Privacy Policy
Last Updated: 30 September 2024
1. Introduction
Welcome to the Paybank2bank (PB2B) Privacy Policy. This sets out how PB2B collects and processes data received from you. This is to be read in conjunction with our Client Terms of Use as together they govern your use of the PB2B Platform and any of the services accessible through our platform.
If you have any comments please email them to team@paybank2bank.io
2. Important Information and Who We are
Intense Technologies SRL, trading as Paybank2bank is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below
Contact Details
Our full details are:
● Full Name of Legal Entity: Intense Technologies SRL
● Title of Data Privacy Manager: Chief Operating Officer
● Email Address: team@paybank2bank.io
● Postal Address: Level 5, Calea Plevnei 53, Sector 1, Bucharest, Romania 030167
You have the right to make a complaint regarding our use of your personal data at any time to The National Supervisory Authority For Personal Data Processing, the Romanian regulator for data protection issues.
3. Changes to the privacy policy and your duty to inform us of changes
Our privacy policy is reviewed regularly.
This version was last updated on September 30, 2024. We reserve the right to make changes to it from time to time and any changes will be posted on our website. We may request that you read and accept any changes in order to continue your use the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
4. Third Party Links
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
5. Data We May Collect About You
We may collect, use, store and transfer different kinds of personal data about you as follows:
● Identity Data: first name, last name, username or similar identifier, title, date of birth, gender.
● Contact Data: billing address, delivery address, email address and telephone numbers.
● Financial Data: bank account details.
● Transaction Data: includes details about payments to and from you.
● Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
● Content Data: includes information stored on your Device, login information, profile photo, and company photo.
● Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
● Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
● Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
● Phone Contacts: if you grant us permission to access your contact list (when you enter the "Refer" and "Invite" pages), we may access this information to help send invites and track rewards.
Location Data: This includes your current location disclosed by GPS technology. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences
6. How we collect your personal data
Your personal data may be collected as follows:
● Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Site or by corresponding with us (for example, by email or chat).
● Information we collect about you and your device. Each time you visit one of Our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
● Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your phone settings.
● Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources such as analytics and search information providers such as Google as well as Identity and Contact Data from publicly available sources.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
7. How we use your data
We will only use your personal data in accordance with the law. Most commonly we will use your personal data in the following circumstances:
● Where you have provided your consent.
● Where we need to perform a contract we are about to enter or have entered with you.
● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
● Where we need to comply with a legal or regulatory obligation.
● When you contact us either by phone, email, via our 'contact us' page or via social media, we will usually collect your name, social media handle and contact details, because it’s in our legitimate interest to make sure we can properly respond to your query.
● When you use our website and consent to our use of cookies we will collect information about how you use our website. We use this information to improve our website and to better understand how people use it. More detail on the information we collect and how we do this is set out in our Cookie Policy below.
● If our business is sold. We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the buyer of our business may not be able to provide services to you.
8. Who do you share my data with?
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table:
● External Third Parties such as merchants in order to facilitate authorised payments and refunds via PB2B mobile apps and websites.
● Our PISP, PROVIDER Limited for account verification, AML and KYC purposes.
● Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
● We may disclose your personal data if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
● Please note that our chat support services are supported by third parties. Any data provided under the chat boxes will be shared with the third parties providing the support.
● We may share some data with the Merchant including details such as your bank name, amount paid, last three digits of your bank account.
● Business partners, for the performance of the contract we enter into with them or you.
● Merchants, in order to enable payments to be made to the merchants using our services, we share information that includes: payment amount, originator account details, payment reference, payment description, bank used.
● Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, prevent fraud or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
● Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer.
PB2B allows other users to see your business name when they receive a SMS payment link or scan a QR code associated with your business account. Customers may be able to view your Account Number and Sort Code but cannot debit funds or interfere with your account in any way.
9. Where do you store my data?
We store your data on third-party servers in Germany. Data may also be stored in the United Kingdom.
When working with third parties we may need to transfer your personal data outside of the UK and/or EU.
Whenever we transfer your personal information outside of the UK and the EU, we ensure it receives additional protection as required by law.
10. Data Security
All information you provide us is stored using secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
11. How long do you keep my data for?
We will only retain your personal information for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.
We delete your account information 6 months after your last application with us. Other information related to your account will be deleted 2 years after your account has become inactive.
12. Your Legal Rights
Data protection laws provide you with certain rights in respect to your personal data. As such, under certain circumstances you may:
● Request access to your personal data.
● Request correction of your personal data.
● Object to processing of your personal data.
● Request restriction of processing your personal data.
● Request transfer or your personal data.
● Right to withdraw consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at team@paybank2bank.io
13. Automated Decision-Making and Profiling
We may from time to time use your personal data for the purpose of automated decision-making. In the event that any such decision has a significant legal effect on you, you have the right to challenge any such decision under GDPR, requesting human intervention and obtaining an explanation of the decision from us.
Automated decisions allow us to determine whether a transaction is to be allowed or not. Any such decision is based on thorough checks carried out with the use of our transaction monitoring service which monitors suspicious transactions based on a range of factors including:
● the age of merchant,
● size of transaction,
● time of day,
● type of transaction - customer present or not present.
Depending upon the results of the checks carried out, this could result in us automatically declining a transaction. The right to object to automatic processing of your personal data does not apply in the following circumstances:
● the decision is necessary for the entry into, or performance of, a contract between the you and us;
● the decision is authorised by law; or
● you have given you explicit consent