Privacy Policy

Pax2pay is a wholly owned subsidiary of Paxport Group. Paxport Group UK Ltd is a software and private limited company registered in England under number 02447353. Its registered office is The Landing, 2nd fl, Redcliff Street, Bristol, BS1 6HU.

Paxport AB is a software and a private limited company registered in Sweden under number 556481-2310. Its registered office is Hollandargartan 13 111 36 Stockholm Sweden.

Pax2pay Ltd is a company registered in England and Wales with Company number 11747127. Its registered office is The Landing, 2nd fl, Redcliff Street, Bristol, BS1 6HU.

Paxport Group UK Ltd, Paxport AB, and Pax2pay may share data between themselves when providing services. This privacy notice sets out how Paxport Group UK, Paxport AB, and Pax2pay (who are collectively known as “Paxport Group”) will process personal data we collect from or about you, or which you provide to us.

Please read this Privacy Policy carefully to understand why data is being collected and what we do with that data once in our possession.

We may change the privacy policy of the terms of business from time to time by amending this page. Paxport Group Risk Manager is Chris Nourse who can be contacted at [email protected].

On what basis we can process your information

Data Protection law states we are allowed to use personal information only if we have a proper reason for doing so. This includes sharing it outside the Paxport group. The law states we must have one or more reasons for processing it:

• to fulfil a contract we have with you, or
• when it is our legal duty, or
• when it is in our legitimate interest, or
• when you consent to it

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you.

What we use your personal information for

• to manage job applications at various stages of selection
• to manage our relationship with you or your business
• to develop new ways to meet our customers’ needs and to grow our business
• to develop and carry out marketing activities
• to provide guidance or advice about our products and services
• to test new products
• to develop and manage our products and services
• to make and manage customer payments
• to collect and recover money that is owed to us
• to manage risk for us and our customers
• to obey laws and regulations that apply to us
• to respond to complaints and seek to resolve them
• to run our business in a proper and efficient way which includes managing our financial position, business capability, planning communications, audit and governance
• to exercise our rights set out in agreements or contracts

Where we collect personal information from

We may collect personal information about you (or your business) from other companies within the Paxport Group and from these sources:

data you give to us:

• When you apply for our products and services
• When you communicate with us by either telephone, emails and letters
• When you use our websites or mobile device apps
• When you apply for vacancies directly
• When you send us unsolicited personal data

Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:

• Payment and transaction data.
• Profile and usage data. This includes the profile created to identify yourself when you consume a service from a third party via the internet or mobile application. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.

Data from third parties we work with:

• companies that introduce you to us
• Recruitment agencies
• Card associations
• Insurers
• Social networks
• Public information sources such as Companies House
• Agents working on our behalf
• Market researchers
• Government and law enforcement agencies.

How long we keep your data for

We will keep your personal information for as long as you are a customer of Paxport Group. After you stop being a customer, we may keep your data for up to 7 years for one of these reasons:

• To respond to any questions or complaints.
• To show that we treated you fairly.
• To maintain records according to rules that apply to us.

We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

As regards the recruited applicants whose data are stored in their personal file, the retention period of their data related to the selection procedure follows the period of storage of the personal file, which is six years.

The retention period for data relating to the non-recruited applicants, and unsolicited personal data, the documents related to these candidates are kept for a period of six months after which time they are destroyed.

Who your information will be shared with

We may share your personal information with companies within the Paxport Group and these organisations:

• Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business
• HM Revenue & Customs, regulators and other authorities
• Any party linked with you or your business’s product or service
• Companies we have a joint venture or agreement to co-operate with
• Organisations that introduce you to us
• Companies that we introduce you to
• Market researchers
• Companies you ask us to share your data with.
• Our professional indemnity insurer in the event a claim is made against us in order to defend ourselves.

We may need to share your personal information with other organisations to provide you with the product or service you have chosen:

• If you have a debit, credit or charge card you use with us, we will share transaction details with companies which help us to provide this service (such as Visa and Mastercard).

We may also share your personal information if the make-up of Paxport Group changes in the future:

• We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
• During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
• If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

Security of your data

Your data will be held on secure servers within the European Economic Area (“EEA”) with all reasonable technological and operation measures put in place to safeguard it from unauthorised access. Your identifiable information will be encrypted or minimised when stored in our systems.

Sending data outside of the EEA

We will only send your data outside of the European Economic Area (‘EEA’) to:

• Follow your instructions
• Comply with a legal duty
• Work with agents to enable us to deliver our service for you

If we do transfer information to agents outside of the EEA, we will make sure that during the transfer process it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:

• Where possible transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
• Where possible transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.

How you can access and update your information

You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent to the Risk Manager, Paxport Group UK Ltd, The Landing, 2nd fl, Redcliff Street, Bristol, BS1 6HU or [email protected].

How you can object to us using your personal data

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted. You can ask us to restrict the use of your personal information if:

• It is not accurate.
• It has been used unlawfully but you don’t want us to delete it.
• It not relevant any more, but you want us to keep it for use in legal claims.
• You have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data or ask us to delete it or restrict how we use it or, please contact us.

How to withdraw your consent

You can withdraw your consent at any time. Please contact us if you want to do so. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

Moving your information to another organisation

You have the right to request that we send a copy of the personal data we hold about you to another organisation for your own purposes, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information to another organisation please let us know. We will respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.

Automated decision making

We do not use your information for automated decision making.

Complaints about the use of your personal data

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated by writing to The Risk Manager, Paxport Group UK Ltd, The Landing, 2nd fl, Redcliff Street, Bristol, BS1 6HU or email [email protected].

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

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