What Information We May Collect About You
When you use our Sites and/or Services we may collect information about you, including the following:
- When you register for a pinPay account
- Use a pinPay (Payen) account,
- Pass details to Payen via our Sites
- Pass details through other communication channels
The information we gather may include:
Personal Information: name, address, date of birth, phone number and email address. Payment Transacting Information: relevant credit/debit card information and/or bank account information that you provide for payment transactions.
Security Information: to safeguard your personal information we will also require you to set the answers to different security questions. This required information is necessary for us to process transactions, issue a new password/pin if you forget or lose your existing password/pin, protect you against credit/debit card fraud and bank account fraud , and contact you should the need arise in administering your Payen account or the Payen Services you have used.
Identification Information: If we cannot verify the information that you provide, we may ask you to upload or send us additional verified information by fax or post (such as your driving licence, credit card statement, and/or a recent utility bill, or other information linking you to the applicable address), or to answer additional questions online to help verify your information. We will also require other identification information if you send or receive certain high-value transactions or high overall payment volumes through the Payen Services or as is otherwise required in order for us to comply with our anti-money laundering obligations under European law.
Non Personalised Information: when you access Payen Service we may collect and store device identification data and geolocation data, this is data in a form that does not permit direct association with any specific individual. This data is used to ensure it is you accessing our service and helps provide more secure transaction processing to prevent fraud. We may also collect information on which pages of our website you visit, IP addresses, the type of browser you use and the times you access our website. We use this information to try to understand our customers’ preferences better and to manage the load on our servers enabling us to improve our services and your experience with Payen. If we do combine non- personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.
Correspondence Information: if you send us correspondence, including emails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Payen to you. We retain these records in order to keep records of our relationship, to measure and improve our customer service and to investigate potential fraud.
In order to fulfill our legal obligations to prevent fraud and money laundering, we may obtain information about you from third party agencies, including your financial history, county court judgments and bankruptcies, from credit reference and fraud prevention agencies when you open a pinPay (Payen) Account and at any time when we feel it is necessary to prevent fraud and minimise our financial risks. Please refer to our Money Laundering Policy for further details.
In accordance with law, we shall however delete personal information about you when it is no longer necessary for us to retain it. We only collect necessary personal and non-personal information from you to:
- Establish your identity when you open an account
- Ensure we provide you a safe and secure online payment service
- Check it is you accessing your account
- Avoid the possibility of money laundering.
How We Collect Personal Data
Payen will collect this information from the internet when you use our website, sign up for a pinPay account, activate a pinPay account and use your existing account. This also applies when you make purchases using the pinPay service through corresponding online businesses that support pinPay.
From Third Parties
In order to complete your payments from other businesses using pinPay, Payen will be passed important personal data as described in “What We Collect About You”, by the online business you were buying services from. This information will allow us to save you from re- entering information (such as name, email address, personal addresses, telephone numbers, date of birth etc) if you have already entered this information on the online business you were transacting with. Please note that third parties you buy from and contract with may have their own privacy policies and Payen is not responsible for their operations, including but not limited to the way they handle your personal information.
Additionally, in order to protect all our customers against potential fraud, we verify the information you provide with the “Payment Processors” and/or “Credit Reference/Fraud Agencies”. In the course of such verification, we receive personally identifiable information about you from such services. To be specific, if you register a credit card or debit card or bank account with Payen, we will use card authorisation and fraud screening services to verify that your bank or card information and address match the information that you have supplied to Payen and that the card has not been reported as lost or stolen.
We collect data when:
- You use our website or the pinPay service
- You purchase goods using pinPay on an approved merchant website
- We perform checks with fraud/identity agencies
How We Use Your Personal Data
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customised experience. You agree that we may use your personal information to:
- Administer your pinPay account
- Provide the pinPay services and customer support you request
- Resolve disputes
- Troubleshoot problems
- Enable third party merchants to accept or facilitate payments from you using the Payen Services
- Carry out your instructions to make and receive payments and undertake transactions using our services, including verifying that you have sufficient funds in your nominated bank account to make such payments
- Notify you about changes to our service(s)
- Improve our internal customer training
- Comply with financial services regulations including retention of financial information and Transactions
- Carry out financial and identity checks, fraud prevention checks, anti-money laundering and credit checks
- Enable good customer service, including answering questions and responding to feedback and complaints
- Enhance the security of our services
- Ensure that content on our Website is presented in the most effective manner for you and for your computer
- Provide you with information, products or services that you request from us or which we feel may interest you
- Inform you about our new services and developments
- Customise, measure, and improve our services and the content and layout of our website
- Compare information for accuracy, and verify it with third parties
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
We are by law required to retain certain records for a period of at least five years after closure of your pinPay (Payen) account which will include your personal data such as your name, contact details, customer number and transaction history etc. We will delete and destroy all other personal data that we hold about you when you (or we) terminate your pinPay (Payen) Account. If you wish to cancel your account or request that we no longer use your personal information to provide you services contact us by email: firstname.lastname@example.org or telephone 0345 450 6107 between 09:00-17:00 Monday-Friday excluding UK Public Holidays.
We do not sell your data to those annoying marketing companies.
We use your data to make sure we know who you are and that your account with Payen is safe and secure from others.
We hold your data for 5 years as we are required by law to do so.
Protection Of Your Information
Payen takes precautions – including administrative, organisational, technical and physical measures — to safeguard your personal information we collect and store against accidental loss, theft and misuse, as well as against unauthorised access, disclosure, alteration, destruction and damage.
Payen online services such as pinPay use Secure Sockets Layer (SSL) encryption on all web pages where personal information is collected. To make purchases from these services you must use an SSL-enabled browser such as Safari, Firefox or Internet Explorer. Doing so protects the confidentiality of your personal information while it’s transmitted over the Internet.
Where is it Stored?
The data that we collect from you is stored, secured and processed within Data Centres within the European Economic Area (“EEA”).
The countries that comprise the EEA are all countries of the European Union together with Iceland, Liechtenstein and Norway.
However, on some occasions your personal information be transferred to, and stored at destinations outside the European Economic Area (“EEA”) for the reasons set out below:
- The transfer is necessary for providing you with the services you request, i.e. if you transfer funds to a merchant that is not located in the EEA it will be necessary to send your details to that merchant
- Or when our anti-fraud agencies, credit reference agencies and other service providers are based outside the EEA and require access to your data to perform their obligations to us and provide services to you
However, this high level of protection can only be effective if you follow certain security practices yourself. The security of your pinPay account relies on your pin. You must never share your pinPay (Payen) Account, pin, authorised devices or login details with anyone. Payen representatives will never ask you for your pin or password, so any email or other communication requesting your pin or password should be treated as unauthorized and suspicious and forwarded to email@example.com. If you do share your Payen pin or password with a third party for any reason, such as that the third party has promised to provide you additional services, the third party will have access to your account and your personal information and you may be responsible for the action taken using your pin or password.
If you are concerned that any of your login details have been compromised you can change them any time once you are logged on, but you should always also immediately contact Customer Services and tell us why you think your login details have been compromised. Details of how to contact Customer Services are available from the “Contact” section of the Website.
If or when you post on social networking services connected with Payen, please remember that the personal information you share is visible to other users and can be read, collected or used by them. You are responsible for the personal information you choose to submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features. To request removal of information from our community forum or chat rooms, contact us by at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Certification: Secure Payment Transactions and Personal Information:
Payen is audited annually and meets the requirement for the highest level of PCI-DSS (Payment Card Industry – Data Security Standards) compliance and registered with Visa and MasterCard as an approved technical provider who is safe and secure for the management of payment card data online and via call centers.
As a PCI:DSS Level 1 Service Provider, Payen, can be located on the approved Visa Merchant Agent List We have a very secure system running within the EEA which is where your data is kept. However, you have to be careful with your own data. We are regulated by both Visa and MasterCard for payment data security.
Access To Your Information
Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with applicable law.
You may review and amend your Personal Data by logging into your pinPay (Payen) Account. If you require assistance or information relating to this contact us.
If you do not have a pinPay (Payen) Account or if you have questions about your Account information or other Personal Data, please contact us.
If your personal details change, you can amend your details in the “myDetails” section of your pinPay (Payen) Account. We shall not be liable for any loss arising out of your failure to keep your personal details up to date. Specific personal details cannot be amended in your pinPay Account without assistance from Payen customer services. For further advice please contact us by email: email@example.com or telephone 0345 450 6107 between 09:00- 17:00 Monday-Friday excluding UK Public Holidays. Please note that for certain amendments (ie, Surname), identification and proof of change will be required.
If you believe that any information we are holding on you is incorrect or incomplete, you should update this within your pinPay account or please write to or email us as soon as possible. We will promptly correct any information found to be incorrect.
You have the right to rectify or delete any information about you that is not accurate and the right to ask us not to process your personal data for any marketing purposes. We shall not be liable for any loss arising out of your failure to keep your personal information accurate and up to date.
You should keep your personal information up to date at all times. If you need us to send you details of the personal data we store on you please contact us at firstname.lastname@example.org.
Controlling Disclosure Of Your Data
Merchants and online Businesses
When making a payment to an online business, which accepts pinPay we will, at a minimum, pass on your email address to the recipient and result of your attempted payment (whether successful or unsuccessful). Depending on the requirements of the merchant and the type of payment involved, we may also send other personal details such as your name, address and country of residence, if the recipients request this information from us. This is to improve the payment process, to reconcile payments with the commercial transaction or to conduct their own anti-fraud and anti-money laundering checks.
Fraud and Credit Reference Agencies
When you open a pinPay (Payen) account, and potentially at intervals of up to every 3 months and at any other time we feel it is necessary to do so to protect our financial interests and prevent money-laundering or fraud, we share certain information about you and your pinPay (Payen) Account, financial history and transactions as part of our normal business operations with our banks, payment facilitator partners, credit/debit card processing services, identity verification service providers and credit reference agencies to identify and verify users, to limit our exposure to fraud and other criminal activities and to manage our financial risk. We can provide you with a list of the credit reference agencies we use upon your written request to the email address set out in the Contact Us section below. When conducting identification or fraud prevention checks, the relevant parties may retain a record of our query along with your information and may share this information with other fraud prevention agencies. If you want to know what information these companies hold about you, you can write to them to request access to your information.
- Any member of our group of companies (our subsidiaries, our ultimate holding company and its subsidiaries) as defined in section 11599 of the Companies Act 2006
- a prospective buyer of our business or a buyer of a substantial number of the shares in our business, if Payen is involved in a merger, acquisition, or sale of all or part of its assets, you will be notified by email and/or prominent notice on our website of any change of ownership or uses of your personal information, as well as any choices you may have regarding your personal information
- The police, other lawful enforcement or regulatory bodies or court, if we are under a duty or required by law to disclose or share your personal data, or to protect the rights, property, or safety of ourselves or our group companies, our customers, or others
- Third parties where you have expressed an interest in receiving information about their goods and services
- Third parties we may occasionally use to provide you with the services that you have requested (we require these third parties to not use your personal information for any other purpose)
It may be necessary — by law, legal process, litigation and/or requests from public and governmental authorities within or outside your country of residence — for Payen to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. We only allow third parties access to your data when required to make a transaction with a third party, or when required by law or for fraud/identity agency reasons
We do not knowingly collect personal information from children under 13. If we learn that we have collected the personal information of a child under 13, we will take steps to delete the information as soon as possible.
We would delete any personal information on children as soon as we are aware.
Third Party Sites
Our website may contain links to other websites of interest or businesses which accept pinPay as a payment option. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information, which you provide whilst visiting such sites that are not governed by this privacy statement. You should exercise caution and look at the privacy statement and any other terms and conditions applicable to the website in question. This is your responsibility.
We are not responsible for other people’s privacy policies and you should read them to check you are happy.
Notification of Changes
This policy may be changed; however any major changes will be notified to you by email.
We may contact you by email to the primary email address registered with your pinPay (Payen) Account or by telephone to the contact telephone numbers you have provided when registering for your account or by post to the address details provided when registering for your account. You can change your primary email address and/or contact telephone number at any time when you are signed into your account.
You may also receive system-generated transactional emails such as confirmation of fund uploads notification of receipt of payments, notification of password changes etc. which are necessary for the proper operation and administration of your account. If you no longer wish to receive emails which are not promotional in nature, then you have the option to deactivate your account. To deactivate your account please contact us by email: email@example.com or telephone 0345 450 6107 between 09:00-17:00 Monday-Friday excluding UK Public Holidays.
Payen representatives will never ask you for your pin or password, so any email or other communication requesting your pin or password should be treated as unauthorized and suspicious and forwarded to firstname.lastname@example.org. If you do share your Payen pin or password with a third party for any reason, including because the third party has promised to provide you additional services, the third party will have access to your pinPay (Payen) account and your personal information, and you may be responsible for action taken using your pin or password.
If you are concerned that any of your login details have been compromised, you can change them any time once you are logged on but you should always also immediately contact Payen Customer Services and tell us why you think your login details have been compromised. Details of how to contact Payen Customer Services are available from the “Contact” section of the Website.
Nobody likes uninvited emails, therefore we only notify you of important actions that have occurred on your account.
Our data protection officer can be reached at: Email: email@example.com Post: Data Protection Officer, Payen Limited, Surrey Research Park, 22 & 24 Frederick Sanger Road, Guildford, GU2 7YD, UK Users in the European Economic Area (EEA) and Switzerland have the right to lodge a complaint with the Supervisory Authority for data protection in their country, should they find that we did not appropriately address their privacy or personal data question or concern.
General customer service enquiries, information or exercising of your rights, please contact us by email: firstname.lastname@example.org or telephone 0345 450 6107 between 09:00-17:00 Monday-Friday excluding UK Public Holidays.
If you have any complaints relating to any aspect of our service, please email email@example.com. Please state clearly the nature of the complaint. We will acknowledge your complaint within five working days and issue a tracking number. We will use the tracking number in all future communications. You will also be assigned a contact name who will be responsible for keeping you informed of the progress of any complaint through to resolution. NOTE: In order to safeguard your personal information please ensure that you do not provide your pin or password to Payen via email or any other communication method (including Customer Services). Information on how to contact Payen.
If you are a pinPay Payen Services User in the European Economic Area (EEA) and Switzerland you also benefit from certain rights granted by applicable law but subject to limitations therein. These rights include the right of access, rectification, restriction, opposition, erasure and portability, and the right to not be subjected to automated decision-making. If you want to exercise those rights or find out more, please contact us. If you are a pinPay User in the European Economic Area (EEA) and Switzerland you can benefit from certain rights granted by law, but subject to limitation.
Cookies and Other Tracking Technologies
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. Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. Cookies do not contain any information that personally identifies you, a cookie in no way gives us access to your computer or any information about you. A cookie is a small amount of data containing information that is downloaded to the device from which you access our site. Cookies are useful because they allow us and other websites to recognise your device. For more comprehensive information about how cookies work, see http://www.allaboutcookies.org. Cookies are widely used in order to make websites work, or work more efficiently and to provide information to the owners of the site. For example, they can allow you to navigate between web pages of our site and remember your preferences such as your language selection.
Types of Cookies we Use
- Session security cookies – These are the cookies that are essential for our site to operate such as those which identify you so you can log into your Payen Account. They allow you to move around our website and use the services you have requested securely. These cookies will be activated when you enter our site and as you use our site. They are terminated when you exit our site.
- Compliance cookies – These include the cookies that are necessary to assist in meeting our regulatory compliance obligations, such as anti-money laundering and anti-fraud obligations and prevent your Payen account from being hijacked. These cookies will be activated when you enter our site and as you use our site. They are terminated when you exit our site.
- Performance cookies – These are cookies that help us to improve how our site works and to deliver a better service to you. For example, they will assess which pages you visit most often or if you get an error message. They also allow us to see if you have used the site of one of our group or affiliated companies. All information collected by these cookies is aggregated and therefore anonymous.
- Functionality cookies – These cookies allow us to deliver a more personalised service to you and allow our site to remember choices you have made such as the language you prefer or the region you are in. They may also be used to provide services you have requested such as being able to comment on one of our blogs.
Third Party cookies
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REGULATION & POLICY
FCA eMoney Regulations
INFORMATION ABOUT FCA REGULATION
Payen is authorised by the Financial Conduct Authority (FCA) under the Electronic Money Regulations 2011 for the issuing of electronic money (register number 900043). The eMoney regulations are very stringent on firms such as Payen to ensure that consumer funds are always safeguarded, and that our internal processes ensure that robust anti-money laundering policies are in place.
Key Aspects of Regulation:
Safeguarding your Funds
Payen follows a clear set of guidelines to ensure that we take the best approach in the safeguarding and protection of your funds. Authorised e-money issuers are required to ring- fence funds received from customers for e-money in specially segregated bank accounts. This means that in the unlikely event of Payen becoming insolvent, the unused e-money will be protected from other creditors’ claims and can be repaid to end customers.
Capital Requirements & Liquidity
Our business is required to maintain minimum levels of capital. The current threshold is €350,000 of our own funds. Payen must also always hold sufficient liquid assets to be able to redeem all e-money issued and to meet our working capital requirements.
Rigorous Background Checks on Company Owners and Management
The FCA must be satisfied that all individuals responsible for the management of the e- money and payment services are of good standing and possess appropriate knowledge and experience. Additionally the FCA needs to understand who owns the company and the way Payen is run by its owners.
Systems & Risk Management Framework
A regulated eMoney issuer must have a robust risk framework which identifies, addresses and manages key risks of the business. This ensures that the company is being properly run and protected from any significant risks, which could have a negative impact on the reputation and robustness of the company. Our company must also operate strong and appropriate technology and systems to ensure on-going compliance with the FCA regulatory framework.
Financial Crime Prevention
Payen must comply with all legal and regulatory requirements to detect and deter financial crime, which includes money laundering and terrorist financing. Relevant legislation includes the financial crime provisions in the EMRs, section 21A of the Terrorism Act 2000, the Proceeds of Crime Act 2002, the Money Laundering Regulations 2007, the EC wire transfer regulation 21 and Schedule 7 to the Counter-Terrorism Act 2008. The Money Laundering Regulations 2007 require firms to put preventative measures in place to reduce the risk of money laundering. These measures include performing Know Your Customer, keeping identity records of the parties involved with financial transactions and maintaining a well-informed staff who are highly familiar with the requirements of the regulations.
ANTI-MONEY LAUNDERING POLICY
Payen operates strict Anti-Money Laundering procedures in order to deter, detect and report any suspected Money Laundering activity. As part of our procedure we need to confirm the identity of both parties involved with all financial transactions. We ask for your co-operation to help us fight against crime and terrorism.
What may happen?
Whether you are a new or returning customer, we may ask you to confirm your identity. The merchant you are buying services from may also ask you to do so. We have minimised interruption to your user experience when using Payen services however in some cases the verification process may take longer while we validate your identity.
What do I have to do?
It is in your long-term interest to provide accurate and valid data, so if you are asked to confirm your identity we ask for your full co-operation during this process. Payen has established a number of verification systems to check your identity when using your payment card and when you provide personal information and/or bank account details. Limits will be placed on your account if you have not completed the full verification required to use the Payen service.
What is Money Laundering?
Money Laundering is when criminals turn the cash and proceeds made from crimes such as drug trafficking, arms dealing and robbery into clean money by using false identities or taking the names of innocent people – like you. Making sure that people are who they say they are is essential in the fight against crime and terrorism. Any information about your identity is held confidentially and will help stop your identity being used falsely.
What does the UK law require?
- We are required to verify your identity and address in order to remove spending limits on your account.
- We are required to keep full records of all transactions together with identification provided.
- We are required to monitor any unusual or suspicious transactions of any size.
- We have a legal obligation and to report any suspicious transactions to the Serious Organised Crime Agency (SOCA).
CONSUMER PROTECTION ACT
Consumer Protection Act Payen complies with the Electronic Commerce Regulations 2002 and the Consumer Protection (Distance Selling) Regulations 2000 Notice.
Our Company Details:
Company Name: Payen Limited Registered in: England and Wales Company Number: 07427913 Registered Office: 130 Wood Street, London, EC2V 6DL, UK Contact: Customer Services Regulation: Financial Conduct Authority FCA Number: 900043
We pride ourselves in provide an outstanding service for our customers however if you are dissatisfied with our service please do not hesitate to contact Payen as follows: Either via the contact form or via post: Customer Services Surrey Research Park 22 & 24 Frederick Sanger Road Guildford GU2 7YD, UK
A description of our electronic money service is provided in the Customer section of the Payen website. Details about any charges for using our services are provided in the Pricing section.
Terms and Conditions of Use:
To use our services, you must read and accept our User Agreement provided on the Payen website. Any electronic money account is opened for an undefined period of time. Should you no longer desire our service you can deactivate your electronic money account by first withdrawing any balance from your account and then contacting our Customer Support Centre.
OUR ACCEPTANCE POLICY
This Acceptance Policy published by Payen outlines the industries or uses which are expressly prohibited by our service. This policy ensures that we maintain compliance with applicable legislation which, if violated, may affect our ability to supply a quality payment service to our customers. pinPay from Payen must not be used, in any way with any of the following categories:
- Gambling (including Casinos, Lotteries & Skill Games)
- Firearms, Weapons and Knives
- Pharmacy or Nutraceuticals
- Alcoholic Beverages and Tobacco
- Stored Value Cards & Pre-Paid Debit Cards
- Adult Content
- Illegal Drugs & Paraphernalia
- Unauthorised Copies (infringement of copyright)
- Pyramid Selling and Multi-Level Marketing
- Content Aggregators
- Virtual Currency
- Unregulated Insurance Firms
Breach of Guidelines
Any transaction appearing on Payen which appears to fall onto one of these categories may be reversed and any account not adhering to this policy may be suspended or terminated to prevent further breach of our guidelines, as per the User Agreement. Some of the guidelines require detailed knowledge of laws in different countries. It is the account holder’s responsibility to trade only where and when it is legal to do so. Customers who do not follow this guidance will be deemed to be in breach of the User Agreement. The contents of this policy are not exhaustive and may be updated at any time in order to satisfy Payen’s own corporate risk management processes.