Table of Contents
PAYSWELL UK AND EU PRIVACY POLICY
This Privacy Policy was last updated on: 18/4/2024
Introduction
This Privacy Policy is for residents and persons located in the United Kingdom and the European Union. For visitors located in the United States or Canada, please visit the version of our Privacy Policy located here. Payswell, LLC, a Delaware limited liability company, and its Affiliates (defined below) (individually and collectively, “Payswell” “we”, “our”, or “us“) owns and operates the website www.payswell.co.uk and others that may be added (individually and collectively, the “Payswell Site“). For the purposes of the U.K. Data Protection Act 1998 and the EU General Data Privacy Regulation (GDPR), we are the data controller. This Payswell UK and EU Privacy Policy (“Privacy Policy”) applies to the Payswell Site and to all of the features, websites, mobile applications, Internet browser extensions, emails, online services and other functionalities available through or related to the Payswell Site, whether accessed through a computer, mobile device, or other devices you use (each a “Device” and collectively, “Devices”) or otherwise (individually and collectively, the “Payswell Site and Features”). This Privacy Policy may also apply to future websites, mobile apps, and interactive services operated by Payswell. By using the Payswell Site and Features, you consent to the collection and use of information in accordance with this Privacy Policy. We reserve the right to change this Privacy Policy from time to time by changing it on the Payswell Site.Information We May Collect from You or about You
- Personal Data
“Personal Data” refers to any information relating to you. We may collect and process the following Personal Data about you:- information (name, email address, phone number, social media account information, birthdate, postal code, and/or physical address) that you provide by registering as a user of the Payswell Site or otherwise completing a user profile through the Payswell Site and Features;
- information you upload or submit in relation to advertising, content, surveys, location-based deals, special offers, promotions, and other rewards opportunities (individually and collectively, “Offers”);
- information in connection with an account sign-in facility, your log-in, and password details;
- details of any transactions made by you through the Payswell Site and Features;
- communications you send to us regarding the Payswell Site and Features; or
- information from surveys that we may present on the Payswell Site and Features for research purposes, whether for ourselves or for third-party research companies.
- We also collect, and may create from Personal Data, information about you that is not Personal Data (“Non-PI”). If we combine Personal Data collected through the Payswell Site and Features with other of your Personal Data or with Non-PI, that combined data will be treated as Personal Data subject to this Privacy Policy.
- You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with some or all services available on or through the Payswell Site and Features. When you visit or use the Payswell Site, we may, by means of cookies and/or other similar technologies, automatically collect additional information about you, such as the type of internet browser or mobile Device you use, any website from which you have come to the Payswell Site, your IP address (the unique address which identifies your Device on the internet), and/or the operating system of your Device. See Cookies and Other Technologies for more information. We may, from time to time, run referral programmes or similar initiatives that invite you to provide us with the contact details of someone who you know and who may find our products or services to be of interest. We will only use those contact details for the purpose of the relevant initiative (and not for other general marketing purposes). By providing us with their details, you confirm that you have their permission to do so and must not provide us with the details of anyone from whom you do not have such permission. We reserve the right to identify you as the person who has made the referral in any messages that are sent to them. You may also choose to install and use optional Internet browser extensions, add-ons, or similar plug-in software and technologies (each an “Extension” and collectively, “Extensions”) which may collect and use your information in a variety of ways. For example, we may offer Extensions that allow you to shop directly with our merchant partners and qualify for rewards. If you install an Extension, we will automatically track certain websites you visit to allow us to provide these features and to correlate your browser history, merchant visits, and Payswell Site and Features engagements to provide a better Payswell Site interaction and/or Offers to you. In addition, cookies and other technologies may be placed on your Devices when you install and use Extensions or when you click on an Affiliate or link within a shopping-rewards feature. See Cookies and Other Technologies below for more information. Your browsing activity on our merchant partners’ websites and other websites you visit may be tracked by cookies, Extensions, or other Payswell Sites and Features having such tracking capabilities.
How We Collect Your Personal Data, Why We Collect it, and How We Use it.
- Location Data
We may collect information through the Payswell Site and Features as to your real time geo-location to provide location services where requested or agreed to by you in order to deliver content, advertising, or other services that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your Device to enable us to recognise your mobile browser or Device when you return to the Payswell Site and Features. We may share your location information with our advertisers, merchant, and survey partners or others to provide you with advertising, content, surveys, and Offers, or for other marketing, administrative, and general business purposes such as attribution, analytics, and research. You may opt out at any time from allowing further access by us to your location data by adjusting the settings on your mobile Device or by following the instructions available on our Payswell Sites and Features. You can also stop all location data collection by un-installing the mobile app and using the standard un-install processes for your mobile Device. - Cookies and Other Technologies
When you visit the Payswell Site, a web server sends a cookie or other similar technology to your Device. Cookies are small pieces of information which are issued to your Device when you visit a website or access or use a mobile application and which store and sometimes track information. Some cookies we use may last only for the duration of your web or application session and expire when you close your browser or exit the Payswell Site. Other cookies are used to remember you when you return to the Payswell Site and will last for longer. The cookies and/or other similar technologies (collectively, “Tracking Technologies”) we use to collect a variety of relevant information, such as the type of internet browser or mobile Device you use, any website from which you have come to the Payswell Site, your IP address, and/or the operating system of your Device. We use cookies and/or other similar technologies either alone or in combination with each other to create a unique device ID and to:- remember that you have visited us before so that we can identify the number of unique visitors we receive and to allow us to make sure we have enough capacity for the number of users that we get;
- customise elements of the promotional layout and/or content of the pages of the Payswell Site;
- collect anonymous statistical information about how you use the Payswell Site and Features (including how long you spend on the Payswell Site) and from where you have come to the Payswell Site, so that we can improve the Payswell Site and learn which parts of the Payswell Site are most popular with users; and
- gather information about the pages on the Payswell Site and Features, and other information about other websites that you visit, so as to place you in a “market segment”, which is collected by reference to the IP address that you are using and/or your unique user ID, and includes information about the county and city you are in, together with the name of your internet service provider and which is then used to place interest-based advertisements and content on the Payswell Site that is believed will be relevant to your market segment – for more information about this type of interest-based advertising, and about how to turn this feature off please visit http://www.youronlinechoices.com/uk/.
- What Are My Cookies Choices?
You can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile Devices may offer ad and data limitation choices. Please note that when you use cookie control tools, you will have to change your settings for each browser and Device you use, and your limitation on cookies can limit the functionality of online services you use, including the Payswell Site and Features. Use the help function on your browser or click on the applicable links below to learn more: If you’d like to opt-out of being tracked by Google Analytics, simply install this add-on to your browser: https://tools.google.com/dlpage/gaoptout. We are not responsible for the completeness, accuracy, or effectiveness of any third-party cookie-choice programs or tools. If you exercise these choice controls, they may need to be compiled on each browser and Device you use, and, if they use a cookie to signal your opt-out, your choice may no longer be recognizable if you later clear or block cookies. - Uses Made of Your Information
We use your Personal Data that we collect to:- enable us to provide you with the information offered through the Payswell Site and Features and which you request;
- administer your account with us;
- audit the downloading of the Payswell Site and Features, as well as data from the Payswell Site and Features;
- improve the layout and/or content of the pages of the Payswell Site and Features and customise them for users;
- identify visitors to the Payswell Site;
- carry out research on our users’ demographics and behaviour;
- send you information we think you may find useful or which you have requested from us, including information about the Payswell Site and Features or the products and services of our service providers, vendors, advertisers, merchants, survey partners, joint business ventures, and other trusted third parties (collectively, “Trusted Third Parties”), provided you have indicated that you do not object to being contacted for these purposes;
- allow, with your consent, Trusted Third Parties to send you information directly which you may find useful regarding their products and services.
- Information Sharing
We may disclose aggregate statistics about users of the Payswell Site to describe our business and the Payswell Site and Features to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include only Non-PI. We may disclose your Personal Data to any of our parent companies, subsidiaries, sister companies, trusted agents, and affiliated services that we own and/or operate (“Affiliates”) subject to the terms of this Privacy Policy, or to our agents or contractors who assist us in providing the Payswell Site and Features, processing transactions, to view order references and/or order fulfillment requests and information, receiving and sending communications, updating marketing lists, analysing data, providing IT and other support services, or in other tasks, subject to the terms of this Privacy Policy. In the event that we undergo re-organisation or are sold to a third party, you agree that any Personal Data we hold about you may be transferred to that re-organised entity or third party. We may disclose your Personal Data if required to do so by law or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Payswell Site and Features or the rights, property, or personal safety of any person. - Community Features and User Content
The Payswell Site and Features may provide you the opportunity to participate in and/or post text (e.g., questions, comments, and suggestions), images, audio, videos, or other content (collectively, “User Content”) publicly through blogs, chat rooms, message boards, news groups, public forums, interactive features, public-facing member profile, third-party social networking services, or other communication functionality (“Community Features”). Certain information, such as your username, Payswell Site start date, earning preferences, qualified rewards, profile picture, and other profile information may be publicly displayed on the Payswell Site and Features along with User Content. User Content may also contain metadata, which may contain information relating to you, that we may also collect, share, and use. Anything posted through Community Features is publicly available. This means that others will have access to that User Content and may use it or share it with third parties; this is beyond our control. If you choose to voluntarily disclose Personal Information in the User Content and/or on the Community Features, that information will be considered publicly available information as well. The protections of this Privacy Policy will not apply to publicly available information. In addition, by posting through our Community Features, you are agreeing that we may use your User Content (and excerpts from your User Content) in connection with our Data Purposes. - Third-Party Services
The Payswell Site and Features contain links to, or otherwise enable the opportunity to interact with other websites and other services provided by Trusted Third Parties that we do not own, operate, or control (“Third-Party Services”). In addition, because aspects of the Payswell Site and Features include third-party Offers, Third-Party Services may collect your information based on your interaction with those Offers, including through Tracking Technologies. By interacting with Offers through the Payswell Site and Features, you authorize and direct us to share your Personal Information and Non-PI with Third-Party Services making Offers and for them to share Offer-related activity data and other information with us. This helps us and them make and fulfill Offers, including facilitating your communications or transactions with them, authenticating and/or validating your identification, crediting you with any qualified rewards, and for our other Data Purposes. Except as legally required for our service providers, the privacy and other practices of Third-Party Services are not covered by this Privacy Policy, and we are not responsible for their privacy or other practices. We encourage you to be aware of and to read the privacy statements, terms of service, and similar disclosures and conditions of Third-Party Services that collect Personal Information or other data before visiting or otherwise interacting with those services. - Advertising Networks
Companies that host networks connecting advertisers with delivery platforms for digital advertising (individually and collectively, “Ad Networks”), which are Third-Party Services, may provide advertising based on your interests, as reflected in your use of the Payswell Site and Features, as well as your use of other websites and services. Some of these Ad Networks may place persistent cookies or other Tracking Technologies on your Devices, allowing them to recognize you and/or your Device each time they send you an online advertisement. Ads themselves may also include Tracking Technologies. Ad Networks may compile information about where you see advertisements online and determine which ads you click on. We are not the data controller for the cookies or other Tracking Technologies that may be placed by these third parties on your Devices, nor do we have responsibility for these third parties’ privacy policies or information collection practices. You may limit or remove such cookies and Tracking Technologies through your Device settings; for more information, visit section 2 (What Are My Cookie Choices?) above. - Session Replay and Analytics Companies
We use certain third-party analytics to help us understand how you use the Payswell Site and Features, and these companies may set their own cookies and other Tracking Technologies on your Devices. For example, we may use third-party services to record and review your interactions with the Payswell Site and Features, including mouse movements, clicks, page visits, keystrokes/key touches, and other details, including any Personal Information that you provide. These “session replay” services help us organize and analyze your interaction data for our Data Purposes. By using any of the Payswell Site and Features, you expressly consent to the recording and sharing of your Personal Information and other data with third-party “session replay” services and other analytics providers. We may also use Google Analytics and similar third-party analytics providers to track visitors’ activity on our website. Google Analytics and similar third-party analytics providers may also use web browsing data and other data analysis to improve their own products. For more information on how to limit this activity, including to learn about the opt-out mechanism Google offers, visit section 2 (What Are My Cookie Choices?) above. These and other Trusted Third Parties may collect information about you, including but not limited to your online activities over time and across different websites and services, when you use the Payswell Site and Features or other online websites and services. - International Transfers
We may transfer the Personal Data we collect about you to the United States, where we are headquartered, and by accepting this Privacy Policy you explicitly permit us to do so. We may also transfer Personal Data to countries for which adequacy decisions have been issued and/or use contractual protections and other mechanisms under applicable law for the transfer of Personal Data to third parties. - Social Media Features
Certain functionality on the Payswell Site and Features may permit interactions that you initiate between the Payswell Site and Features and third-party social media services (“Social Media Services”) such as Facebook and LinkedIn (“Social Media Features”). Enabling or interacting with Social Media Features may set one or more cookies or other technologies on your Devices. Please refer to the terms of use and privacy policies of such Social Media Services offering such Social Media Features. If you choose to use Social Media Features, information you post or provide access to may be shared with and publicly displayed on the Payswell Site and Features or on such Social Media Services. Similarly, if you post information on a Social Media Service that references any of the Payswell Site and Features, your post may be published on the Payswell Site and Features in accordance with the terms of the Social Media Services and our Term of Use. In addition, we may receive information about you if other users of a Social Media Service give us access to their profiles and you are one of their “friends” or “connections” or information about you is otherwise accessible through your friends’ or connections’ web pages, profile pages, groups you or they belong to, or similar pages on such Social Media Services. The information we collect in connection with Social Media Features is subject to this Privacy Policy. The information collected by any Social Media Service through its Social Media Features remains subject to its privacy practices, including whether it continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on such Social Media Service.
Child Safety
Protecting the safety of children when they use the Internet is important to us. The Payswell Site and Features are intended for use only by persons who are at least 18 years of age.Security
We place great importance on the security of all Personal Data associated with our users. We have security measures in place to attempt to protect against the loss, misuse, and alteration of Personal Data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to Personal Data. Whilst we cannot ensure or guarantee that loss, misuse, or alteration of information will never occur, we attempt to use all reasonable efforts to prevent it. You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit through the Payswell Site and Features whilst it is in transit over the internet and any such submission is at your own risk. It is advisable to close your browser when you have finished your user session to help ensure others do not access your Personal Data if you use a shared Device or a Device in a public place.Storage of Your Information
Information that you submit through the Payswell Site and Features is sent to and stored on secure servers located in the United Kingdom but may be transferred by us to our other offices and/or to third parties, who may be situated in the United States of America or elsewhere outside the UK and the EEA, and may be processed by staff operating outside the UK or the EEA (see Information Sharing). The US and other non-EEA countries do not have similar data protection laws to the UK and the EEA, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from the United Kingdom and Europe. Where we transfer your information, we will take all reasonable steps to ensure that your privacy rights continue to be protected consistent with our obligations under local law. By submitting information through the Payswell Site and Features, you agree to this storing, processing, and/or transfer.Your Rights
You have the following legal rights under the U.K. Data Protection Act 1998 and/or and the EU General Data Privacy Regulation (GDPR):- You have the right to access and a copy of all the Personal Data about you held by us. On request, we will provide you with a copy of this information.
- You have the right to correct any errors in your Personal Data and/or complete any incomplete information in your Personal Data .
- You have the right to delete your Personal Data, but, in that case, we may necessarily have to close your account and your participation in any of our Offers.
- You have the right to object to the processing of your Personal Data under circumstances.
- You have the right to withdraw your consent at any time when you have provided it to us to authorise processing of your Personal Data.
