Privacy Policy

This Privacy Policy describes the information PAAY LLC (“PAAY” “we,” and “us”) collects from its users via PAAY’s website (www.paay.com) (the “Site”) as well as the services offered thereon (the “Services”), and the manner by which such information is used. At PAAY, we are committed to safeguarding your privacy. We want you to know how we may collect, use, share, and keep information about you and the choices that are available to you. To the extent other offerings of PAAY are governed by different privacy terms, then this Privacy Policy shall only govern your use of the Site and the services thereon, and your use of those other offerings shall be governed by those other privacy terms.

Amendments and Changes to this Privacy Policy

We may amend this Privacy Policy from time to time by posting a revised version and updating the “Last Updated” date below. The revised version will be effective at the time we post it. We will provide you with reasonable prior notice of substantial changes in how we use your information. Where you might feel these changes may cause material detriment to you, you may of course cease to use the Services on the Site at any time. We encourage you to review this Privacy Policy whenever you use our Services to stay informed about our information practices and the choices available to you and to contact us if you have any questions about these changes. Your continued use of our Services after changes have been posted to this Privacy Policy constitutes your acceptance of the amended and updated Privacy Policy.

Information You Provide; Collection of Information

We collect information from visitors of our Site when a person or business (“you” or “your”) submits information to us in order to subscribe for one or more PAAY offerings or when you sign up for a PAAY account to receive our 3DS services. The information we collect about you may include, without limitation:

• Identification information, such as your name, email address, postal address, phone number, photograph, birthdate, passport, driving license and the like;
• Financial information and credit reporting agency information; other historical, contact and demographic information; and
• Any other information required to complete the merchant processing application form, if applicable.

We also collect information you upload to or send through our Services, including Information about the products and services you sell, and other Information you provide about you or your business from time to time.

Some of the information we collect is collected to comply with applicable laws and regulations, including anti-money laundering, anti-terrorism and security laws.​

We collect information you provide when you participate in contests or promotions offered by PAAY or our partners, respond to our surveys or otherwise communicate with us. Without information about you, we may not be able to provide you with the Services or the support you request.

Information We Collect from Your Use of our Services

We collect information about you when you use our Services, including the following:

Device Information. We collect specific information about the device you use when you access our Services (the “Device”), including your hardware model, operating system and version, unique device identifier, mobile network information and information about your Device’s interaction with our Services. We may also identify other software running on your Device for anti-fraud and malware-prevention purposes (but will not collect any content from such software).

Use Information. We collect information about how you use our Services, including your access time, browser type and language and Internet Protocol (“IP”) address.

Information Collected by Cookies and Web Beacons. We use various technologies to collect information when you use our Services, including sending cookies to your Device and using web beacons. Cookies are small data files that are stored on your hard drive or in Device memory when you visit a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We also may collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, track the number of visits to our website, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information and to learn how to block or delete cookies used in the Services, please see “Your Choices” below.

Third-Party Advertising and Analytics

We may allow third-party service providers to deliver content and advertisements in connection with our Services and to provide anonymous site metrics and other analytics services. These third parties may use cookies, web beacons, and other technologies to collect information, such as your IP address, identifiers associated with your Device, other applications on your Device, the browsers you use to access our Services, webpages viewed, time spent on webpages, links clicked, and conversion information (e.g., transactions entered into). This information may be used by PAAY and third-party service providers on behalf of PAAY to analyses and track usage of our Services, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand how you use our Services. The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies.

Use of Information

In addition to using the information you provide in order to evaluate and process your merchant processing application, we may also use the information about you to provide, maintain and improve our Services, such as:

• Developing new PAAY products and Services and improving those already in the market;
• Delivering the information and support you request, including technical notices, security alerts, and support and administrative messages; and
• Sending you information we think you may find useful or which you have requested from us about our Services, provided that you have not objected to being contacted for these reasons.

We may use information about you to improve, personalize and facilitate your use of our Services. For example, when you sign up for a PAAY account, we may associate certain information with your new account, such as information about other accounts you had or currently have with PAAY, and prior transactions you made using our Services. We also may use information about you to measure, customize, and enhance our Services, including the design, content, and functionality of our applications and websites, or to track and analyze trends and usage in connection with our Services.

We may use information about you to send you news and information (provided you have not indicated otherwise) or to conduct surveys and collect feedback about our Services and to communicate with you about products, services, contests, promotions, discounts, incentives and rewards offered by us and select partners, based on your communication preferences and applicable law. We also may contact you to resolve disputes, collect fees and provide assistance for problems with our Services or your PAAY account. You can tell us to not contact you with information about our other products and services at any time, either by contacting us, by following the unsubscribe link in our communications or by changing your notification settings by logging into your PAAY account. Please note that at all times, even where you choose not to receive promotional content from us, we may still message you about the Services for which you have signed up.

We may use information about you:

• To protect our rights or property or the security or integrity of our Services;
• To verify your identity as required by anti-money laundering, anti-terrorism and security law (e.g., some of the government-issued identification numbers we collect are used for this purpose);
• To investigate, detect, and prevent fraud, security breaches and other potentially prohibited or illegal activities;
• To comply with any applicable law, regulation, legal process or governmental request; and
• For any other purpose disclosed to you in connection with our Services.

We may use third-party service providers to process and store your information. For more information, please see the “International Data Transfer” section below.

In addition to the foregoing, we may aggregate and anonymize information you provide to us in such a way as to ensure that you are not identified or identifiable from it. This data may be used for statistical, analytic, and administrative purposes, including for customizing our web sites, analyzing trends, tailoring products and services, or conducting risk and cost analysis. We may share anonymized or aggregated data at our discretion, in accordance with applicable laws.

Sharing of Information

We may share information about you as follows:

• With our group companies and affiliates for the purposes outlined above, subject to applicable laws and regulations;
• With third parties to provide, maintain and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention, identity verification and fee collection services), as well as financial institutions, payment networks, payment card associations and other entities in connection with your application and the payment process;
• With our banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you meet their criteria which includes having PAAY close your PAAY account due to your breach of the Terms and/or any other agreement to which PAAY and you are parties;
• With third parties that run advertising campaigns, contests, special offers or other events or activities in connection with our Services;
• With other users of our Services with whom you interact through your own use of our Services. For example, we may share information when you make or accept a payment using our Services;
• In connection with or during the negotiation of any merger, sale of company stock or assets, financing, acquisition, divestiture or dissolution of all or a portion of our business;
• If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from tax authorities), (ii) to enforce the terms of our Seller Agreement or other applicable agreements or policies, (iii) to protect our rights or property, or the security or integrity of our Services or (iv) to protect us, users of our Services or the public from harm or potentially prohibited or illegal activities; or
• With your consent.

We also may share aggregated information with third parties that does not specifically identify you or any individual user of our Services.

Your Choices

Personal Information

You may access, change or correct information about you by logging into your PAAY account at any time or by making a request to us using the contact details below, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information.

Canceling Your Account

If you wish to cancel your PAAY account, you may do so by logging into your PAAY account or by emailing us using the contact details provided below. However, even after you cancel your PAAY account, we may retain archived copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Seller Agreement or other applicable agreements or policies or to take any other actions consistent with applicable law. The termination of your PAAY account shall not result in the automatic termination of any merchant processing services that may be receiving from PAAY and/or any other account(s) that PAAY and/or you may have established in connection with such merchant processing services, if applicable.

Cookies

We try to make your experience with PAAY simple and meaningful. When you access or use the Services, our web server may send a cookie to your Device. Certain cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to use the Services and as such, will last longer.

We may use cookies to:

• Remember that you have visited us or used the Services before. This means we can identify the number of unique visitors we receive, which allows us to make sure we have enough capacity to accommodate all of our users.
• Customize elements of the promotional layout and/or content of our website or application.
• Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.

Most web and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser settings to prevent automatic acceptance of cookies or to notify you each time a cookie is set.

You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note, however, that by blocking or deleting cookies used in the Services, you may not be able to take full advantage of the Services.

As described above, we also use cookies to gather information about the areas of the PAAY website you access and your access and use of our applications or other content. This information is used to place interest-based advertisements on the website or application which it is believed will be relevant to you. This may mean you see advertisements for PAAY on other websites and applications that you visit.

Type of Cookies

Description and further information

Essential Cookies

Essential cookies are cookies that enable you to navigate and use all the features in the Services provided by us. For example, without these, you would not be able to navigate between pages on the website

Functionality Cookies

These cookies enable us to remember you have used our Services before, preferences you may have indicated and information you have provided to us to give you a customized experience. For example, this would include ensuring the continuity of your registration process.

Performance and Analytical Cookies

This information is used to make sure our Services can cope with the volume of users, to help us correct errors in the Services and to measure use across our Services. These cookies help us understand if you have used our Services before so we can identify the number of unique users we receive. They also help us understand how long you spend using our Services and from where you have accessed the Services, so that we can improve the Services and learn about the most popular aspects of the Services. We use third parties, for example, Google Analytics, to analyze statistical information from users of the Site. We might be able to associate such information with other information which we collect from you once we receive it from a third party.

Retargeting or advertising Cookies

These cookies collect information about the pages you visit and also other information about other websites you visit. This information is only collected by reference to the cookie identifier that you are using.

Examples of our third-party service providers include:

• Google: To understand more about Google Analytics and update your preferences in relation to Google’s analytics tools please see here  https://support.google.com/analytics/answer/6004245?hl=en-GB  and to opt out of Google Analytics please click here https://tools.google.com/dlpage/gaoptout.

Facebook: To understand more about Facebook advertising please see here https://www.facebook.com/about/ads

Promotional Communications

You may opt out of receiving promotional messages from PAAY at the time that you provide your information or thereafter via the unsubscribe link contained within each of our promotional messages. If you decide to opt out, we may still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.

Children’s Online Privacy Information

PAAY does not knowingly collect personal information from minors who are under the age of 18 through the Site and/or the Services thereon. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his/her consent, then he or she should contact PAAY at the contact information described below. If we become aware that a child under the age of 16 has provided us with personally identifiable information, we will delete such information from our files. Further, the Children’s Online Privacy Protection Act (“COPPA”) requires parental consent for collection of data from children younger than the age of 13 years old. For tips on protecting children’s privacy online, generally, please view the U.S. Federal Trade Commission (“FTC”) website at http://www.ftc.gov/privacy/privacyinitiatives/childrens.html.

California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the address provided below in the “Contact Us” section.

If you are a California resident, please refer to our California Privacy Act Notice for additional privacy rights you have pursuant to the California Consumer Privacy Act of 2018, Cal. Civ. Code §1798.100 et. seq.

We do not sell the personal information that we collect on California residents.

Security

We take reasonable measures, including administrative, technical and physical safeguards, to protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We hold information about you in various locations, including at our own premises and with the assistance of third-party service providers. We restrict access to personal information to those PAAY employees, contractors and agents who need to know that information in order to transmit, store or process it, who are subject to contractual confidentiality obligations consistent with this Privacy Policy and who may be disciplined or terminated if they fail to meet these obligations. Our third-party service providers store and transmit personal information in compliance with this Policy and other appropriate confidentiality and security measures.

Nevertheless, PAAY cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. In the event that any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations. 

PAAY is committed to protecting your privacy rights. Further, where we transfer your information we will take all reasonable steps to ensure that your privacy rights continue to be protected under applicable data protection legislation.

By interacting with our Services, you agree to this storing, processing and/or transfer described above.

Conflicting Provisions

If any provision hereunder conflicts with those contained in any other agreement that you may sign or have signed with PAAY from time to time and/or any other terms and conditions imposed by PAAY under which you are subject, then these Terms shall govern your use of the Site/Services, and those other agreements/terms and conditions shall govern all such other uses.

Contact

Please contact our Privacy Department with any questions or concerns regarding this Privacy Policy by emailing privacy@PAAY.com. 

If you have any questions or concerns regarding our policy or if you believe our policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our Privacy Department listed above and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.

Last Updated: March 2021