This Policy regulates the collection and processing of personal data collected by iPay See d.o.o. Beograd- Čukarica, with the registered office in Belgrade, Beogradskog bataljona 4, Corporate ID No. 21150711 (hereinafter: iPay).
The Policy relates to all iPay service users, our application and website users, our associates, business partners, representatives, distributors, clients, suppliers and the iPay job candidates.
It also provides contact information in order to obtain additional information on our privacy protection procedures and how to exercise your rights.
We can collect data in various ways, for example via our websites, applications and social networks; in our events; by telephone, e-mail and fax; through job applications; in person; or through our interactions with clients and suppliers.
We can collect a choice of personal data, depending on the nature of relationship, including, but not limited to:
All information you provide to iPay must be accurate and true.
If you are required to provide details of the recipient’s e-mail address or other means of identification, make sure to enter correct data on the money recipient. We shall not be liable for any errors made in entering the recipient’s identification data.
When you provide personal data of any person (other than yourself) using our services, you claim that you have obtained that person’s consent to enter his/her personal data, and to have such data collected, used and disclosed for purposes set forth herein.
PURPOSE OF DATA COLLECTION
iPay collects and uses data in accordance with the applicable regulations, in order to:
All data processing shall be carried out in accordance with the applicable regulations, and upon consent given either explicitly or implicitly (through concludent action) by the data subject, in order to ensure compliance with any legal and contractual requirements, or any requirements of entry into, and performance of agreements (for example, processing your personal data in order to enable a payment transaction you initiate), which is essential for iPay legitimate interests.
We can also use information in other ways of which we specifically inform you on or before the data collection date.
iPay may process personal data for specific lawful business purposes, including some of the following:
• to improve, modify, personalize or otherwise improve our services to the benefit of our clients and associates;
• to identify and prevent fraud and violation of regulations, particularly those on money laundering and terrorism financing;
• to improve safety of our network and information systems;
• to better understand individual interactions with our websites;
• for direct marketing purposes;
• to communicate what we think might be of interest to you;
• to determine effectiveness of promotional campaigns and advertisements.
Please keep in mind that, if you exercise your right to object, this may affect our ability to carry out and provide services to your benefit, including a possibility that we may not be able to provide you a service at all (for example, to carry out a transaction or to issue a requested payment instrument).
How we process and protect personal data
The collected data is processed automatically and for a certain period of time, in order to ensure that personal data are not kept longer than necessary.
We implement administrative, technical and physical protection measures designed to protect personal data you provide against accidental, unlawul or unauthorized destruction, loss, modification, access, disclosure or use.
In order to ensure adequate safety and confidentiality of personal data, we have implemented the following safety measures:
• Encoding data in transit;
• Intense authentication;
• Reinforced network infrastructure;
• Network monitoring solutions;
How long we keep the collected data
In our systems we keep personal data collected in a manner which allows for identification of a data subject for no longer than is necessary for purposes for which such data is collected or further processed.
We determine this period of time by taking into account:
We do not publish the personal data collected on you, except as set forth herein or in special notices-policies provided in respect of certain activities.
We may forward personal data to the payment transaction participants.
We do not authorize the participants to use or publish information, unless that is necessary in order to provide services on our behalf and in accordance with regulations.
Additionally, we may disclose your personal data if we are required to do so by law or any government authority in accordance with their statutory requirements, or when be believe that such disclosure is necessary or proper in order to prevent a physical damage or financial loss, or in connection with investigation of any suspected or actual fraudulent or unlawful activity.
We also reserve the right to transfer your personal data in the event of disposal of our business or assets, or any part thereof.
The countries to which we may transfer you personal data may be:
• Within the European Union
• Outside the European Union
Your rights as a data subject
Where provided for by law, a subject data may exercise the following special rights:
Where data processing is based on consent, the subject data may at any time withdraw his/her consent.
We shall inform you of any significant changes by posting a notice on our websites and applications, indicating the last update date thereof.
By accepting this Policy and using iPay services, you acknowledge that you are aware of this Policy and that you give us your permission for access, process and keep any information you provide in the manner set forth herein.