last updated: November 12, 2022
1. Who's your controller?
SaltPay Group encompasses a range of companies who provide payments solutions and related services to individuals and legal entities, always focused on small and medium sized businesses. For the purposes of the applicable data protections laws, SaltPay is the data controller of your personal data unless otherwise specified. The SaltPay entity responsible for your data may depend on your location and the Service you use with us.
2. The data we collect about you
We collect information about you in three ways: (i) when you provide it to us directly; (ii) when we gather information while you are using the Services; and (iii) when we collect information from other sources. Please note that the personal data we collect, and process depend on the Service you use.
Below is a description of the types of information that we may receive directly from you.
- “Identity Data” includes first name, last name, email address, address and telephone numbers.
- “Call Recording Data” includes information collected when recording telephone calls which you make to us or receive from us.
- “Financial Data” includes bank account and payment card details, which may include the Bank Identification Number (BIN) and the last four digits of the card number, the card type, postcode, expiry date or country of issue.
- “Job Application Data” If you apply for a job with us, which includes your contact information (including name, postal address, email address and phone number), job history, curriculum vitae, contact details of your referees and any other personal information you choose to submit along with your application when applying for a job at SaltPay.
- “Other Information” you choose to provide. You may choose to provide other information, such as different types of content (e.g., photographs, articles, comments), content you make available through our live web chat function or through social media accounts or memberships with third parties, or any other information you want to share with us.
We also get data from the devices you use when you interact with our systems, like your location or information about the device you’re using.
- “Technical Data” includes information we obtain from your device or browser (such as IP address, your login data, version and device identifiers, time zone setting and location, browser plug-in types and versions and operating system) as well as how you use our website. We may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies. We may also receive data about you if you visit other websites employing our cookies.
- “Commercial Data” includes information about the products and services you sell e.g., inventory, pricing and other data and information about your payment transactions e.g., when and where the transactions occur, a description of the transactions, the payment or transfer amounts, billing and shipping information, and payment methods used to complete the transactions.
We also need to check that you are eligible for the services you want to use, to ensure that you use them legally, and to protect your data and our services from potentially fraudulent activities which may put you and your money at risk. To do this, we may collect data about you from companies that help us verify your identity, do a credit check, prevent fraud or assess risk, which we refer to as “External Data”.
- “Background Data” includes Identity Data from publicly availably sources such as the company registrar and the electoral register in your country, as well as data from search information providers and third-party websites such as UK Company House, CreditSafe, ComplyAdavntage, Google.
- “Fraud Data” account or credit-related information with any credit reporting agency or credit bureau.
We also obtain information about your customers on your behalf as your service provider when they transact with you or otherwise when you request that we do so. We call this information “Customer Data”. We process Customer Data when they interact with you through your use of the Services, for instance when they make a payment at your establishment, or schedule an appointment, or receive an invoice from you. The particular Customer Data we collect will vary depending on your location, which Services you use and how you use them. Your Customers’ Data may include:
- “Customer Device Data” includes information about your customer's device, including hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device's interaction with our Services.
- “Customer Financial Data“ includes bank account and payment card numbers.
- “Customer Identification Data” includes first name and last name.
- “Customer Transaction Data” When your customers use our Services to make or record payments to you, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions which may include item-level data, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.
We use Customer Data as part of our contractual obligation to provide the Services you request to you.
It is your responsibility to obtain any necessary permission for us to process Customer Data in the manner envisaged in this Policy so that we can provide you with the Services requested by you.
3. Lawful bases for processing your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform a contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- where we need to comply with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data other than some cases when sending direct marketing communications to you via email or text message.
Note that we may process your personal data relied on more than one lawful base depending on the specific purpose(s) for which we are using your personal data.
4. Purposes for which we will use your personal data
We have set out below, a description of all the purposes for which we will process your personal data.
- If you are a legal entity, to register you as a new customer.
- If you are using our Services (either as our customer or a customer of our customer), to facilitate a transaction as an acquirer.
- If you are a legal entity, to manage our arrangement with you, including: (a) managing payments, fees and charges; (b) collecting and recovering money owed to us.
- To provide the live chat function on our website to answer any enquiries from users regarding our Services.
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
- To use data analytics to improve our website, Services, marketing, customer relationships and experiences.
- To make suggestions and recommendations to you about Services that may be of interest to you.
- To comply with laws and to respond to and comply with requests from the government, regulators and other third parties with legal authority.
- To investigate, detect and prevent fraud or crime.
- To exercise or defend legal claims.
- To consider your application for a job.
We will only process your personal data for the purposes specified above unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain to you the legal basis which allows us to do so.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity and Technical Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (“Marketing and Communications Data”).
You would receive marketing communications if you purchased similar goods or services or have been in contact with us about similar goods or services. We would also send you marketing communications when you have given your consent for us to do so.
You can ask us to stop sending you marketing messages by contacting us at any time at firstname.lastname@example.org.
6. Disclosures of your personal data
We may share the personal information described in section 2 for the purposes set out in section 4 with the following service providers and third parties:
- Service providers who provide IT and system administration services.
- Professional advisers who legitimately need to have access to the personal data for a business need.
- Regulators and other authorities who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
Further, all SaltPay Group companies have a legitimate business interest (i.e., to provide a complementary or related service for your business) in accessing the data and may do so for the purposes and in the way described in this Policy. SaltPay Group companies shall be taken to include any entity that directly or indirectly controls, is controlled by, or is under common control with SaltPay from time to time, whether located in or outside of the United Kingdom. When we transmit data between our group entities located inside and outside of the EEA, this sharing is governed by our intra-group data sharing and processing agreement which is drafted in compliance with the GDPR and includes the relevant safeguards necessary for transfers outside the EEA.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and, unless otherwise notified to you, only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International transfers
Many of our external third parties are based outside the EEA or the UK so their processing of your personal data will involve a transfer of data outside the EEA or the UK.
Whenever we transfer your personal data out of the EEA, we will take reasonable steps to ensure that your personal data is kept secure, including where relevant, by entering into appropriate contractual terms with the receiving party outside the UK or EEA, such as the Standard Contractual Clauses approved by the EU Commission or issued by the UK Information Commissioner’s Office (as applicable) or any other approved mechanisms that may become available to us in the future. We will also carry out a risk assessment of the laws and practices of the destination country to identify any technical and organisational measures that need to be put in place to ensure that your personal information is fully protected when transferred to that country.
8. Data security
Data security is extremely important to us, and we have put in place appropriate security measures (such as encryption, confidentiality obligations of our personnel, log-in records, vulnerability testing etc,) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures and incident management policies to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. How long we retain your information
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purpose of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the relevant laws, amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party).
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (c) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to a third party. We will provide to the third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
- Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.
If you wish to exercise any of the rights set out above, please contact us at email@example.com.
No fee is usually required to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What me may need from you is specific information to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).
Time limit to respond, in cases of legitimate requests, is one month. Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Changes to this Policy and your duty to inform us of changes
SaltPay reserves the right to change, modify or amend this Policy at any time, but will not reduce the level of privacy protection contained herein. This version was last updated on 28th October 2022.
12. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
If you have any questions about the Policy or you would like to exercise your rights as stated in section 10, please contact us by e-mail at firstname.lastname@example.org. Our DPO, together with our data protection team, will deal with them.