or webmasters before providing any Personal Data.
What are my data protection rights?
Subject to verification of your identity, you may request access to and have the opportunity to update and amend your Personal Data. You may also exercise any other rights you enjoy under applicable data protection laws. Please use the contact details in Section 13 of this Privacy Notice.
“Data Subjects” have the right to:
• Request access to any Personal Data we hold about them as well as related data, including the purposes for processing the Personal Data, the recipients or categories of recipients with whom the Personal Data has been shared, where possible, the period for which the Personal Data will be stored, the source of the Personal Data, and the existence of any automated decision making;
• Obtain without undue delay the rectification of any inaccurate Personal Data we hold about them;
• Request that Personal Data held about them is deleted provided the Personal Data is not required by us, for compliance with a legal obligation under applicable law or for the establishment, exercise or defence of a legal claim;
• Under certain circumstances, prevent or restrict processing of your Personal Data, except to the extent processing is required for the establishment, exercise or defence of legal claims; and
• Under certain circumstances, request the transfer of Personal Data directly to a third party where this is technically feasible.
Also, where you believe that Pagotec Consultancy LTD has not complied with its obligations under this Privacy Notice or the applicable law, you have the right to make a complaint to a relevant Data Protection Authority or through the courts. Although not required, we would encourage you to let us know about any complaint you might have, and we will respond in line with our Complaints Procedure (see Section 12 of this Privacy Notice).
Privacy-related complaints procedure
Where you believe that we have not complied with our obligations under this Privacy Notice or the applicable law, you have the right to make a complaint to a Data Protection Authority or through the courts.
Although not required, we would encourage you to let us know about any privacy-related complaint you might have, and we will respond in line with our complaint’s procedure–our contact details are set out below.
Privacy-related complaints or concerns can be lodged with our privacy team:
• By email at: compliance@pagotec.io
• By post to: Pagotec Consultancy LTD Pagotec Data Protection Officer 4/4A Bloomsbury Square, London, WC1A 2RP
Pagotec Consultancy Ltd employees are required to direct any privacy-related complaints or concerns to our privacy team.
Pagotec Consultancy Ltd will aim to send an acknowledgement within 10 days of receipt of the complaint/concern.
Pagotec Consultancy Ltd will investigate in accordance with relevant laws and will aim to respond substantively within 28 days of receipt of the complaint/concern. f further time is required to investigate your complaint/concern, Pagotec Consultancy Ltd will write to you within 28 days of receiving the complaint/concern, informing you of the investigation timeline which will be no longer than an additional two months for the complaints procedure to be concluded.
In the case of a rejection of the complaint, Pagotec Consultancy Ltd will provide you with a written explanation for the rejection.
If the complaint/concern is considered justified, Pagotec Consultancy Ltd will take reasonable steps to try to address the complaint/concern to your reasonable satisfaction.
If you are not satisfied with the reply/outcome, or otherwise with the handling of the complaint, you have the right to lodge a claim before a relevant Data Protection Authority or the courts. In the United Kingdom, the Data Protection Authority is the Information Commissioner’s Office (website: https://ico.org.uk/for-the-public/ and telephone: 0303 123 1113).
For all other complaints or concerns about our Services that are unrelated to privacy, please contact our Customer Service Team on + 44 (0) 203 206 1551
Contact Us
• By email at: compliance@pagotec.io
• By post to: Pagotec Consultancy LTD Pagotec Data Protection Officer 4/4A Bloomsbury Square, London, WC1A 2RP
Any complaints will be handled in line with our complaints procedure as set out in Section 12 of this Privacy Notice.
Terms and conditions
Introduction
These terms and conditions apply between you, the User of this Website (including any sub-domains unless expressly excluded by their own terms and conditions), and Pagotec Consultancy Ltd, the owner and operator of this Website. Please read these terms and conditions carefully, as they affect your legal rights. Your agreement to comply with and be bound by these terms and conditions is deemed to occur upon your first use of the Website. If you do not agree to be bound by these terms and conditions, you should stop using the Website immediately.
In these terms and conditions, User or Users means any third party that accesses the Website and is not either (i) employed by Pagotec Consultancy Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Pagotec Consultancy Ltd and accessing the Website in connection with the provision of such services.
You must be at least 18 years of age to use this Website. By using the Website and agreeing to these terms and conditions, you represent and warrant that you are at least 18 years of age.
Intellectual property and acceptable use
• All Content included on the Website, unless uploaded by Users, is the property of Pagotec Consultancy Ltd, our affiliates or other relevant third parties. In these terms and conditions, Content means any text, graphics, images, audio, video, software, data compilations, page layout, underlying code and software and any other form of information capable of being stored in a computer that appears on or forms part of this Website, including any such content uploaded by Users. By continuing to use the Website you acknowledge that such Content is protected by copyright, trademarks, database rights and other intellectual property rights. Nothing on this site shall be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark, logo or service mark displayed on the site without the owner’s prior written permission.
• You may, for your own personal, non-commercial use only, do the following: A. retrieve, display and view the Content on a computer screen B. print one copy of the Content
• You must not otherwise reproduce, modify, copy, distribute or use for commercial purposes any Content without the written permission of Pagotec Consultancy LTD Ltd.
Prohibited use
You may not use the Website for any of the following purposes: A. in any way which causes, or may cause, damage to the Website or interferes with any other person’s use or enjoyment of the Website; B. in any way which is harmful, unlawful, illegal, abusive, harassing, threatening or otherwise objectionable or in breach of any applicable law, regulation, governmental order; C. making, transmitting or storing electronic copies of Content protected by copyright without the permission of the owner.
Privacy Policy and Cookies Policy
Use of the Website is also governed by our Privacy Policy and Cookies Policy, which are incorporated into these terms and conditions by this reference. To view the Privacy Policy and Cookies Policy, please click on the following: DATA PRIVACY POLICE
Availability of the Website and disclaimers
• Any online facilities, tools, services or information that Pagotec Consultancy Ltd makes available through the Website (the Service) is provided “as is” and on an “as available” basis. We give no warranty that the Service will be free of defects and/or faults. To the maximum extent permitted by the law, we provide no warranties (express or implied) of fitness for a particular purpose, accuracy of the information, compatibility and satisfactory quality. Pagotec Consultancy LTD is under no obligation to update information on the Website.
• Whilst Pagotec Consultancy Ltd uses reasonable endeavours to ensure that the Website is secure and free of errors, viruses and other malware, we give no warranty or guaranty in that regard and all Users take responsibility for their own security, that of their personal details and their computers.
• Pagotec Consultancy Ltd accepts no liability for any disruption or non-availability of the Website.
• Pagotec Consultancy Ltd reserves the right to alter, suspend or discontinue any part (or the whole of) the Website including, but not limited to, any products and/or services available. These terms and conditions shall continue to apply to any modified version of the Website unless it is expressly stated otherwise
Limitation of liability
• Nothing in these terms and conditions will: (a) limit or exclude our or your liability for death or personal injury resulting from our or your negligence, as applicable; (b) limit or exclude our or your liability for fraud or fraudulent misrepresentation; or (c) limit or exclude any of our or your liabilities in any way that is not permitted under applicable law.
• We will not be liable to you in respect of any losses arising out of events beyond our reasonable control.
• To the maximum extent permitted by law, Pagotec Consultancy Ltd accepts no liability for any of the following: A. any business losses, such as loss of profits, income, revenue, anticipated savings, business, contracts, goodwill or commercial opportunities; B. loss or corruption of any data, database or software; C. any special, indirect or consequential loss or damage.
General
• You may not transfer any of your rights under these terms and conditions to any other person. We may transfer our rights under these terms and conditions where we reasonably believe your rights will not be affected.
• These terms and conditions may be varied by us from time to time. Such revised terms will apply to the Website from the date of publication. Users should check the terms and conditions regularly to ensure familiarity with the then current version.
• These terms and conditions together with the Privacy Policy and Cookies Policy contain the whole agreement between the parties relating to its subject matter and supersede all prior discussions, arrangements or agreements that might have taken place in relation to the terms and conditions.
• The Contracts (Rights of Third Parties) Act 1999 shall not apply to these terms and conditions and no third party will have any right to enforce or rely on any provision of these terms and conditions.
• If any court or competent authority finds that any provision of these terms and conditions (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of these terms and conditions will not be affected.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This Agreement shall be governed by and interpreted according to the law of England and Wales and all disputes arising under the Agreement (including non-contractual disputes or claims) shall be subject to the exclusive jurisdiction of the English and Welsh courts
Pagotec Consultancy Ltd details
Pagotec Consultancy Ltd is a company incorporated in England and Wales with registered number 12141139 whose registered address is 4/4a Bloomsbury Square, London, England, WC1A 2RP and it operates the Website https://pagotec.io
Legal
Anti-money laundering and compliance program highlights
Pagotec Consultancy Ltd formal Anti Money Laundering and Compliance program require approval of senior management. Our legal and regulatory compliance program includes a designated Compliance Officer that is responsible for coordinating and overseeing the AML and Compliance program on a day-to-day basis. We have developed written policies documenting the processes that we have in place to prevent, detect and report suspicious transactions. Pagotec Consultancy LTD is committed to maintaining effective prevention and detection measures to assist the law enforcement authorities in combating financial crime.
In addition to inspections by the government supervisors/regulators, Pagotec Consultancy Ltd has an internal audit function and independent third-party reviewers that assess AML policies and practices on a regular basis. We have policies covering relationships with politically exposed persons consistent with industry best practices.
Pagotec Consultancy Ltd has implemented systems for the identification of its customers, including customer information in the case of recorded transactions, account opening, etc. We perform a risk-focused assessment of our customer base and their transactions. We determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that we have reason to believe pose a heightened risk of illicit activities. Know Your Customer (KYC) Information is collected at account opening and reviewed on periodic intervals. Pagotec Consultancy Ltd takes steps to understand the normal and expected transactions of its customers based on its risk assessment of them. We have appropriate record retention procedures that exceed the requirements of the applicable law, as well as clear policies regarding Anti Bribery and Corruption practices.
Pagotec Consultancy Ltd has policies and practices for the identification and reporting of transactions that are required to be reported to the authorities. Our systems are programmed to identify transactions structured to avoid regulatory reporting requirements. We screen transactions of customers against lists issued by government/international bodies (e.g., OFAC, HM Treasury, UN Security Council and our own internal sanctions list) prior to completing any such transactions.
Pagotec Consultancy Ltd provides AML training to all employees that include identification and reporting of transactions that must be reported to government authorities, examples of different forms of money laundering involving the Company’s products and services and internal policies to prevent money laundering. Pagotec Consultancy Ltd retains records of its training sessions including attendance records and relevant training materials used. Pagotec Consultancy Ltd has policies to communicate new AML related laws or changes to all employees.
