Privacy Policy

We take your personal privacy seriously

Trustpay Global was founded to improve the experience for consumers when transacting with businesses online. As part of this drive we take your personal privacy seriously.

The policy below explains how Trustpay Global collects, secures, uses and controls data relating to you that you provide through our Services and Sites. We would like you to please take the time to read through the policy and make sure you understand our practices.

We have made the privacy policy easy to read for your benefit. Our full legal terms are provided on the left side and on right we have explained it in short for you.

If you have any further questions please do not hesitate to contact us.

Overview

The Effective Date of this Privacy Policy is 25th May 2018.

Trustpay Global Limited (registered number: 07427913) is a company incorporated within England and Wales, with its registered office at 130 Wood Street, London, EC2V 6DL.

Trustpay Global is a registered on the Information Commissioner’s Register of Data Controllers (registration number Z2549792).

In order to operate the pinPay Service and to reduce the risk of money laundering and fraud Trustpay Global (“we” or “us”), the data controller, must ask you to provide us with personal information.

By consenting to, and agreeing the terms of, this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out herein. This Privacy Policy describes the information collection, use, how we use that information disclose. Trustpay Global takes the processing of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy.

By consenting to, and agreeing the terms of, this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out herein. This Privacy Policy describes the information collection, use, how we use that information, disclose. Trustpay Global takes the processing of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy.

When you complete any form, speak with our staff or submit any details to us or using our Website, we will collect, use and disclose your personal information in the manner described in this Privacy Policy.

Legal questions relating to the meaning of our Privacy Policy will be resolved in accordance with English law.

If you do not agree with this Privacy Policy then please do not use our services.

If you use pinPay or our website you accept this privacy policy.

What Information We May Collect About You

When you use our Sites and/or Services we may collect information about you, including the following:

  • When you register for a pinPay account
  • Use a pinPay (Trustpay Global) account
  • Pass details to Trustpay Global via our Sites
  • Pass details through other communication channels

The information we gather may include:

Personal Information: name, address, date of birth, phone number and email address.

Payment Transacting Information: relevant credit/debit card information and/or bank account information that you provide for payment transactions.

Security Information: to safeguard your personal information we will also require you to set the answers to different security questions. This required information is necessary for us to process transactions, issue a new password/pin if you forget or lose your existing password/pin, protect you against credit/debit card fraud and bank account fraud , and contact you should the need arise in administering your Trustpay Global account or the Trustpay Global Services you have used.

Identification Information: If we cannot verify the information that you provide, we may ask you to upload or send us additional verified information by fax or post (such as your driving licence, credit card statement, and/or a recent utility bill, or other information linking you to the applicable address), or to answer additional questions online to help verify your information. We will also require other identification information if you send or receive certain high-value transactions or high overall payment volumes through the Trustpay Global Services or as is otherwise required in order for us to comply with our anti-money laundering obligations under European law.

Non Personalised Information: when you access Trustpay Global Service we may collect and store device identification data and geolocation data, this is data in a form that does not permit direct association with any specific individual. This data is used to ensure it is you accessing our service and helps provide more secure transaction processing to prevent fraud. We may also collect information on which pages of our website you visit, IP addresses, the type of browser you use and the times you access our website. We use this information to try to understand our customers’ preferences better and to manage the load on our servers enabling us to improve our services and your experience with Trustpay Global. If we do combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.

Correspondence Information: if you send us correspondence, including emails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Trustpay Global to you. We retain these records in order to keep records of our relationship, to measure and improve our customer service and to investigate potential fraud.

In order to fulfill our legal obligations to prevent fraud and money laundering, we may obtain information about you from third party agencies, including your financial history, county court judgments and bankruptcies, from credit reference and fraud prevention agencies when you open a pinPay (Trustpay Global) Account and at any time when we feel it is necessary to prevent fraud and minimise our financial risks. Please refer to our Money Laundering Policy for further details.

In accordance with law, we shall however delete personal information about you when it is no longer necessary for us to retain it.

We only collect necessary personal and non personal information from you to:

  • Establish your identity when you open an account
  • Ensure we provide you a safe and secure online payment service
  • Check it is you accessing your account
  • Avoid the possibility of money laundering.

How We Collect Personal Data

Direct

Trustpay Global will collect this information from the internet when you use our website, sign up for a pinPay account, activate a pinPay account and use your existing account. This also applies when you make purchases using the pinPay service through corresponding online businesses that support pinPay.

From Third Parties

In order to complete your payments from other businesses using pinPay, Trustpay Global will be passed important personal data as described in “What We Collect About You”, by the online business you were buying services from. This information will allow us to save you from re-entering information (such as name, email address, personal addresses, telephone numbers, date of birth etc) if you have already entered this information on the online business you were transacting with. Please note that third parties you buy from and contract with may have their own privacy policies and Trustpay Global is not responsible for their operations, including but not limited to the way they handle your personal information.

Additionally, in order to protect all our customers against potential fraud, we verify the information you provide with the “Payment Processors” and/or “Credit Reference/Fraud Agencies”. In the course of such verification, we receive personally identifiable information about you from such services. To be specific, if you register a credit card or debit card or bank account with Trustpay Global, we will use card authorisation and fraud screening services to verify that your bank or card information and address match the information that you have supplied to Trustpay Global and that the card has not been reported as lost or stolen.

We collect data when:

  • You use our website or the pinPay service
  • You purchase goods using pinPay on an approved merchant website
  • We perform checks with fraud/identity agencies

How We Use Your Personal Data

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customised experience. You agree that we may use your personal information to:

  • Administer your pinPay account
  • Provide the pinPay services and customer support you request
  • Resolve disputes
  • Troubleshoot problems
  • Enable third party merchants to accept or facilitate payments from you using the Trustpay Global Services
  • Carry out your instructions to make and receive payments and undertake transactions using our services, including verifying that you have sufficient funds in your nominated bank account to make such payments
  • Notify you about changes to our service(s)
  • Improve our internal customer training
  • Comply with financial services regulations including retention of financial information and Transactions
  • Carry out financial and identity checks, fraud prevention checks, anti-money laundering and credit checks
  • Enable good customer service, including answering questions and responding to feedback and complaints
  • Enhance the security of our services
  • Ensure that content on our Website is presented in the most effective manner for you and for your computer
  • Provide you with information, products or services that you request from us or which we feel may interest you
  • Inform you about our new services and developments
  • Customise, measure, and improve our services and the content and layout of our website
  • Compare information for accuracy, and verify it with third parties

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

Retention

We are by law required to retain certain records for a period of at least five years after closure of your pinPay (Trustpay Global) account which will include your personal data such as your name, contact details, customer number and transaction history etc. We will delete and destroy all other personal data that we hold about you when you (or we) terminate your pinPay (Trustpay Global) Account. If you wish to cancel your account or request that we no longer use your personal information to provide you services contact us by email: customerservices@trustpayglobal.com or telephone 0345 450 6107 between 09:00-17:00 Monday-Friday excluding UK Public Holidays.

We do not sell your data to those annoying marketing companies.

We use your data to make sure we know who you are and that your account with Trustpay Global is safe and secure from others.

We hold your data for 5 years as we are required by law to do so.

Protection Of Your Information

Trustpay Global takes precautions – including administrative, organisational, technical and physical measures — to safeguard your personal information we collect and store against accidental loss, theft and misuse, as well as against unauthorised access, disclosure, alteration, destruction and damage.

Trustpay Global online services such as pinPay use Secure Sockets Layer (SSL) encryption on all web pages where personal information is collected. To make purchases from these services you must use an SSL-enabled browser such as Safari, Firefox or Internet Explorer. Doing so protects the confidentiality of your personal information while it’s transmitted over the Internet.

Where is it Stored?

The data that we collect from you is stored, secured and processed within Data Centres within the European Economic Area (“EEA”).

The countries that comprise the EEA are all countries of the European Union together with Iceland, Liechtenstein and Norway.

However on some occasions your personal information be transferred to, and stored at destinations outside the European Economic Area (“EEA”) for the reasons set out below:

  • The transfer is necessary for providing you with the services you request, i.e. if you transfer funds to a merchant that is not located in the EEA it will be necessary to send your details to that merchant
  • Or when our anti-fraud agencies, credit reference agencies and other service providers are based outside the EEA and require access to your data to perform their obligations to us and provide services to you

We have taken and will take all necessary steps to ensure that your data is treated securely and in accordance with this privacy policy no matter where it is located.

We will protect your information as described in this Privacy Policy if your Personal Data is transferred to other countries. By using our Sites and Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules that your country. Please contact us for more information about this at customer.services@trustpayglobal.com.

Be careful:

However, this high level of protection can only be effective if you follow certain security practices yourself. The security of your pinPay account relies on your pin. You must never share your pinPay (Trustpay Global) Account, pin, authorised devices or login details with anyone. Trustpay Global representatives will never ask you for your pin or password, so any email or other communication requesting your pin or password should be treated as unauthorized and suspicious and forwarded to privacy@trustpayglobal.com. If you do share your Trustpay Global pin or password with a third party for any reason, such as that the third party has promised to provide you additional services, the third party will have access to your account and your personal information and you may be responsible for the action taken using your pin or password.

If you are concerned that any of your login details have been compromised you can change them any time once you are logged on, but you should always also immediately contact Customer Services and tell us why you think your login details have been compromised. Details of how to contact Customer Services are available from the “Contact” section of the Website.

If or when you post on social networking services connected with Trustpay Global, please remember that the personal information you share is visible to other users and can be read, collected or used by them. You are responsible for the personal information you choose to submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features. To request removal of information from our community forum or chat rooms, contact us by at customerservices@trustpayglobal.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

To request removal of your personal information from social networking sites, you can either log into the third party application to remove your comment or you can contact the appropriate third party application. Your interaction with these features is governed by the privacy policy of the company providing it.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Certification:

Secure Payment Transactions and Personal Information:

Trustpay Global is audited annually and meets the requirement for the highest level of PCI-DSS (Payment Card Industry – Data Security Standards) compliance and registered with Visa and MasterCard as an approved technical provider who is safe and secure for the management of payment card data online and via call centres.

As a PCI:DSS Level 1 Service Provider, Trustpay Global, can be located on the approved Visa Merchant Agent List

We have a very secure system running within the EEA which is where your data is kept.

However you have to be careful with your own data.

We are regulated by both Visa and MasterCard for payment data security.

Access To Your Information

Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with applicable law.

You may review and amend your Personal Data by logging into your pinPay (Trustpay Global) Account. If you require assistance or information relating to this contact us.

If you do not have a pinPay (Trustpay Global) Account or if you have questions about your Account information or other Personal Data, please contact us.

If your personal details change, you can amend your details in the “myDetails” section of your pinPay (Trustpay Global) Account. We shall not be liable for any loss arising out of your failure to keep your personal details up to date. Specific personal details cannot be amended in your pinPay Account without assistance from Trustpay Global customer services. For further advice please contact us by email: customerservices@trustpayglobal.com or telephone 0345 450 6107 between 09:00-17:00 Monday-Friday excluding UK Public Holidays. Please note that for certain amendments (ie, Surname), identification and proof of change will be required.

If you believe that any information we are holding on you is incorrect or incomplete, you should update this within your pinPay account or please write to or email us as soon as possible. We will promptly correct any information found to be incorrect.

You have the right to rectify or delete any information about you that is not accurate and the right to ask us not to process your personal data for any marketing purposes. We shall not be liable for any loss arising out of your failure to keep your personal information accurate and up to date.

You should keep your personal information up to date at all times. If you need us to send you details of the personal data we store on you please contact us at privacy@trustpayglobal.com, there may be a small administration charge for this service, up to £10

Controlling Disclosure Of Your Data

Merchants and online Businesses

When making a payment to an online business, which accepts pinPay we will, at a minimum, pass on your email address to the recipient and result of your attempted payment (whether successful or unsuccessful). Depending on the requirements of the merchant and the type of payment involved, we may also send other personal details such as your name, address and country of residence, if the recipients request this information from us. This is to improve the payment process, to reconcile payments with the commercial transaction or to conduct their own anti-fraud and anti-money laundering checks.

Fraud and Credit Reference Agencies

When you open a pinPay (Trustpay Global) account, and potentially at intervals of up to every 3 months and at any other time we feel it is necessary to do so to protect our financial interests and prevent money-laundering or fraud, we share certain information about you and your pinPay (Trustpay Global) Account, financial history and transactions as part of our normal business operations with our banks, payment facilitator partners, credit/debit card processing services, identity verification service providers and credit reference agencies to identify and verify users, to limit our exposure to fraud and other criminal activities and to manage our financial risk. We can provide you with a list of the credit reference agencies we use upon your written request to the email address set out in the Contact Us section below. When conducting identification or fraud prevention checks, the relevant parties may retain a record of our query along with your information and may share this information with other fraud prevention agencies. If you want to know what information these companies hold about you, you can write to them to request access to your information.

We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We do not sell your personal information to third parties. We may also disclose your personal information to:

  • Any member of our group of companies (our subsidiaries, our ultimate holding company and its subsidiaries) as defined in section 11599 of the Companies Act 2006
  • a prospective buyer of our business or a buyer of a substantial number of the shares in our business, if Trustpay Global is involved in a merger, acquisition, or sale of all or part of its assets, you will be notified by email and/or prominent notice on our website of any change of ownership or uses of your personal information, as well as any choices you may have regarding your personal information
  • The police, other lawful enforcement or regulatory bodies or court, if we are under a duty or required by law to disclose or share your personal data , or to protect the rights, property, or safety of ourselves or our group companies, our customers, or others
  • Third parties where you have expressed an interest in receiving information about their goods and services
  • Third parties we may occasionally use to provide you with the services that you have requested (we require these third parties to not use your personal information for any other purpose)

Other:

It may be necessary — by law, legal process, litigation and/or requests from public and governmental authorities within or outside your country of residence — for Trustpay Global to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.

We only allow third parties access to your data when required to make a transaction with a third party, or when required by law or for fraud/identity agency reasons

Children

We do not knowingly collect personal information from children under 13. If we learn that we have collected the personal information of a child under 13, we will take steps to delete the information as soon as possible.

We would delete any personal information on children as soon as we are aware.

Third Party Sites

Our website may contain links to other websites of interest or businesses which accept pinPay as a payment option. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information, which you provide whilst visiting such sites that are not governed by this privacy statement. You should exercise caution and look at the privacy statement and any other terms and conditions applicable to the website in question. This is your responsibility.

We are not responsible for other people’s privacy policies and you should read them to check you are happy.

Notification of Changes

This Privacy Policy may be revised over time to reflect changes to our privacy practices or as new features are added to the Trustpay Global Sites and Services or as we incorporate suggestions from our customers. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. If you disagree with the terms of this Privacy Policy, you may close your account at any time.

Any changes we make to this Privacy Policy in the future will be posted on this page. Any new Privacy Policy will be effective from the Effective Date. We reserve the right to make changes to our Privacy Policy at any time, where such change is required by applicable legislation.

If we make any material changes to the way your personal data are used, we will notify you by email prior to the change becoming effective. You may object to any new use or change in the use of your personal data by contacting us however you must immediately close your account in accordance with our Terms and Conditions if you do object.

The date of the current version of the Privacy Policy is shown above. See Effective Date within Overview section.

This policy may be changed, however any major changes will be notified to you by email.

Contacting You

We may contact you by email to the primary email address registered with your pinPay (Trustpay Global) Account or by telephone to the contact telephone numbers you have provided when registering for your account or by post to the address details provided when registering for your account. You can change your primary email address and/or contact telephone number at any time when you are signed into your account.

You may also receive system-generated transactional emails such as confirmation of fund uploads notification of receipt of payments, notification of password changes etc. which are necessary for the proper operation and administration of your account. If you no longer wish to receive emails which are not promotional in nature, then you have the option to deactivate your account. To deactivate your account please contact us by email: customerservices@trustpayglobal.com or telephone 0345 450 6107 between 09:00-17:00 Monday-Friday excluding UK Public Holidays.

Trustpay Global representatives will never ask you for your pin or password, so any email or other communication requesting your pin or password should be treated as unauthorized and suspicious and forwarded to privacy@trustpayglobal.com. If you do share your Trustpay Global pin or password with a third party for any reason, including because the third party has promised to provide you additional services, the third party will have access to your pinPay (Trustpay Global) account and your personal information, and you may be responsible for action taken using your pin or password.

If you are concerned that any of your login details have been compromised, you can change them any time once you are logged on but you should always also immediately contact Trustpay Global Customer Services and tell us why you think your login details have been compromised. Details of how to contact Trustpay Global Customer Services are available from the “Contact” section of the Website.

Nobody likes uninvited emails, therefore we only notify you of important actions that have occurred on your account.

Contacting Us

If you have general questions, comments or requests regarding this Privacy Policy and privacy practices or questions about your Personal Data you may contact us: Email: customer.services@trustpayglobal.com

Our data protection officer can be reached at: Email: privacy@trustpayglobal.com Post: Data Protection Officer, Trustpay Global Limited, Surrey Research Park, 22 & 24 Frederick Sanger Road, Guildford, GU2 7YD, UK

Users in the European Economic Area (EEA) and Switzerland have the right to lodge a complaint with the Supervisory Authority for data protection in their country, should they find that we did not appropriately address their privacy or personal data question or concern.

Customer Service

General customer service enquiries, information or exercising of your rights, please contact us by email: customer.services@trustpayglobal.com or telephone 0345 450 6107 between 09:00-17:00 Monday-Friday excluding UK Public Holidays.

Complaints

If you have any complaints relating to any aspect of our service, please email complaints@trustpayglobal.com. Please state clearly the nature of the complaint. We will acknowledge your complaint within five working days and issue a tracking number. We will use the tracking number in all future communications. You will also be assigned a contact name who will be responsible for keeping you informed of the progress of any complaint through to resolution.

NOTE: In order to safeguard your personal information please ensure that you do not provide your pin or password to Trustpay Global via email or any other communication method (including Customer Services).

Information on how to contact Trustpay Global

Your Rights

If you are a pinPay TrustpayGlobal Services User in the European Economic Area (EEA) and Switzerland you also benefit from certain rights granted by applicable law but subject to limitations therein. These rights include the right of access, rectification, restriction, opposition, erasure and portability, and the right to not be subjected to automated decision-making. If you want to exercise those rights or find out more, please contact us.

If you are a pinPayUser in the European Economic Area (EEA) and Switzerland you can benefit from certain rights granted by law, but subject to limitation.

Cookies and Other Tracking Technologies

General

A cookie is a small file, which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not.

Cookies do not contain any information that personally identifies you, a cookie in no way gives us access to your computer or any information about you.

A cookie is a small amount of data containing information that is downloaded to the device from which you access our site. Cookies are useful because they allow us and other websites to recognise your device. For more comprehensive information about how cookies work, see http://www.allaboutcookies.org. Cookies are widely used in order to make websites work, or work more efficiently and to provide information to the owners of the site. For example, they can allow you to navigate between web pages of our site and remember your preferences such as your language selection.

Types of Cookies we Use

In order to comply with legislation, we have reviewed the use of cookies on our site and set out the information below. This is to ensure that you are aware of these cookies and are able to give your consent for the placing of some or all of these cookies on your device when you use our site.

In summary, we use the following types of cookies:

  • Session security cookies – These are the cookies that are essential for our site to operate such as those which identify you so you can log into your Trustpay Global Account. They allow you to move around our website and use the services you have requested securely. These cookies will be activated when you enter our site and as you use our site. They are terminated when you exit our site.
  • Compliance cookies – These include the cookies that are necessary to assist in meeting our regulatory compliance obligations, such as anti-money laundering and anti-fraud obligations and prevent your Trustpay Global account from being hijacked. These cookies will be activated when you enter our site and as you use our site. They are terminated when you exit our site.
  • Performance cookies – These are cookies that help us to improve how our site works and to deliver a better service to you. For example, they will assess which pages you visit most often or if you get an error message. They also allow us to see if you have used the site of one of our group or affiliated companies. All information collected by these cookies is aggregated and therefore anonymous.
  • Functionality cookies – These cookies allow us to deliver a more personalised service to you and allow our site to remember choices you have made such as the language you prefer or the region you are in. They may also be used to provide services you have requested such as being able to comment on one of our blogs.

Third Party cookies

When you visit a page on our site with content embedded from third parties, i.e. YouTube or Twitter, cookies may be downloaded onto your device. We do not set or control these cookies. If you are concerned about the types of cookies that may be downloaded you check the privacy policy of third party websites for more information about these cookies. The use of cookies by our service providers is not covered by this privacy policy.

Blocking Use of Cookies
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.

Should you want to continue using our services but restrict our use of cookies, you can block certain cookies by activating the setting on your browser, which allows you to refuse the setting of all or some cookies. In order to utilize pinPay (Trustpay Global) Account it is necessary to have locally set cookies enabled as a minimum. These are used for Session Security and Compliance as detailed above. Preferably Third Party cookies will also be enabled. These are used for Performance as detailed above.

Caution: if you use your browser settings to block all cookies you will not be able to use your pinPay (Trustpay Global) Account or use all areas of the Trustpay Global website.

Script and Tags

Technologies such as 1st party and 3rd party scripts are used by Trustpay Global. These technologies are used for functional purposes only.

We do use cookies but only to manage security

Definitions

Account means a Trustpay Global pinPay Account.

Personal Data means information that can be associated with an identified or identifiable person. “Personal Data” can include name, postal address (including addresses), telephone number, email address, financial account information, account number, and date of birth. Personal Data does not include information that does not identify a specific user.

Process describes any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

Services means all Trustpay Global products, services, content, features, technologies, or functions (including integrations with third party services) and all related sites, applications and services.

Site means the Trustpay Global websites, mobile apps, official social media platforms, or other online properties through which Trustpay Global offers the Services.

User means you or anyone else who has established a relationship with Trustpay Global (for example, by opening an Account) or otherwise uses the Services or accesses the Sites.