As the operators of the website www.kwikpay.com and of the Kwikpay Android or IoS Apps (“Platform”), Kwikpay Limited (“We“, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Kwikpay Limited.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of the Platform or providing our services:
- Information that you provide by filling in forms on the Platform or filing in forms as part of the registration process. This includes information provided at the time of registering to use the Platform, whilst purchasing services or products, or requesting further information. We may also ask you for information when you report a problem with the Platform.
- Specifically, personal details such as name, email address, billing and delivery address, mobile number and any information we collect from you or you input by when using the Platform, completing our survey forms, using our services.
- If you contact Us, We may keep a record of that correspondence.
- We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
- Details of your visits to the Platform including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
- Details of your mobile device including but not limited to IMEI number, IP addresses.
- We may also receive information about you from third parties if you login or register for an account with a third party service (for example, Facebook, G+ login or LinkedIn), the third party service may send us information such as your registration and profile information from that service.
The provision of your name, e-mail address, billing and delivery address, mobile number is required from you to enable Us to process your purchases. The provision of your name, e-mail address, mobile number, address is required form you to enable Us to enable us to register you as a user and provide you with our services. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
USES MADE OF YOUR INFORMATION
We use information held about you in accordance with the following “legal bases” and for the following purposes-
- To provide you with our Platform, associated functionality and services (such as, allowing you to purchase the products/services, passing your information to and informing the service provider that you have purchased their product) and to carry out any other obligation arising from any contracts entered into between you and Us. We rely on “performance of contract with you” as the legal basis for this processing.
- To prevent use of any fraudulent identities or payment details and to support concerned authorities in tracking any such events. We rely on “legitimate interest” as the lawful basis on which your personal data is collected and processed by us and disclosed to a third party.
- We rely on your consent as the lawful basis where you have agreed to participate in a survey, and for the processing of such personal information as has been collected through that survey.
- To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website. We rely on “legitimate interest” as the legal basis for this processing, and the legitimate interest is the “maintenance and improvement of our Website for the benefit of all our users”.
- To notify you about changes to our service. We rely on “performance of a contract with you” as the legal basis for this processing.
- To allow you to participate in interactive features of our service, when you choose to do so.
To provide you with information and offers that you request from Us or which We believe may be of interest to you. We rely on “legitimate interest” as the lawful basis on which We process your personal data for direct marketing purposes.
If you do not want Us to use your data in this way please either (i) tick the relevant box situated on the form on which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
- We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.
- We pass your information to service providers who services/products you purchase via our Platform so that they are able to perform that service or deliver the product you have purchased. These service providers may use your personal data for marketing where they have a legal basis to do so.
We may also disclose your personal data to third parties:
- in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
- if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Platform Terms and Conditions and other agreements; or
- to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Platform.
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Platform, you are responsible for keeping this password confidential.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Payment is handled securely, through the payment processor you have selected. If you want to find out more about how the payment processor processes your personal data, you can refer to their own privacy notice.
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 the Platform; 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.
Keeping your personal data up to date
If your personal details change you may update them by accessing the relevant page of the web site or the “My Accounts” within the Platform or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
- We will hold your personal data including your name, email address, billing and delivery address, mobile number, IP address, IMEI number and your purchase history for 7 years from the transaction date.
- In instances where you have registered but not made a purchase We will hold your contact details, for as long as you are registered with the site and for 7 years after the transaction was attempted.
- Where you have contacted us via e-mail and telephone, We will hold your contact and any details we have collected from you for 7 years, unless you register.
- Where you have participated in our surveys, We will hold your survey details for 7 years.
Where we store your personal data
All information We hold about you is stored on secure servers in the UK.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). We will take all steps reasonably necessary to ensure that your data is held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).
We will not otherwise transfer your personal data outside the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information please contact Us (see ‘Contact’ below).
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require Us to correct any mistakes in your information which We hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, Us at firstname.lastname@example.org,
- let Us have enough information to identify you (name and e-mail address),
- let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let Us know the information to which your request relates , including your order ID, e-mail address and mobile number
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner.
We may collect information about your mobile phone, computer or other device from which you access the Platform including where available your IP address, IMEI numbers, operating system and browser type, for systems administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies We use include:
- “Analytical” They allow Us to recognise and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps Us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
- “Strictly necessary” cookies. These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform, use a shopping cart or make use of e-billing services.
- “Functionality” cookies. These are used to recognise you when you return to our Platform. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- “Targeting” cookies. These cookies record your visit to our Platform, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Platform, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to email@example.com write to us at Kwikpay Limited, Devonshire House, 7 Goswell Road, London EC1M 7AD UK.