WELLET
Privacy Policy

We recognize the importance of protection of the personal data of our clients and business partners. This site provides a comprehensive and structured overview of information we collect regarding identification of persons and when we collect it.

Information on Personal Data Protection
This site will tell you everything about the personal data processing that we carry out. If we do process your personal data, you will find detailed information on your rights and on the manner in which you can exercise your rights here. You will find more details about each individual processing, your rights and the manner in which your rights may be exercised under the following headings designating groups of persons whose personal data are being processed and specific types of processing.

I. Employees' personal data.
II. Clients' personal data (users of Company's services and solutions).
III. Marketing (Information on goods and services including business message and profiling).
IV. Suppliers of goods and services and their representatives.
Key characteristics of each individual processing
I. Employee personal data – the processing of employees' personal data to ensure compliance with the employer's legal obligations (performance of employment obligations) and exercising and protection of the employer's rights and legal interests, for instance with consent of an employee.
Comprehensive information on the processing, including details of your rights and the requirements for exercising your rights and the manner in which your rights may be exercised, is available HERE.
II. Clients' personal data (users of Company's services and solutions) – retention and processing of personal data of Company's clients in order to ensure the fulfilment of the Service Agreement concluded between the client and the Company.
Comprehensive information on the processing, including details of your rights, the requirements for exercising your rights and the manner in which your rights may be exercised, is available HERE.
III. Marketing – collecting and processing of information in order to identify the best offer for our customers in order to support sales and build Company's reputation.
Comprehensive information on the processing, including details of your rights, the requirements for exercising your rights and the manner in which your rights may be exercised, is available HERE.
IV. Contact details of suppliers of goods and services, and their representatives –retention of contact details for the purpose of entering into a contractual relationship and data necessary for contractual relations with the supplier of goods or services. Eventually, retention of contact details of the representatives (employees, executives representatives or other designated persons) of the suppliers.
Comprehensive information on the processing, including details of your rights, the requirements for exercising your rights and the manner in which your rights may be exercised, is available HERE.
I. EMPLOYEES' PERSONAL DATA
1. CONTROLLER
The personal data controller is Wellet GmBH with its registered office located at c/o Dr. Brandenburg GmbH, Am Wehrhahn 50, 40211 Düsseldorf , identification No. HRB 91634, registered in the of the district court of Düsseldorf (hereinafter the "Controller").

2. YOUR RIGHTS
You have the following rights in respect of the personal data processing concerned:
a. ACCESS – The right to be informed whether or not your personal data are being processed. If your personal data are being processed, you have the right to obtain the information about the processing in prescribed extent and the right, under certain conditions, to obtain a copy of the processed personal data;
b. RECTIFICATION – The right to request rectification if the personal data processed are inaccurate, or the right to request completion if the data are incomplete;
c. ERASURE (right to be forgotten) - Right to request, under certain conditions stipulated by law (withdrawal of consent, termination of contract, unlawful processing), erasure of the personal data;
d. RESTRICTION OF PROCESSING – The right to request marking and, if applicable, restriction (suspension) of the processing pending verification of accuracy of the data, lawfulness of the processing, response to an objection or to ensure protection of your interests (exercise or protection or defence of rights and legitimate interests);
e. COMPLAINT – The right to lodge a complaint to the Office for Personal Data Protection against the Controller, the processing or the terms and conditions of exercising your rights. See www.edpb.europa.eu for the contact details and other information about the Office;
f. WITHDRAWAL OF CONSENT – in relation to the use of photographs. Consent may be withdrawn at any time (in writing). The withdrawal of consent shall not affect the lawfulness of the processing of personal data carried out before the withdrawal. The photographs will be erased upon the request of withdrawal of consent, in relation to which the legal ground for their use by the Controller.

Use the relevant link to find details of individual rights, their characteristics and the conditions under which the rights arise and may be exercised. See how to exercise your rights at wellet.io/exercise-of-rights.

A DATA PROTECTION OFFICER is not designated at the Controller.

3. PURPOSE OF PROCESSING
The Controller processes personal data for the purpose of:
Performance of employment obligations between the employee and the employer. Fulfilment of legal obligations of the employer (maintaining a database in accordance with the Labour Code, social security and health care, tax duties) and contractual obligations.

4. LEGAL GROUND FOR PROCESSING
The legal ground for the processing of personal data is: fulfilment of legal obligation of the Controller as stipulated in labour legal regulations, social security regulations and tax regulations (pursuant to Art. 6(1)(c) of the GDPR) and fulfilment of contractual obligations with the employee (pursuant to Art. 6(1)(b) of the GDPR);

5. SCOPE OF THE DATA being processed
The Controller processes the following data for the above purpose:
Identification and contact data qualification data, employment data (especially worked hours, wage, statutory levies, claims, breach of discipline, work injury, occupational disease, holiday, bank details, and number of children including their age), health insurance, personal ID number, information on tax details (tax discounts including personal details on a spouse and children, including their personal ID numbers)

6. PROVISION OF DATA IS MANDATORY
The provision of personal data is statutory requirement necessary for the employer to perform employment obligations, i. e. to perform a contract with the employee.
The provision of personal data is therefore mandatory; possible consequences of failure to provide personal data are breach of discipline, eventually subsequent obligation to compensate for damages occurred for example by imposing fine to the employer for a public offence which was caused by failing to provide mandatory report (for example insurance registration of employee) to relevant authority (for example District Social Security Administration).

7. PERIOD for which the personal data are stored and processed
The Controller processes personal data: in relation to each individual processing determined by law during statutory period, in case of data necessary for compliance with contractual obligations to ensure performing of employment obligations (employment, contract to complete job) and, if it is necessary, for performance of partial obligations (for example Non-Compete Clause) or exercise or protection of the Controllers' right (for example liability for damages, unlawful dismissal disputes, fulfilment of legal obligations and burden of proof to authorities, repayment of debts, etc).

8. PLACE where the personal data are being processed
The place of personal data processing shall be: Controller's business premises, including Controller's registered office.

9. THIRD COUNTRY
Personal data ARE NOT transferred outside of the EU for further processing.

10. PROCESSOR
A personal data processor pursuant to Art. 4(8) of the GDPR or a third party authorized by the Controller to process personal data may be engaged in the processing of personal data. In such cases, the Controller will minimize the risk of unauthorized disclosure, destruction, processing or loss of the personal data.

11. AUTOMATED DECISION-MAKING AND PROFILING
Automated decision-making means decisions that are made by automated means or based on the output of automated processes, without human intervention/volition.

Profiling means the use of personal data to evaluate certain personal aspects relating to a natural person, e.g. to predict that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, etc.

Automated decision-making WILL NOT be used in connection with personal data processing.

Profiling WILL NOT be used in connection with personal data processing.
II. CLIENTS' PERSONAL DATA (USERS OF COMPANY'S SERVICES AND SOLUTIONS)
1. CONTROLLER
The personal data controller is is Wellet GmBH with its registered office located at c/o Dr. Brandenburg GmbH, Am Wehrhahn 50, 40211 Düsseldorf , identification No. HRB 91634, registered in the of the district court of Düsseldorf (hereinafter the "Controller").


2. YOUR RIGHTS
You have the following rights in respect of the personal data processing concerned:
a. ACCESS – The right to be informed whether or not your personal data are being processed. If your personal data are being processed, you have the right to obtain the information about the processing in prescribed extent and the right, under certain conditions, to obtain a copy of the processed personal data;
b. RECTIFICATION – The right to request rectification if the personal data processed are inaccurate, or the right to request completion if the data are incomplete;
c. ERASURE (right to be forgotten) - Right to request, under certain conditions stipulated by law (withdrawal of consent, termination of contract, unlawful processing), erasure of the personal data;
d. RESTRICTION OF PROCESSING – The right to request marking and, if applicable, restriction (suspension) of the processing pending verification of accuracy of the data, lawfulness of the processing, response to an objection or to ensure protection of your interests (exercise or protection or defence of rights and legitimate interests);
e. COMPLAINT – The right to lodge a complaint to the Office for Personal Data Protection against the Controller, the processing or the terms and conditions of exercising your rights. See edpb.europa.eu for the contact details and other information about the Office;

You also have the right to:
OBJECT – The right to request for your personal data not to be further processed for tasks in public interest, for the Controller's or third person's legitimate interest or marketing purposes.

Use the relevant link to find details of individual rights, their characteristics and the conditions under which the rights arise and may be exercised. See how to exercise your rights at wellet.io/exercise-of-rights.

A DATA PROTECTION OFFICER is not designated at the Controller.


3. PURPOSE OF PROCESSING
The Controller processes personal data for the purpose of fulfilment of the contract and his / her own legitimate interests: To ensure the uninterrupted provision of services.


4. LEGAL GROUND FOR PROCESSING
The legal ground for the processing of personal data is:
Natural person (individual entrepreneur) or a legal entity registers through a website or other communication channels used by the Controller and measures from its own initiative, in the pre-contractual or fulfilment stage – measures necessary before conclusion of the contract and fulfilment of the contract with data subject (pursuant to Art. 6(1)(b) of the GDPR).


5. SCOPE OF THE DATA being processed
The Controller processes the following data for the abovementioned purpose:
— In case the client is a freelancer or is conducting business as a natural person (individual entrepreneur) - identification and contact data, i.e. the name, surname, date of birth, identification number and tax identification number, scope of business, registered seat / office and information on contractual obligation including communication concerning contract negotiation and performance, banking and credit card details, invoicing details, electronic device details (cell phone, tablet, etc.) used to run the Controller'sservices.
— In case the client is a legal entity - identification and contact data of a representative of such entity (work contact information), job title, name, surname, registered office and information on contractual obligations.


6. PROVISION OF DATA IS NECESSARY
Provision of personal data is necessary only if it is necessary for the contractual and fulfilment purposes. It is not possible to conclude a contract without such provision.


7. PERIOD for which the personal data are stored and processed
The Controller processes personal data: for the necessary period of time, i.e. for the entire duration of cooperation or potential cooperation with the data subject. In case of contractual obligations, until they are fulfilled, and for the duration of the applicable statutory time limits, including period for claiming defects, statute of limitations and prescription periods in relation to potential claims arising from contractual relationship. Data and documents may be retained for a period prescribed by law (for example tax records, etc.).


8. RECIPIENTS to whom the personal data may be disclosed
Personal data are provided to following recipients (categories): NO RECIPIENTS.


9. PLACE where the personal data are being processed
The place of the processing of personal data shall be: Controller's business premises, including Controller's registered seat / office.


10. THIRD COUNTRY
Personal data ARE NOT transferred outside of the EU for further processing.


11. PROCESSOR
A personal data processor pursuant to Art. 4(8) of the GDPR or a third party authorized by the Controller to process personal data may be engaged in the processing of personal data. In such cases, the Controller will minimize the risk of unauthorized disclosure, destruction, processing or loss of the personal data.


12. AUTOMATED DECISION-MAKING AND PROFILING
Automated decision-making means decisions that are made by automated means or based on the output of automated processes, without human intervention/volition.
Profiling means the use of personal data to evaluate certain personal aspects relating to a natural person, e.g. to predict that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, etc.

Automated decision-making WILL NOT be used in connection with personal data processing.

Profiling WILL NOT be used in connection with personal data processing.
III. MARKETING
1. CONTROLLER
The personal data controller is is Wellet GmBH with its registered office located at c/o Dr. Brandenburg GmbH, Am Wehrhahn 50, 40211 Düsseldorf , identification No. HRB 91634, registered in the of the district court of Düsseldorf (hereinafter the "Controller").


2. YOUR RIGHTS
You have the following rights in respect of the personal data processing concerned:
a. WITHDRAWAL OF CONSENT – Consent may be withdrawn at any time in a manner described at https://spacehosting.io/rights: The withdrawal of consent shall not affect the lawfulness of the processing of personal data carried out before the withdrawal. Processing of your data for marketing purposes will end upon the withdrawal of consent.
b. ACCESS – The right to be informed whether or not your personal data are being processed. If your personal data are being processed, you have the right to obtain the information about the processing in prescribed extent and the right, under certain conditions, to obtain a copy of the processed personal data;
c. RECTIFICATION – The right to request rectification if the personal data processed are inaccurate, or the right to request completion if the data are incomplete;
d. ERASURE (right to be forgotten) - Right to request, under certain conditions stipulated by law (withdrawal of consent, termination of contract, unlawful processing), erasure of the personal data;
e. RESTRICTION OF PROCESSING – The right to request marking and, if applicable, restriction (suspension) of the processing pending verification of accuracy of the data, lawfulness of the processing, response to an objection or to ensure protection of your interests (exercise or protection or defence of rights and legitimate interests);
f. COMPLAINT – The right to lodge a complaint to the Office for Personal Data Protection against the Controller, the processing or the terms and conditions of exercising your rights. See edpb.europa.eu for the contact details and other information about the Office;
g. PORTABILITY – The right stipulated by law to obtain information for further processing for person determined by you, and to whom you will hand over such information, or request direct hand over to another person for further processing.

You also have the right to:
OBJECT – The right to request for your personal data not to be further processed for tasks in public interest, for the Controller's or third person´s legitimate interest or marketing purposes.

Use the relevant link to find details of individual rights, their characteristics and the conditions under which the rights arise and may be exercised. See how to exercise your rights at wellet.io/exercise-of-rights.

A DATA PROTECTION OFFICER is not designated at the Controller.


3. PURPOSE OF PROCESSING
The Controller processes personal data for marketing purposes: Sending and calling information about the Controller's services and goods. Business messages and calls take into account expected needs, interests and preferences of the addressee based on profiling of the addressee using data on its online presence and participation in online networks and business directories.


4. LEGAL GROUND FOR PROCESSING
The legal ground for the processing of personal data is: for the direct marketing the legitimate interest of the Controller (pursuant to Art. 6(1)(f) of the GDPR), and for the other marketing activities a consent of the data subjects (pursuant to Art. 6(1)(a) of the GDPR).


5. SCOPE OF THE DATA being processed
The Controller processes the following data for the above-mentioned purpose:
Identification and contact data, i.e. the name, surname, phone number, email address, information on the type of conducted business and online presence data (cookies and other similar data sources and tools, participation on social media and business directories).


6. PROVISION OF DATA IS VOLUNTARY
Provision of data is voluntary.


7. PERIOD for which the personal data are stored and processed
The Controller processes personal data for purposes stipulated in art. 3: for the necessary period of time, i.e. for the entire cooperation or potential cooperation with data subject as for the data processed on the basis of legitimate interest, otherwise until the withdrawal of consent but no longer than 5 years after the last interaction with the subject of data.


8. PLACE where the personal data are being processed
The place of personal data processing shall be: the Controller's business premises, including the Controller's registered office.


9. RECIPIENTS to whom the personal data may be disclosed
Personal data are provided to following recipients (categories): NO RECIPIENTS.


10. THIRD COUNTRY
Personal data ARE NOT transferred outside of the EU for further processing.


11.
PROCESSOR
A personal data processor pursuant to Art. 4(8) of the GDPR or a third party authorized by the Controller to process personal data may be engaged in the processing of personal data. In such cases, the Controller will minimize the risk of unauthorized disclosure, destruction, processing or loss of the personal data.


12. AUTOMATED DECISION-MAKING AND PROFILING
Automated decision-making means decisions that are made by automated means or based on the output of automated processes, without human intervention/volition.

Profiling means the use of personal data to evaluate certain personal aspects relating to a natural person, e.g. to predict that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, etc.

Automated decision-making WILL NOT be used in connection to personal data processing.

Profiling WILL be used in connection to personal data processing. Specifically, preference profiling based on client's / user's online presence, social media and business directories usage and other data obtained from cookies and similar tools.
IV. CONTACT DETAILS OF SUPPLIERS OF GOODS AND SERVICES, AND THEIR REPRESENTATIVES
1. CONTROLLER
The personal data controller is Wellet GmBH with its registered office located at c/o Dr. Brandenburg GmbH, Am Wehrhahn 50, 40211 Düsseldorf , identification No. HRB 91634, registered in the of the district court of Düsseldorf (hereinafter the "Controller").

2. YOUR RIGHTS
You have the following rights in respect of the personal data processing concerned:
a. ACCESS – The right to be informed whether or not your personal data are being processed. If your personal data are being processed, you have the right to obtain the information about the processing in prescribed extent and the right, under certain conditions, to obtain a copy of the processed personal data;
b. RECTIFICATION – The right to request rectification if the personal data processed are inaccurate, or the right to request completion if the data are incomplete;
c. ERASURE (right to be forgotten) - Right to request, under certain conditions stipulated by law (withdrawal of consent, termination of contract, unlawful processing), erasure of the personal data;
d. RESTRICTION OF PROCESSING – The right to request marking and, if applicable, restriction (suspension) of the processing pending verification of accuracy of the data, lawfulness of the processing, response to an objection or to ensure protection of your interests (application or protection or defence of rights and legitimate interests);
e. COMPLAINT – The right to lodge a complaint to the Office for Personal Data Protection against the Controller, the processing or the terms and conditions of exercising your rights. See edpb.europa.eu for the contact details and other information about the Office;

You also have the right to:
OBJECT – The right to request for your personal data not to be further processed for tasks in public interest, for the Controller's or third person's interest or marketing purposes.

Use the relevant link to find details of individual rights, their characteristics and the conditions under which the rights arise and may be exercised. See how to exercise your rights at wellet.io/exercise-of-rights.

A DATA PROTECTION OFFICER is not designated at the Controller.

3. PURPOSE OF PROCESSING
The Controller processes personal data for fulfilment of the contract and its own legitimate interests:

Database of identification and contact data, i.e. name, surname, place of residence / registered seat (office), identification number, phone number, email address, banking and billing details of potential / current suppliers of goods and services for contract negotiation, records of communication with the supplier regarding contract negotiations (in order to be able to prove the content of the contract as well as pre-contractual liability etc.), conclusion of the contract with the supplier. In respect of fulfilment of contractual obligations, it is the documentation and correspondence concerning performance of employment that is necessary to prove the manner in which the fulfilment of the contract and protection and exercise of rights took place.

In case the supplier is not one of the contractual parties, data concerning his employees, executive representatives or other persons authorised to negotiate about contract, i.e. contract performance, are registered.

4. LEGAL GROUND FOR PROCESSING
The legal ground for the processing of personal data is:
— Controller's legitimate interest in relation to the database of potential suppliers Art. 6(1)(f) of the GDPR), in the contracting and fulfilling stage – necessary measures before the conclusion of the contract and fulfilling the contract with data subject Art. 6(1)(b) of the GDPR), all applies if the supplier is a natural person (individual entrepreneur);
— Controller's legitimate interest in relation to the database of suppliers, negotiations and fulfilment of the contract where the subject of processing are personal data of supplier' representatives (Art. 6(1)(f) of the GDPR), all applies if the supplier is a legal entity

5. SCOPE OF THE DATA being processed
The Controller processes the following data for the above-mentioned purpose:
— In case the supplier is a natural person (individual entrepreneur) - identification and contact data, i.e. name, surname, scope of business, registered seat / office, billing and invoicing details and information on contractual obligation including communication concerning contract negotiation and performance.
— In case the supplier is a legal entity - identification and contact data of a representative of such entity (work contact information), job title, name, surname, scope of business, registered seat / office, billing and invoicing details and information on contractual obligation including communication concerning contract negotiation with the employer.

6. PROVISION OF DATA IS NECESSARY
Provision of personal data is necessary only if it is necessary for the contractual and fulfilment purposes. It is not possible to conclude a contract without such provision.

7. PERIOD for which the personal data are stored and processed
The Controller processes personal data: for the necessary period of time, i.e. for the entire cooperation, or potential cooperation with the data subject. In case of contractual obligations – until they are fulfilled, and for the time period stipulated by law, including period for claiming defects, statute of limitations and prescription periods regarding potential claims arising from contractual relationship. Data and documents may be retained for a period prescribed by law (for example tax records, etc.).

8. PLACE where the personal data are being processed
The place of the processing of personal data shall be: the Controller's business premises, including the Controller's registered office

9. RECIPIENTS to whom the personal data may be disclosed
Personal data are provided to following recipients (categories): NO RECIPIENTS.

10. THIRD COUNTRY
Personal data ARE NOT transferred outside of the EU for further processing.

11. PROCESSOR
A personal data processor pursuant to Art. 4(8) of the GDPR or a third party authorized by the Controller to process personal data may be engaged in the processing of personal data. In such cases, the Controller will minimize the risk of unauthorized disclosure, destruction, processing or loss of the personal data.

12.
AUTOMATED DECISION-MAKING AND PROFILING
Automated decision-making means decisions that are made by automated means or based on the output of automated processes, without human intervention/volition.
Profiling means the use of personal data to evaluate certain personal aspects relating to a natural person, e.g. to predict that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, etc.

Automated decision-making WILL NOT be used in connection with personal data processing.

Profiling WILL NOT be used in connection with the processing of personal data.
WITHDRAWAL OF CONSENT WITH DATA PROCESSING
If you wish to withdraw your consent for data processing for marketing purposes, please enter your email address and send to confirm.

Paynetics
Privacy and security policy

WE ARE COMMITTED TO SAFEGUARD YOUR PRIVACY

SECTION I: INTRODUCTION

PAYNETICS AD (hereinafter referred to as "Paynetics", "we", "us" and "our") is regulated as an e-money institution and principal member of the International Card Schemes VISA & MasterCard in Europe and it has the responsibility to maintain the highest standards of confidentiality in the safeguarding of information about:
  • visitors on our website;
  • people who do business with us and register for our service.
PAYNETICS collects and processes personal data according to this Privacy Policy.

Please read this Privacy Policy carefully to understand our views and approach regarding your personal data, how we use it in our capacity of data controller and how we will treat it.
SECTION II: GENERAL

"Personal data" is defined in Article 4(1) of the GDPR:

"(1) 'personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

Paynetics respects the privacy of its users ("user"or "you") that use our website located at www.paynetics.digital, including other media forms, media channels, mobile website or mobile application related or connected thereto collectively, the "Website". The following Privacy Policy is designed to inform you, as a user of the Website, about what types of data Paynetics may gather about or collect from you in connection with your use of the Website. It is also intended to explain the conditions under which Paynetics uses and discloses the data, and your rights in relation to the personal data collected. We do not collect personal data from anyone under the age of 18.

When you first visit our website www.paynetics.digital, we will ask you to consent to out use of cookies in accordance with the terms and conditions of this Privacy Policy.

Each time you use this Website, the current version of the Privacy Policy will apply. You express your informed and explicit consent to provide your personal data to be collected and processed by PAYNETICS. More details on the use of the personal data by PAYNETICS can be found in this policy. Our website incorporates privacy controls which affect how we will process your personal data. By using them you can specify explicitly communicate with us your consent or refusal for collecting or processing your personal data.

We will not share your personal information except if:

  1. Being authorized by you
  2. In connection with providing our Services to you
  3. As may be required by law or court order
The Website is hosted in Bulgaria and subject to Bulgarian and European regulation for Data Protection Privacy. If you are accessing our Website from other jurisdictions outside the European Economic Area (EEA), please be advised that you are transferring your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws in Europe concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws and regulations governing the use of Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction.
SECTION III: USE YOUR PERSONAL DATA

1. In this section we have set out:
  1. the general categories of personal data that we may process;
  2. in the case of personal data which is not provided directly from you, the source and specific categories of that data;
  3. the purposes for which we may process personal data; and
  4. the legal bases of the processing.
We may collect and combine information when you interact with Paynetics, listed in next articles.

Information that You provide to us

2. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is your consent and our legitimate interests, namely monitoring and improving our website and services or providing personalized solutions for you.
3. We may process your account data with you explicit consent ("account data"). The account data may include your name, email address, Date of birth & Nationality. You are providing this data to us in order use our service. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website and business and our obligation to apply identification and strong authentication mechanisms when providing payment services to you.
4. We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests etc. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our contractual agreement.
5. We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include access logs into our platform, history of the associated services with our platform. The source of the service data is our platform, where you are maintaining your registered account. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our contractual agreement and our legal requirements for fraud prevention and security.
6. We may process personal documents that you load on our platform through our User registered area ("content data"). The content data in form of attached files may be processed for identification and verification purposes of enabling you using our website and services. The legal basis for this processing is our legitimate obligation to verify your identity in compliance with the AML law before we provide payment services to you.
7. We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is your consent to manage and improve our communication channels with you.
8. We may process information relating to transaction and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include card, bank account details and the transaction history details. The transaction data may be processed for the purpose of providing services to you and keeping proper records of those transactions. The legal basis for this processing is the performance of the contract between you and us or when taking steps, at your request, to enter into such a contract.
9. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
10. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact or inquiry forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, our contractual agreement and communications with users.
11. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
12. Please do not supply any other person's personal data to us, unless we prompt you to do so.
13. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, authorized agents, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
13.1 We may disclose specific personal data, requested for identification and verification purposes to our authorized suppliers or subcontractors as reasonably necessary for specify purposes.
13.2 We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes for managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
13.3 We may disclose your usage data and enquiry data to one or more of our co-partners, identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant services having the same purpose as the services Paynetics offers. Each such co-partner will act as a data controller in relation to the usage and enquiry data that we supply to it; and upon contacting you, each such co-partner will ask you to give your consent to its privacy policy.
13.4 In addition to the specific disclosures of personal data set out in this policy, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
14. You might be subject to automated risk assessment, although Paynetics reassures you, that the final decisions are always made by an authorized employee of the company.

Information from Cookies and Other Technologies
15. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
16. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
17. We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website.
(b) status – we use cookies to help us to determine if you are logged into our website.
(c) personalisation – we use cookies to store information about your preferences and to personalise the website for you.
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you.
(f) analysis – we use cookies to help us to analyse the use and performance of our website and services.
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally
18. We collect information when you access content, advertising, sites, interactive widgets, applications, and other products (both on and off of our Services) where Paynetics's data collection technologies (such as web beacons, development tools, cookies and other technologies, etc.) are present. These data collection technologies allow us to understand your activity on and off our Services and to collect and store information when you interact with Services we offer to partners.
19. This information also includes the kind of content or ads served, viewed or clicked on; the frequency and duration of your activities; the sites or apps you used before accessing our Services and where you went next; whether you engaged with specific content or ads; and whether you went on to visit an advertiser's website, downloaded an advertiser's app, purchased a product or service advertised, or took other actions.

Cookies used by our service providers

20. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
21. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy.
22. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
23. Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
24. Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. This website does currently respond to DNT browser signals or mechanisms.

Information from Others

25. We collect information about you when we receive it from other users, third-parties, and affiliates, such as:
  • When you connect your account to third-party services or sign in using a third-party partner (like Facebook or Google).
  • From publicly-available sources.
  • From advertisers about your experiences or interactions with their offerings.
  • When we obtain information from third-parties or other companies, such as those that use our Services. This may include your activity on other sites and apps as well as information those third-parties provide to you or us.
SECTION IV: RETAINING & DELETING PERSONAL DATA

26. This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
27. Personal data that we process for any purpose(s) shall not be kept for longer than is necessary for that purpose or those purposes.
28. We will retain your personal data as follows:
  1. all personal data will be retained for a minimum period of 5 years following termination of our mutual Servicing contract.
  2. as an exception to art.28.1, transaction data will be kept up to a maximum of thirteen months to allow for resolution of potential disputes and payment queries.
  3. all personal data will not be further processed in a manner incompatible with the purpose or purposes for which the information was originally collected.
29. Paynetics will take appropriate security measures against unauthorized access to, or unauthorized alteration, disclosure or destruction of, the data, and against all other unlawful forms of processing.
30. Once the purpose for which the personal data was obtained has ceased and the personal data is no longer required, Paynetics will delete or dispose of it in a secure manner.
31. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
SECTION V: SECURITY

32. We take the security of your personal data seriously and use reasonable electronic, personnel and physical measures to protect it from loss ,theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks.
33. We are dedicated to protect all information on the website as is necessary. However, you are responsible for maintaining the confidentiality of your personal authentication information by keeping your access passwords to our website platform confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately to the provided contact details at the end of this Policy.
SECTION VI: AMENDMENTS

34. Paynetics may update this policy from time to time by publishing a new version on this website.
35. You should check this page occasionally to ensure you are happy with any changes to this policy.
36. We may, as determined in our discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. It is important that users always maintain and update their contact information.
SECTION VII: YOUR RIGHTS

37. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
  1. the supply of appropriate evidence of your identity (for this purpose, we will ask you to provide identity verification documents via our platform)
  2. You have the right to instruct us to provide you with your personal data processed by us. Whereas your requests are manifestly unfounded or excessive, in particular because of their recurrence, we may charge a reasonable fee for providing the information or take an action to process your request.
  3. the deadline for our response is currently fixed at one (1) month, after receiving your request;
  4. You can request your personal data with email to privacy@paynetics.digital or access your personal data by visiting our website when logged into your registered account.
38. We may withhold personal information that you request to the extent permitted by law.
39. You may instruct us at any time not to process your personal information for marketing purposes.
40. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
41. Your principal rights under data protection law are:
  1. the right to access;
  2. the right to rectification;
  3. the right to erasure;
  4. the right to restrict processing;
  5. the right to object to processing;
  6. the right to data portability;
  7. the right to complain to a supervisory authority; and
  8. the right to withdraw consent.
42. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
43. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
44. You may request to limit the processing of your personal data in any of the following cases:
  1. the accuracy of personal data is disputed by you for a period that allows the administrator to verify the accuracy of your personal data;
  2. the processing is illegal, but you do not want your personal data to be deleted, and you require instead limiting their use;
  3. the administrator no longer needs your personal data for the purposes of processing, but you require processing them for the establishment, exercise or protection of legal claims;
  4. You have reproached the processing pending verification that the legal grounds on the basis of which we handle your personal data take precedence over your interests.
45. When processing is limited due to the presence of any of the above hypotheses under art.44, such data shall only be processed, with the exception of their storage, with your consent or for the purpose of establishing, exercising or protecting legal claims or protecting the rights of another individual or for important reasons of public interest to the Union or a Member State.
46. When you have requested a limitation of processing under art.44, we will inform you before revoking the limitation of processing.
47. You have the right, at any time on and on grounds relating to your particular situation, to object to the processing of your personal data when processing is done on any of the following grounds:
  • processing is necessary for the performance of a task in the public interest or in the exercise of the official powers conferred on the controller;
  • the processing is necessary for the purposes of our legitimate interests of the controller or of a third party, except where the interests or fundamental rights and freedoms of the data subject that require the protection of personal data are particularly advantageous to such interests.
48. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You have the right to object against profiling. We will discontinue the processing of your personal data unless we find that there are compelling legal grounds for the processing that take precedence over the interests, rights and freedoms of the data subject, or for the establishment, exercise or protection of legal claims.
49. You have the right to object to our processing of your personal data for historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
50. To the extent that the legal basis for our processing of your personal data is:
  1. consent; or
  2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. The same right applies for transmission of your personal data to another controller.
(Right to data portability)

51. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
52. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
53. You may exercise any of your rights in relation to your personal data by written notice to us and send to our official email address for communication, published on our website.
54. We will retain in our files some personally identifying information to prevent fraud, to troubleshoot problems, to assist any investigations, to enforce our Terms and conditions and to comply with legal requirements as is permitted by law. Therefore you should not expect that all your personally identifying information will be completely removed from our database in response to your request. Additionally, we keep a history of changed information to investigate suspected fraud with your account.
SECTION VIII: OUR DETAILS

PAYNETICS AD is registered as personal data administrator Under № 036580 according to the Bulgarian Law and Commission for Personal Data Protection.

Our principal place of business is bul. James Bourchier 76A, Hill Tower, Sofia, PO 1407, Bulgaria

You can contact us:
(a) by telephone, on the contact number published on our website from time to time
(b) by the following email – privacy@paynetics.digital
(c) by post, to the postal address given above