This privacy explains what we do with personal information when people visit our website, make contact with us or use our services. The policy is intended to be layered, giving as much information as maybe required to allow readers to easily find what they are looking for. Clicking the various links will help navigate around the policy. Part 1 of the policy are intended for everyone, with more specific information being provided in Parts 2 to 4 in respect of each differing activity. Whilst we encourage you read the entire policy, we realise you may prefer to read only that which concerns you most.
Part 2 – Contacting us with a general enquiry.
Part 3 – Contacting us as part of an application to engage in a contract with us.
Part 4 – Ongoing client account(s) management
In each part, we will provide specify information to explain:
Who we are
PAYVER is the data controller for the personal information we process (unless stated otherwise). We may be contacted by phone, email or surface mail using the following contact details:
Payver Limited New Court
Abbey Road North, Shepley Huddersfield
United Kingdom HD8 8BJ
Email to: support@payver.io
Phone: +44 (0) 20 3476 9011
What is a Data Controller, Data Processor, Data Subject and Personal Information?
A Date Controlleris an organisation that decides how and why to use the personal information ofother people. To use personal information is to ‘process’ that personal information.
A Data Processor is an organisation that ‘processes’ personal information with a contractual obligation to a Data Controller to do so. A Data Processor does not have authority to decide how or why to use the personal information it has access to under such a contract.
A Data Subject is the living person that can be identified by the personal information.
Personal information is any information that can be used to identify a living person. For example names, email addresses, financial information, unique reference numbers and website usage. Exactly what may or may not be considered personal information may differ greatly from case to case.
How do we get Personal Information?
Most of the personal information we will process is provided to us directly by the data subject for one of the following reasons:
We also receive personal information indirectly, in the following scenarios:
Data Protection Rights
Under data protection law, users of our website and services have rights including:
Right to be informed – confirmation if we are or are not processing your personal information
Right of access – to ask for copies of your personal information
Right to rectification – to ask usto rectify personal information you consider may be inaccurate. This includes asking us to complete information you think is incomplete.
Right to be forgotten – to ask us to erase your personal information in certain circumstances.
Right to restriction of processing – to ask us to restrict the processing of your personal information in certain circumstances.
Right to object – to object to the processing of your personal information in certain circumstances.
Right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
We will not charge a fee to exercise any of these rights and we will aim to fulfil any requests within one calendar month.
To exercise any of these rights, please contact us using the contact details provided at Who we are.
Your right to complain
If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details provided at Who we are.
If you are unhappy with our response, or how we have used your data, you can also complain to the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights. The ICO’s address:
Information Commissioner’s Office
Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Sharing your information
We will not share your information with any third parties for the purposes of direct marketing.
We use data processors who are third parties who provide services to and for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have contractually engaged them to do so. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
In some circumstances we are legally obliged to share information. For example under a court order or where we are required to cooperate with an appropriate supervisory or regulatory authority. In any scenario, we will only share such information that we and our legal advisors are satisfied we have a legal requirement to do so. In such circumstances, the receiving organisation will be considered a Controller in their own right.
Links to other websites
Our website may contain links to other websites of interest. Where we provide links to websites of other organisations, this privacy notice does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.
Regular review and updating of this privacy policy
We keep our privacy notice under regularreview to make sure it is up to date and accurate. Version 0.1 of this policy came into initial effect from 21st of September 2020.
This latest version, Version 2.0 came into effect from 13 April 2021.
PAYVER may change this policy from time to time by updating this page. Any revised Privacy Policy will be effective as of the publishing date. If changes are significant, we will notify existing clients and those that have provided us with valid email addresses. We encourage you check this policy from time to time.
Children’s personal information
We do not provide services directly to children or proactively collect their personal information.
Visitors to our website
When you visit our website, payver.eu or payver.co.uk we use a third-party service, provided by Google Analytics, to collectstandard internet log information, generating a unique ID that is used to provide statistical data on how the visitor uses the website. This information is only processed in a way that does not directly identify anyone.
We do not make, nor do we authorise Google to make, any attempts to identify visitors to our website.
Security and performance
We use a third-party web application firewall from Amazon Web Services (AWS) to help maintain the security and performance of our website. The service checks that traffic to the site is behaving as would be expected. The service will block traffic that is not using the site as expected or that which appears to originate from an IP address in a country which is not approved to engage our services.
To provide this service, the system processes site visitors’ IP addresses. We host our website in AWS in the EEA and keep traffic information for 12 months.
Purpose and lawful basis for website cookies, security and performance processing
The purpose for the use of website cookies, security and performance processing is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users. The lawful basis we rely on in this case is Article 6(1)(f) which allows us to process personal data when it’s necessary for our legitimate interests. For example in order to maintain the integrity of our IT systems and improve our website.
What purpose we are processing it for (what we will use it for)
Should you contact us with a general enquiry, we will use the information you provide to respond to your enquiry.
Why we are permitted to process your information (the lawful basis)
The lawful basis we rely on in this case is consent under article 6(1)(a) of the GDPR. Our record of consent is the overt act you made when you chose to contact us and provide your contact details. Your consent may be withdrawn at any time by contacting us using the contact details provided at Who we are.
Do you have to provide it to us (if it is optional or a condition of service)
It is optional, but if you do not provide us with a means to respond to you, your enquiry cannot be fulfilled.
How long do we store it for (retention schedule)
We intend to store records of communicationsfor no longerthan 7 years. This may be extended if the enquiry proceeds to form pre contract communications. If the enquiry goes on to that stage, refer to application to engage in a contract or ongoing client account management for further information.
Will we share it with others (other Controllers or Data Processors)
Generally, we will not share it with another Controller. We will share it with our data processor that conducts marketing and sales activities on our behalf.
Will we transfer it to another country
We will share it with our data processor that conduct marketing activities on our behalf, our data processor is based in the EEA, with a small number ofsales representatives based outside the EEA.
For those representatives based outside the EEA, we have in place specific contracts approved by the European Commission which give personal data the same protection it has in Europe. If you are a client or prospective client, we will provide you with a copy of the clauses of these contracts upon request. To request a copy, please contact us using the contact details provided at Who we are and we will provide a copy by email.
Will we employ automated decision-making or profiling techniques
Yes, our systems use artificial intelligence to identify unintelligible email addresses. If your email address is input incorrectly, our systems will discard the enquiry. If you have not had a response within a few days, please consider contacting us via another method.
Are there any restrictions to your data protection rights
None that are anticipated.
What purpose we are processing it for (what we will use it for)
Should you make an application to engage in a contract with us, we will use the information you provide to establish if we may engage in a contract with you. This will involve some research with industry standard credit reference agencies or fraud prevention agencies and adding to the information you have provided to verify your identity and suitability.
Why we are permitted to process your information (the lawful basis)
The lawful basis we rely on in this case are:
Do you have to provide it to us (if it is optional or a condition of service)
It is a condition ofservice that you provide the details we request for you to engage in a contract with us.
If you fail or refuse to provide the requested information, or the results of our research are unsatisfactory, you may be asked to provide further information or your application may be declined.
How long do we store it for (retention schedule)
We intend to store records of applications for 6 years from the end of the year in which the application was made.
This period will be extended if the application is successful, refer to ongoing client account management for further information.
Will we share it with others (other Controllers or Data Processors)
Generally, we will not share it with another Controller. In some circumstances we are legally obliged to share information. For example under a court order or where we are required to cooperate with an appropriate supervisory or regulatory authority. In any scenario, we will only share such information that we and our legal advisors are satisfied we have a legal requirement to do so. In such circumstances, the receiving organisation will be considered a Controller in their own right.
We willshare it with our data processorthat conducts Know your Customer (KYC), Counter Terrorist Financing (CTF) and Anti Money Laundering (AML) screening on our behalf.
Will we transfer it to another country
We will share it with our data processor that conduct marketing activities on our behalf, our data processor is based in the EEA, with a small number ofsales representatives based outside the EEA.
For those representatives based outside the EEA, we have in place specific contracts approved by the European Commission which give personal data the same protection it has in Europe. If you are a client or prospective client, we will provide you with a copy of the clauses of these contracts upon request. To request a copy, please contact us using the contact details provided at Who we are and we will provide a copy by email.
We will share it with our data processor that conduct KYC, CTF & AML screening on our behalf, our data processor is based in the EEA. The results of the KYC, CTF & AML screening will not be transferred outside of the EEA by us or our data processor.
Will we employ automated decision-making or profiling techniques
No, all applications are subject to human decision making.
Are there any restrictions to your data protection rights
Yes, in some circumstances, if you request us to rectify, delete or restrict the information which we must maintain in order to follow our legal obligations such as fraud prevention, anti-money laundering or counter terrorism financing we may be required to decline your request and keep that information in line with our normal retention periods.
Should you become a client, you will be required to enter into a signed contract, which may include separate Terms and Conditions, General Terms and Conditions, Client Agreements or other such contractual agreements. The terms of which should be read in conjunction with this policy. This policy is intended to be an overview of our approach to privacy and does not supersede or invalidate the terms of any such signed agreements.
What purpose we are processing it for (what we will use it for)
Should you be successfully onboarded and have an active client account with us, we will use the information you provide to manage, maintain, monitor and provide you with the agreed service. This will include business as usual activitiessuch as compliance monitoring, billing and customer relationship management.
In addition, in order to follow our legal obligations such as fraud prevention, anti-money laundering or counter terrorism financing we are required to conduct periodic reviews to re-verify your identity and suitability remain extant.
Why we are permitted to process your information (the lawful basis)
The lawful basis we rely on in this case are:
Do you have to provide it to us (if it is optional or a condition of service)
It is a condition ofservice that you continue to provide the details we request for you to continue engage in a contract with us.
If you fail or refuse to provide the requested information, or the results of our periodic reviews are unsatisfactory, you may be asked to provide further information or your Client Agreement may be subject to immediate termination.
How long do we store it for (retention schedule)
We intend to store records of client accounts for 6 years from the end of the year in which the final transaction is made or your relationship with us is terminated, whichever occurs last.
Will we share it with others (other Controllers or Data Processors)
Generally, we will notshare it with another Controller. In some circumstances we are legally obliged to share information. For example under a court order or where we are required to cooperate with an appropriate supervisory or regulatory authority. In any scenario, we will only share such information that we and our legal advisors are satisfied we have a legal requirement to do so. In such circumstances, the receiving organisation will be considered a Controller in their own right.
We will share it with our data processor that conducts Know your Customer (KYC), Counter Terrorist Financing (CTF) and Anti Money Laundering (AML) screening on our behalf.
Will we transfer it to another country
We will share it with our data processor that conducts Know your Customer (KYC), Counter Terrorist Financing (CTF) and Anti Money Laundering (AML) screening on our behalf, our data processor is based in the EEA.
Will we employ automated decision-making or profiling techniques
Yes, our systems use artificial intelligence to screen transactions according to a series of risk settings and rules, which are intended to flag identified transactions as potentially fraudulent. Any such automated flags will be reviewed by a human.
Are there any restrictions to your data protection rights
Yes, in some circumstances, if you request us to rectify, delete or restrict the information which we must maintain in order to follow our legal obligations such as fraud prevention, anti-money laundering or counter terrorism financing we may be required to decline your request and keep that information in line with our normal retention periods.
This cookie notice is for visitors to our websites, apps and other digital platforms. It sets out how we use cookies. In this notice ‘we’ ‘us’ and ‘our’ means PAYVER Limited, whereas ‘you’ ‘your’ ‘user(s)’ refers to you.
What are Cookies?
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.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you.
Which Cookies do we use?
We use ‘strictly necessary’ cookies
Strictly necessary cookies are essential to navigate around a website and use its features. Without them, you wouldn’t be able to use basic services which are offered by our webpage. These cookies do not gather information about you that could be used for marketing or remembering where you’ve been on the internet.
Examples of how we use ‘strictly necessary’ cookies include:
We use ‘Google Analytics’ cookies
Google Analytics cookies help us to measure how you interact with website content by helping to distinguish unique users and throttle the request rate.
More detailed Cookie information:
Choice cookie – this cookie saves your choice regarding cookies on PAYVER webpage. All of our visitors will get a “PAYVER_session” cookie set on your browser. This cookie is installed
automatically and is necessary for the performance of website and as such cannot be declined.
Cross-Site Request Forgery Protection cookie – this cookie protects your computer from forgery. With XSRF protection, all of our visitors will get a “XSRF-TOKEN” cookie set on your browser, and all POST requests must be accompanied by a POST parameter with a matching name and value. If they aren’t, website will reject the request. This cookie is installed automatically and is necessary for the performance of website and as such cannot be declined.
gtag.js and analytics.js – cookie usage
The analytics.js JavaScript library is part of Universal Analytics and uses first-party cookies to:
gtag.js and analytics.js set the following cookies:
| Cookie name | Expiration time | Description |
| _ga | 2 years | Used to distinguish users. |
| _gid | 24 hours | Used to distinguish users. |
| _gat | 1 minute | Used to throttle request rate. |
Your consent to Cookies
You can change your consent to the use of cookies at any time by clicking ’Delete and Revoke’. If you choose not to accept our Cookies, please note that your experience can be not as fulfilling as it should be. PAYVER only uses cookies which are improving user experience, and which are strictly necessary for your successful usage of our webpage.
We use cookies on our site to provide you with the most relevant experience by remembering your preferences and repeat visits. By clicking “Accept” you consent to the use of ALL cookies.
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