Maayan Payments LTD

1. Privacy Notice

Welcome to the Privacy Notice of Maayan Payments Ltd, trading as M-Pay. We are a private limited liability company, registered under company number 12552087. As an entity authorized by the Financial Conduct Authority (FCA) with FRN 927556, we operate as an authorised electronic money institution. Our commitment to your privacy is paramount.

In our role as an electronic money institution, we handle various types of data, which necessitates adherence to stringent data protection regulations. This document serves to inform you about the ways in which we handle your personal data – how it is collected, controlled, processed, and shared. Understanding this notice is crucial as it details both your rights and our responsibilities regarding your data. Should you have any queries or concerns, we encourage you to contact us. We are readily available to assist.

This Privacy Notice is part of our commitment to ensuring the privacy and security of your data. It may be complemented by additional privacy statements that are issued during specific data collection or processing activities. These additional notices are meant to provide further clarity and are not designed to replace this primary Privacy Notice.

2. Scope of Our Privacy Notice

This document outlines the data management practices of M-Pay regarding the collection and use of personal information. It applies to individuals who interact with our services, including website visitors, mobile app users, and consumers of our products or services.

By engaging with our website, mobile application, or utilising any of our products or services, you are consenting to the practices regarding data handling as detailed in this notice. We are committed to keeping you informed and may periodically revise this notice. Any modifications will be promptly communicated through updates on our website and mobile application.

We advise you to regularly review this notice, especially before providing any personal data or completing transactions, to stay informed about any changes. If at any point you find yourself disagreeing with the terms of this notice or any of its updates, you have the option to terminate your agreement with us. This can be done by closing your account, which can be requested via our web portal or mobile application.

3. Privacy Practices for Site Visitors (Excluding Service Users)

When you visit our site without using our services, we collect information through cookies and similar technologies. Details of this collection are thoroughly described in our cookie policy. The specific use of your personal information is governed by our cookie policy, with each application depending on the type of cookie involved.

3.1 Sharing of Personal Information

Your information may be shared with the following parties:

Our staff, who are permitted to use the data only for their official duties, research purposes, and customer support. The data is not used for any unrelated purposes.

Website hosting service providers, who assist us in maintaining and hosting our website.

3.2 Retention of Personal Information

We retain the information as outlined in our cookie policy, with two exceptions:

If legal obligations necessitate longer retention, we will comply accordingly.

If the data is relevant to legal proceedings, it will be retained until the conclusion of those proceedings.

4. Privacy Practices for Service Users

When you apply to use our services, you will need to provide:

Account Information: Creating an account is essential for transactions. This requires:

Email and password.

Personal details like name, address, date of birth, and phone number.

Government-issued IDs like passports, driver’s licenses, or UK identity cards, along with proof of address.

Your occupation, employer, and proof of funds for transactions.

Transaction Information: For transactions, you need to provide details about the recipient, such as their name, address, phone number, financial institution details, and the nature of the payout. We may also request information about the transaction's purpose and your relationship with the recipient.

Enhanced Due Diligence for Higher Limits: For transactions exceeding certain limits, additional personal information will be required, including details of previous transactions, payment methods, transaction frequencies, recipient relationships, and a detailed explanation of the purpose of the transfer.

Competitions, Promotions, Surveys: Participation in these activities requires submitting personal details as specified in the relevant forms.

Apart from the abovementioned information, we will collect the following:

Transaction logs and unique identifiers.

Customer support interactions.

Data from third-party sources like identity verification services.

Technical information automatically collected when accessing our services, like device details, IP address, and service usage patterns.

Cookies, as elaborated in our cookie policy.

4.1 Use of your Information and Legal Basis

We use your data for:

Legal and Regulatory Compliance: Specifically for anti-money laundering and financial crime prevention.

Contract Fulfilment: To provide services and prepare for contractual agreements.

Legitimate Interests: Balancing your rights against our interests, including maintaining service quality, managing financial crime risks, and marketing relevant products.

Consent: Primarily in cases where explicit consent is given for specific processing activities.

4.2 Automated Decision Making

We engage in profiling and automated decisions to ensure efficient service delivery and compliance with legal obligations. This includes:

Profile Creation: Based on age, residency, financial status, and anti-money laundering checks.

Fraud Prevention: Identifying potential fraud or money laundering activities.

Tailoring Services: Determining the suitability of services and products.

We offer options for human intervention in these processes and take measures to ensure data security, including pseudonymisation where feasible.

5. Sharing of Information and International Data Transfers

We transfer your information to parties in countries outside of the UK, as permitted or required by applicable law, regulatory authorities, law enforcement and government agencies. Additionally, when you send or receive money to or from another country, we will also be required to share some of your personal information with that country as required or permitted by law.

Business partners who facilitate the money transfer transaction or specific service you have requested;

Vendors, payments processors, banking partners and data processors contracted to provide business and customer services;

Customer services, based on your consent where applicable, including marketing, advertising and customer satisfaction and market research on our behalf;

Vendors and data processors contracted to help us validate the accuracy of the information provided by you, and to authenticate your identity and manage risks related to security, fraud and identity.

We may transmit personal information we possess in connection with a sale or transfer of all or part of our business. We may also disclose your personal information globally, as required or permitted by applicable laws and regulations, to group companies of M-Pay, regulatory and financial authorities, credit reporting agencies, law enforcement bodies, courts, governments or government agencies, to meet compliance and legal obligations or to assert or defend the rights and interests of M-Pay or others.

We do not have a list of all third parties we share your data with, as this would be dependent on your specific use of our services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to [email protected].

Where such recipients of data are located in third countries for which the UK Government has not issued an adequacy decision, M-Pay has in place contractual relationships with each such recipient that include international data transfer agreements and standard contractual clauses as approved by the UK Government or other supervisory authority where required, intended to ensure an adequate level of protection. We will always conduct rigorous due diligence to ensure there are no risks to such transfers and your personal data is protected and secured.

6. Retention of Personal Information

Our policy is to keep your personal information only for the time necessary to serve the purposes for which it was collected. This includes fulfilling legal, regulatory, accounting, or reporting obligations. In deciding how long to retain personal information, we consider several factors:

The requirements and timeframes set forth by applicable laws and regulatory bodies.

The type and sensitivity level of the personal data we hold.

The potential risk arising from unauthorized access or disclosure of your personal data.

The specific reasons we process your data and if these objectives can be achieved by other means.

As a standard practice, we retain your data for a period of 5 years following your last transaction with us or the termination of our relationship, whichever is later. Additionally, during the period of our business engagement, we maintain your information for a duration of 10 years from the date of each transaction.

7. Children

The services of M-Pay are not intended or designed to attract minors. Therefore, we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 18 is using our services, we will prohibit and block such use and will make all efforts to promptly and securely delete any personal data stored with us about such child. If you believe that we might have such data, please contact us by email at [email protected].

8. Your Rights

Data protection legislation offers you certain rights related to your data. These rights are not absolute and may be subject to exceptions. Nevertheless, they can be summarised as follows:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

8.1 No fee is usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

8.2 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8.3 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Safeguarding Your Personal Data

At M-Pay, we adhere to widely recognised industry standards to safeguard the personal information you provide to us. We have implemented both organizational and technical security measures to prevent accidental loss, unauthorized access, modification, or disclosure of your personal data. Access to your personal information is restricted to employees who need the information for business purposes. These employees process your personal data strictly according to our instructions and are bound by confidentiality obligations.

It's important to acknowledge that no method of data transmission over the Internet or electronic storage is completely secure. As such, while we strive to protect your personal information, we cannot assure or warrant its complete security. Any transmission of personal data is done at your own risk. For any concerns or queries regarding our security practices, please feel free to reach out to us at [email protected].

In the event of a suspected data breach, we have established procedures to respond promptly. Should such a breach occur, we will notify you and any relevant regulatory authorities as mandated by law.

10. Interaction with External Websites and Services

Our website and mobile application feature links to external websites, which have their own privacy practices that may differ from M-Pay. When you provide personal information to these third-party websites, it is subject to their respective privacy policies. M-Pay bears no responsibility or liability for the privacy policies of these external sites, nor for any personal data (including contact and location information) that may be collected and processed through these external websites or services. We recommend that you review the privacy notices of any external websites or software applications that you interact with.

Furthermore, this privacy notice does not extend to the practices of third-party entities you might engage with while using our services. This includes entities such as mobile network operators or other users of our services. We advise contacting these third parties directly to understand their privacy policies before sharing your personal information with them.