Privacy Policy

GENERAL

This Privacy Policy, together with our Terms of Use, governs Paynote’s collection, processing and use of your Personal Data. As used in this Privacy Policy, “Paynote”, “we”, “us” or “our” refers to Aardo LTD., registered with the Estonian Trade and Companies Register under the number 12419276, with its registered address at Punane tn 6-215c, Tallinn, 13619, Estonia, a virtual currency exchanging license number FVR000386, and Digiyastreb LTD, registered within the Spanish and Companies Registrar under the number B42524470, with its registered address at Ingeniero Sanchis pujalte 12, bajo, 03010 Alicante/Alacant, Spain.. Aardo LTD and Digiyastreb LTD are both data controllers under this Privacy Policy, which sets out the manner in which both companies, as data controller, may use your Personal Data.

 

COLLECTION AND USE OF PERSONAL INFORMATION
A. Personal Information We Collect

We collect the Personal Data you provide directly to us or which we generate when you open a Paynote Account, perform any transactions on the Paynote Platform, or use other Paynote Services or our website. This may include:

  • Contact information, such as name, home address, and email address;
  • Account information, such as username, password, account settings and preferences;
  • Financial information, such as bank account numbers, bank statement, and trading information;
  • Identity verification information, such as images of your government issued ID, passport, national ID card, or driving licence
  • Residence verification information, such as utility bill details or similar information;
  • Information regarding the way in which you use our services, such as when you used our services and the specific services used; and
  • Information relating to communications with us, whether through the Paynote website or via e-mail, over the phone or via any other medium.

We also automatically collect certain computer, device and browsing information when you access the Paynote website or use Paynote Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:

  • Computer or mobile device information, including IP address, operating system, network system, browser type and settings;
  • Website usage information.

Finally, we may collect Personal Data from third party partners and public sources, which include:

  • Reputational information;
  • Financial information;
  • Business activities of corporate customers.

We need to collect certain types of information for compliance with legal requirements relating to our anti-fraud/anti-money laundering/counter financing of terrorism/know your customer obligations. If this information is not provided we may not be able to provide a service for you. Your personal data may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claims. We will not dеlete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved. We do not perform behavioral tracking of a customer’s activities on our Paynote website or across different websites, nor do we allow third-party data collection through our Paynote Service save as expressly set out in this Privacy Policy.

It is important to note that the Personal Data we collect on you when you create an account will be retained for the mandatory retention period set forth by applicable law and as necessary for us to maintain an exhaustive documentation of our operations as required from us as regulated financial sector professionals, even if your account has not been successfully activated (e.g., if account verification has not been completed) or no transaction has been made using it.

B. Use of Cookies and Similar Technology

The Paynote website is using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our website are most visited and difficulties our visitors may experience in accessing our website. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Site.

We use third party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we sеlect that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using information they receive from our Site other than to assist us.

If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features or our website or services, such as logging on to your Paynote Account or making transactions. Your use of our website or service with a browser that is configure to accept cookies constitutes an acceptance of our and third-party cookies.

If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features or our website or Services, such as logging on to your Paynote Account or making Transactions.

C. How We Use Your Personal Information

We collect and use your information for a variety of reasons. We need some information to enter into and perform our contract – for example your contact and payment details. Some information processing is required by law due to our anti-fraud screening obligations or in the public interest such as making sure we verify our customers’ identities.

Some information is processed because you’ve given your consent to that, which can be withdrawn in your account preferences and settings. Other information we collect and use because we have legitimate business interests to so, having taken into account your rights, interests and freedoms.

We may use your Personal Information to:

  • Create and administer your Paynote account and generally for accounting, billing, maintenance of legal documentation and claim and dispute management. Related processing operations are necessary for the performance of a contract with you (or to take steps at your request prior to entering into a contract), and for compliance with legal obligations to which we are subject;
  • Process your Paynote transactions. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject;
  • Verify your identity in accordance with applicable know-your-customer, money laundering and other financial sector legislation or regulations, including as required for compliance with the Paynote Anti Money Laundering policy, as well as address other law enforcement needs as more fully described in our Terms of Use, and generally as required for compliance with legislation and regulations applicable to Paynote. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject;
  • Personalise your Paynote Services experience. Related processing operations are necessary for purposes of our legitimate interests (that is, improving our services);
  • Analyse Paynote website usage, and improve our website and website offerings. Related processing operations are necessary for purposes of our legitimate interests (that is, improving and promoting our services);
  • Help us respond to your customer service requests and support needs. Related processing operations are necessary for the performance of a contract with you, and for purposes of our legitimate interests (that is, improving our services and offering you the best experience);
  • Contact you about Paynote Services. The email address you provide may be used to communicate information and updates related to your use of the Paynote Services.

DISCLOSING AND TRANSFERRING PERSONAL DATA

We may disclose your Personal Data to third parties and legal and regulatory authorities, and transfer your Personal Data outside the EEA, as described below.

A. Disclosures to Third Parties

There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.

We may share information about you with other members of our group of companies so we can provide the best service across our group. They are bound to keep your information in accordance with this Privacy Policy;
We may also share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other recipients/service providers include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists, email providers or outsourced call centres. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function;
We may also share your information with certain other third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you. These include credit reference agencies, anti-fraud databases, screening agencies and other partners we do business with.

B. Disclosures to Legal Authorities

We may share your Personal Data with law enforcement, data protection authorities, government officials, and other authorities when:

Compelled by court order, or other legal procedure.
Disclosure is necessary to report suspected illegal activity.
Disclosure is necessary to investigate violations of this Privacy Policy or our Terms of Use.

C. International Transfers of Personal Data

We store and process your Personal Data in data centers around the world, wherever Paynote facilities or service providers are located. As such, we may transfer your Personal Data outside of the European uniоn. Some of the countries to which your personal data may be transferred for these purposes that are located outside the EU do not benefit from an adequacy decision issued by the EU Commission regarding protection afforded to personal data in that country. Details of these specific countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. Such transfers are undertaken in accordance with our legal and regulatory obligations and appropriate safeguards under DP Law will be implemented, such as standard data protection clauses with data recipients or processors approved by competent authorities. A copy may be requested at the address set out in the Contact Us section.
YOUR STATUTORY RIGHTS

You have certain rights concerning your Personal Data under DP Law as mentioned below, and can exercise them by contacting us at info@paynote.eu.

Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it to check that we are lawfully processing it. We process a large quantity of information, and can thus request, in accordance with DP Law, that before the information is delivered, you specify the information or processing activities to which your request relates.

Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.

Erasure: you are entitled to ask us to dеlete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.

Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Transfer: you may request the transfer of certain of your personal data to another party.

Objection: where we are processing your personal data based on a legitimate interests (or those of a third party) you may challenge this. However we may be entitled to continue processing your information based on the our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal data for direct marketing purposes.

Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European uniоn where you are habitually resident, where we are based, or where an alleged infringement of Data Protection law has taken place

SECURITY OF PERSONAL DATA

We use a variety of security measures to ensure the confidentiality of your Personal Data, and to protect your Personal Data from loss, theft, unauthorised access, misuse, alteration or destruction. These security measures include, but are not limited to:

Password protected directories and databases;
Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely;
PCI Scanning to actively protect our servers from hackers and other vulnerabilities.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorised Paynote personnel are permitted access to your Personal Data, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.

We do not ask for financial or payment information, such as your credit card number, passcode, account number or pin number, in an e-mail, text or any other communication that we send to you. Please always check that any website on which you are asked for financial or payment information in relation to our reservations or services is operated by Paynote. If you do receive a suspicious request, do not provide your information and report it by contacting one our member service representatives as set in this Privacy Policy.

You are responsible for keeping your account passcode, membership numbers and pin numbers safe and secure. Do not share those with anyone. If there is an unauthorised use or any other breach of security involving your information, you must notify us below as soon as possible.

RETENTION OF PERSONAL DATA

We retain Personal Data for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. The criteria we may use to determine the retention period for certain categories of data includes:

How long you have been a Paynote member;
whether there are contractual or legal obligations that exist that require us to retain the data for a certain period of time;
whether there is any ongoing legal or financial claim that relates to your relationship with us;
whether any applicable law, statute, or regulation allows for a specific retention period; and
what the expectation for retention was at the time the data was provided to us.

In accordance with our record keeping obligations, we will retain Account and other Personal Data for at least five years (and some up to ten years, as required by applicable law) after an Account is closed.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy was last revised effective May 25 2018. We may change this Privacy Policy from time to time, so it is advisable to review it frequently. Changes to this Privacy Policy will be announced on our website or through similar means for a reasonable length of time prior to and following the change taking effect.

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