Privacy Policy

This Privacy Policy (hereinafter “Policy”) describes how we deal with your “personal data” (that is, information about any identified or identifiable living persons, hereinafter also referred to as “data”). Please read on to find out what kinds of personal data we collect, how we use and protect it, to whom we disclose it and how you can access and rectify it or request that we stop processing it.

Paymentwall and its affiliates and subsidiaries (collectively referred to as “Paymentwall”, “our”, “us” or “we”) respect your right to privacy, the present privacy policy governs how Paymentwall deals with the personal data collected, stored and processed by us . The present policy complies with applicable laws for the protection of your privacy, including, without limitation, wherever applicable, the California Consumer Privacy Act (CCPA), the European Union General Data Protection Regulation (GDPR), the Hong Kong Personal Data Ordinance (PDPO), and the current Data Protection legislation in India .

By using the Paymentwall site (hereinafter “Site”) and/or the Paymentwall services (hereinafter “Services”), you accept this Policy, our terms of service and our cookie policy. Please do not use the Site and/or Services unless you have read this Policy, our cookies policy and our terms of service. If you use the Site and/or the Services, we will assume that you do accept it.

Data Collection

What is personal data?

“Personal Data” means any information that can either itself identify you as an individual (“Personally Identifying Information”) or that can be connected to you indirectly by linking it to Personally Identifying Information.

When do we collect your data?

We collect data about you directly from you and/or from third parties, to whom you have granted such consent, as well as automatically through your use of the Services:

When you access the Site or visit a page that integrates the Services: Our systems gather data that is automatically transmitted from the device(s) you use to access the Site or other sites integrating the Services, such as your IP address, unique device identifier, browser information, and system information (e.g., operating system).
When you complete a transaction using our Services: During the course of a transaction, you will be prompted to enter certain information about yourself, if you have not already provided it as part of the account creation process. This data may include your full name, address, date of birth, and details about the payment method you are using.
When personal data is provided to us by third-party sources in connection with your use of the Services: Merchants for whom we process payments for, may send us any required data you have provided them, including your personal details (e.g., name, contact information) and details regarding your past and current purchases and activity on their site to the extent such data is necessary to process your transaction.
When you communicate with our customer support team: If you initiate communication with our customer support team, you may be prompted to provide additional information about yourself and your transaction. Additionally, our customer support team may contact you to request further proof of personal identity, such as a new or updated picture of a legal identification document in order to ensure your transaction is valid or to the extent it otherwise may be necessary to comply with our legal obligations.

Data Use

Paymentwall collects personal information for the following reasons:

To offer the Services: We will use your personal data as necessary to provide the Services, including to the extent necessary to process the transactions you initiated, verify your identity, authenticate your access to a user account, and communicate with you about the Services.
To manage risk and protect you, the Site and the Services: Fraud prevention is a critical part of providing our services, and we use your data to help us detect and prevent fraud.
To comply with our legal obligations: Our obligations may include complying with all applicable anti-money laundering (AML) and counter terrorist financing (CTF) regulation as well as our contractual obligations with third-party partners who provide or help to provide any payment method(s) you use on our Services.
For our other legitimate interests: We may need to use your personal data in order to enforce our contracts and terms of service and monitor activity on the Site.
Where you have given consent to it.

What Data do we collect?

Basic Account Data

When setting up an Account, Paymentwall will collect your email address, Name and telephone number. The provision of this information is necessary to register a User Account.

Transaction and Payment Data

In order to make a transaction on Paymentwall, you will need to provide payment data. If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date and security code) to Paymentwall, which will process and transmit to the payment service provider of your choice to enable the transaction and perform anti-fraud checks. Likewise, Paymentwall will receive data from your payment service provider for the same reasons.

Other Data You Explicitly Submit

We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication. This data includes:

- Information sent through customer support chat;

- Information you provide when you request information or support from us or purchase Content and Services from us, including information necessary to process your orders with the relevant merchant.

Your Use of the Paymentwall Websites

We collect a variety of information through your general interaction with the websites, Content and Services offered by Paymentwall. Personal Data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions and application usage data. Likewise, we will track your process across our websites and applications to verify that you are not a bot and to optimize our services.

Tracking Data and Cookies

We use “Cookies”, which are text files placed on your computer, and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to help us analyze how users use our services, as well as to improve the services we are offering, to improve marketing, analytics or website functionality. The use of Cookies is standard industry practice on the internet. Although most web browsers automatically accept cookies, the decision of whether to accept or not is yours. You may adjust your browser settings to prevent the reception of cookies, or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser. When you visit any of our services, our servers log your IP address, which is a number that is automatically assigned to the network your computer is part of.

Data Disclosure

If you access a third party website, which is part of our Merchant Base , personal data may be collected by these third parties in accordance with their privacy policy. Please carefully review such policies before proceeding with browsing. Your privacy is important to us so we have taken measures to ensure that all of the entities we share your personal data/information with, have implemented strong data privacy and data protection practices of a level comparable to that which we employ. Your personal data may be disclosed under the following circumstances:

When our related affiliates or subsidiaries require the data to help provide the Services: We have related affiliates and subsidiaries around the world that assist in providing the Services. We may provide your data to these affiliates or subsidiaries for any of the purposes we would ourselves use your data, including carrying out the transaction you requested, preventing fraud or illegal activity, and enforcing our terms and conditions. If we disclose your personal data to these affiliates or subsidiaries, their use of the personal data will subject them to this Policy.
When our third-party payment partners need it to process a transaction you initiated: We have contracts with banks and other third-party financial institutions for every payment method we offer on the Services. When you authorize a transaction, we will transmit to the relevant third-party data they require to process the transaction. The data that is required will vary according to the payment type, but may include your name, address, and details of the purchase you are attempting to make.
When our merchants need the data in connection with a transaction you initiated: Where necessary, we will share certain data about you with our third-party merchants to help facilitate the transactions. This data will never include your sensitive payment details (Eg. credit card number).
When other third-parties that provide us with ancillary services in order to facilitate the Services: This includes our server hosting providers and independent auditors whom we engage for the purposes of analyzing our compliance with the law or relevant independent standards.
To the extent required by law: We will share your data with third-parties to the extent we are required to do so by law. For example, we are required by law to undergo certain routine audits, which may require us to share your data with the third-party auditors we have engaged in relation to these requirements. Additionally, we may have to disclose your data when we receive a valid subpoena or other law enforcement request, or when the law requires us to affirmatively notify law enforcement in order to prevent harm or illegal activity. The necessity of all such disclosures will be determined in our sole discretion.
To the extent our legitimate interests require us to do so: We may transmit your data to our third-party partners for inclusion on their blacklists or lists of terminated merchants, or to help us engage in our fraud reduction efforts, to support our corporate governance activities, to facilitate the sale or other transfer of all or part of our business, or to protect us or our Services.

While sharing your personal information with third parties such as payment processors, etc., we control the use of your data via written contracts which conform to this Privacy Policy.

Data Retention

The retention period for your data, collected through our contact website or email will vary, depending on the development of our business relationship and until fulfillment of the purposes, for which your data has been collected and/or to comply with our legal obligations as per applicable record retention laws (including obligations under the Anti Money Laundering Act).

Data Location

We use servers located in the European Union, the United States and India to store personal data gathered by the Services. For India users we collect and store data exclusively in India. Additionally, to the extent we transfer your data to a third-party, including our related affiliates, as described in this Policy, these third-parties may be located outside our usual business location and your country of residence. In all such cases, data transfers will be carried out only after we ensure the third-party provides comparable levels of data protection and that they will use your data only for the purposes set out in this Policy.

Your rights with regards to personal data processing

To the extent that your personal data have been collected, every user is entitled to the following rights, subject to applicable data protection laws in Your respective jurisdiction:

Right to withdraw consent at any time

If processing is based on consent, you can withdraw your consent at anytime. Your withdrawal of consent does not affect the lawfulness of processing based on consent before your withdrawal.

Right of access by the data subject

You can confirm with us whether or not we have processed your personal data. If we processed your personal data, you have the right to request for copies of your personal data. We may charge you a small fee for this service.

Right to rectification

You have the right to request that we correct any information about you that you believe is inaccurate. You also have the right to request that we complete information about you that you believe is incomplete.

Right to erasure

You have the right to request that we erase your personal data, under certain conditions. We may not be required to comply with your request to delete personal data if the processing of your personal data is necessary for compliance with Our legal obligations as per applicable laws or for the establishment, exercise, or defense of legal claims.

Right to restriction of processing

You have the right to request that we restrict the processing of your personal data, under the following circumstances: (i) you contest the accuracy of your personal data; (ii) the processing is unlawful but you wish to restrict rather than prohibit the processing of your personal data; (iii) the purposes for processing your personal data no longer exist, but you require the personal data for the establishment, exercise, or defense of legal claims; or (iv) you have legitimately objected to the processing of your personal data and the processing is therefore restricted pending the verification of whether the legitimate grounds of the controller override your objection.

Right to data portability

To the extent that we process your personal data, (i) based on your consent or under contractual obligations, and (ii) through automated means, you have the right to request that we transfer your personal data that we have collected to another organization where technically feasible, or directly to you in a structured, commonly used, machine-readable format.

Right to object and automated individual decision-making

The right to lodge a complaint with a supervisory authority

You can lodge a complaint with a supervisory authority, in particular in the member state of the European Union, in your habitual residence, place of employment or place of alleged infringement. Without implying any obligation to do so, we would like to kindly encourage you to discuss and try to resolve in good faith any issue, which may have arisen with regards to data processing, storage and usage.

Children’s Privacy

We do not process personal data of children under the minimum legal age pursuant to local legal requirements in the state, province, country or jurisdiction of residence. We take appropriate measures to ensure that children do not use the Services. If you discover that a child under age has provided us with his/her personal data, please contact us at support@paymentwall.com.

Contact Us

To exercise your data protection rights as listed above, please send the privacy request form to support@paymentwall.com. Please note that we may request for additional identification including photo identification in order to verify and grant an individual access to their requested personal data. For further questions and concerns, you may reach our Data Protection Officer at dataprotection@paymentwall.com.

Changes to this Policy

This Policy is current as of the Effective Date set forth below. We may change this Policy from time to time, so please be sure to check back periodically to be updated. We will post any changes to this Policy on the Site and the Services. If we make any changes to this Policy that materially affect our practices with regard to the personal data that we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on the Site and the Services.

Additional Information for Users in California, USA

CCPA grants certain privacy rights to residents of California, USA regarding the personal information we collect. We respect these rights and strive to comply with CCPA. The following describes these rights and Paymentwall’s practices regarding them.

Right to Know

Under the CCPA you have the right to request that we disclose to you what Personal Data we collect, use and/or disclose.

Right to Request Deletion

You have the right to request deletion of Personal Data that is in our possession, subject to certain exceptions. Please note that your request to delete data may impact your use of the Service in some cases, and we may decline to delete information for reasons set forth in this Privacy Policy or as permitted by the CCPA.

Other Rights

The CCPA also gives California residents a right to opt-out from the sale of their Personal Data.We do not sell Personal Data and have not done so in the past 12 months. You also have a right to receive notice of our practices at or before collection of your Personal Data. Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

Exercise of Rights

The way you access, manage, or delete your personal information is through contacting our dedicated customer support department at support@paymentwall.com. Another way to exercise your rights is directly by submitting a ticket using our website www.paymentwall.com.

You may appoint a formal agent in writing or by power of attorney to request the exercise of your rights under CCPA. Prior to responding to a request from an agent, we require the agent to provide evidence that it has been authorized to act as an agent. We may also ask you to verify your identity directly or indirectly with us.

Categories, Sources, Purposes and Recipients of the Information We Collect Over the past 12 months, we have collected personal data in the categories set forth in Section A of this Privacy Policy. The sources of personal data and the purposes for which it is collected / processed are described in Section A. Over the past 12 months, we have disclosed personal information in each category to third parties in the categories listed in Section A for business purposes.

Additional information for Users in India

Right Of Access By The Data Subject

Right To Rectification

You have the right to request that we correct any information about you that you believe is inaccurate.

You also have the right to request that we complete information about you that you believe is incomplete.

This Privacy Policy was last updated on 15th March 2024.