Privacy Policy

Payoro, Inc. and its affiliates (collectively “Payoro”, “we” and “us”) respect your privacy. We offer services that connects consumers with leading financial institutions around the world, powered by state of the art banking technology.

This Global Privacy Policy describes the types of Personal Data we collect through our products and services (“Services”) and via our online presence, which include our main website at Payoro.com, as well as services and websites that we enable Internet users to access, such as the Payoro Platform (collectively, our “Sites”). This policy also describes how we use Personal Data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third-parties carefully.

Privacy Policy Contents

1. Overview
2. Personal Data We Collect
3. How We Use Personal Data
4. How We Disclose Personal Data
5. Your Rights and Choices
6. Security and Retention
7. International Data Transfers
8. Use by Minors
9. Updates To this Privacy Policy
10. Links To Other Websites
11. Jurisdiction and specific Provisions
12. Contact Us

Payoro obtains Personal Data about you from various sources to provide our Services and to manage our Sites. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User” or “Payoro User”), or a customer of a Partner (“Partner Customer”). If you are a Partner Customer, Payoro will possibly only partially collect your Personal Data directly from you and some data may be provided under the consent that you have authorized the respective Partner. Your agreement with the relevant Payoro Partner should explain how the Payoro Partner shares your Personal Data with Payoro, and if you have questions about this sharing, then you should direct those questions to the Payoro Partner.

a. Personal Data that we collect about you

Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites and Services will be apparent from the context in which you provide the data. In particular:

• When you register for a Payoro account we collect certain information about you, such as your full name, email address, social security number, address, mobile phone number and account log-in credentials.
• As part of your business relationship with us, we may also receive financial and personal information about you, such as your date of birth and government identifiers associated with you (such as your social security number, tax number, or Employer Identification Number).
• If you are a Customer of a Payoro User, when you make payments or conduct transactions through a Payoro User’s website or application or device we provide, we will receive your transaction information. Depending on how the Payoro User implements our Services, we may receive this information directly from you, or from the Payoro User or third parties. The information that we collect will include information about the relevant financial transaction, such as currency, amount, payee information, recipient information and similar. Different transaction typos may require the collection of different categories of information.

When we conduct fraud monitoring, prevention, detection, and financial compliance activities or provide such services to our Users, we will receive Personal Data from you (and your device) and about you through our Service and from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may collect Personal Data about you and use technology to help us assess the risk associated with an attempted transaction by you with a Payoro User.

You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

b. Information that we collect automatically on our Sites.

Our Sites use cookies and other technologies to function effectively. These technologies record information about your use of our Sites, including:

• Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting
• Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.

We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our Sites to help us analyze Your use of our Sites and diagnose technical issues.

To learn more about the cookies that may be served through our Sites and how You can control our use of cookies and third-party analytics, please see our Cookie Policy.

a. Our products and services.

We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete payment transactions and to provide payment-related services to our Users.

b. Marketing and events-related communications.

We may send you email marketing communications about Payoro products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law.

c. Advertising.

When you visit our Sites, we (and our service providers) may use Personal Data collected from you and your device to target advertisements for Payoro Services to you on our Sites and other sites you visit (“interest-based advertising”), where allowed by applicable law. For example, when you visit our Site, we will use cookies to identify your device and direct ads for our Services to you. You have choices and control over our cookies (or similar technologies) we use to advertise to you. Please see our Cookie Policy for more information. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.
We do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site visitors.

Payoro does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.

a. Payoro.

We share Personal Data with other Payoro entities in order to provide our Services and for internal administration purposes.

b. Service providers.

We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union.

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

c. Business partners.

We share Personal Data with third party business partners when this is necessary to provide our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and financial institutions.

d. Our Users and third parties authorized by our Users.

We share Personal Data with Users as necessary to maintain a User account and provide the Services. We share data with parties directly authorized by a User to receive Personal Data, such as when a User authorizes a third-party application provider to access the User’s Payoro account through the Payoro platform. The use of Personal Data by an authorized third party is subject to the third party’s privacy policy.

e. Corporate transactions.

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

f. Compliance and harm prevention.

We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Payoro, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

You have choices regarding our use and disclosure of your Personal Data:

a. Opting out of receiving electronic communication from us.

If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

b. How you can see or change your account Personal Data.

If you would like to review, correct, or update personal data that you have previously disclosed to us, you may do so by signing in to your Payoro account or by contacting us.

c. Your data protection rights.

Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:

• The right to request confirmation of whether Payoro processes Personal Data relating to you, and if so, to request a copy of that Personal Data
• The right to request that Payoro rectifies or updates your Personal Data that is inaccurate, incomplete or outdated
• The right to request that Payoro erase your Personal Data in certain circumstances provided by law
• The right to request that Payoro restrict the use of your Personal Data in certain circumstances, such as while Payoro considers another request that you have submitted (including a request that Payoro make an update to your Personal Data) and
• The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.

Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

d. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact Payoro.

We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

If you are a Customer of a Payoro User, please direct your requests directly to the User. For example, if you are making, or have made, a transaction using Payoro to facilitate the transaction, and you have a request that is related to the transaction itself, then you should address your request directly to the Payoro User.

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.

We retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services directly or indirectly to you, even if you close your Payoro account or complete a transaction with a Payoro User, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy and under the GDPR. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your Payoro Dashboard, email address and/or the physical address listed in your Payoro account.

The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.

For all data protection or privacy concerns the responsible entity for both the collection and processing of Personal Data for residents of the EEA, the UK and Switzerland is Payoro OÜ.

For any concerns, queries or to exercise any of your data protections rights, the Data Protection Officer may be contacted via privacy@payoro.com.

Please note that we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required. If you are a Customer of a Payoro Partner, please direct your requests directly to the Payoro Partner with whom you shared your personal information.

Beyond this, if you are a resident of the EEA and at any time believe we do not process your information in scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Office of the Data Protection Commissioner (https://www.dataprotection.ie/). If you are a resident of the UK, as the UK is no longer a Member State of the EU, you may direct your questions or concerns to the UK Information Commissioner’s Office (https://ico.org.uk/).

If you have any questions or complaints about this Privacy Policy, please contact us electronically on support@payoro.com.