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MultiSafepay Privacy Policy

MultiSafepay is a provider of payment services and processes a large amount of data. MultiSafepay therefore attaches great importance to protecting the personal data you share with us and wants the highest possible level of protection. MultiSafepay takes all necessary steps to ensure secure data processing.

In this privacy policy, MultiSafepay (MultiSafepay, we, us, our) informs you about how we collect, process, use and share personal data of Customers, Merchants and Website Users.

This Privacy Policy applies to:

• Visitors to our websites (including www.multisafepay.com/privacy-cookies) or any other person who contacts us over the telephone, email or other means (Visitors);
• Customers who register for and/or use MultiSafepay Services (meaning given under the MultiSafepay Terms and Conditions) (Customers). This may include merchants, platforms, and sub-merchants (for instance if you have an account on a platform);
• Consumers who do business with, or otherwise engage in a transaction with a Customer, such as those buying goods and services from a Customer using MultiSafepay Services for payment processing (End Users); and
• Personnel, officers, and connected persons of our Customers and other partners (Representatives) where their personal information is provided to us in connection with MultiSafepay Services.

Unless otherwise indicated or the context requires otherwise, reference to you or your are intended to refer to a Visitor, Customer, End User and/or Representative, and reference to MultiSafepay, we, us or our in this Privacy Policy refer to MultiSafepay B.V., and other affiliates involved in providing MultiSafepay Services to you (each an Affiliate). References to the Group refer to Ant International, which MultiSafepay and its Affiliates are subsidiaries of.

1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We collect and use personal information about you, including when you interact with us, register for an account, contact us directly with respect to any queries or otherwise communicate with us, use MultiSafepay Services to make purchases or otherwise conduct financial transactions, or otherwise visit or use our MultiSafepay Services.

We may collect the following personal information about you:

• Basic Personal Details, such as your first and last name, date of birth, and copies of your government ID documents (e.g., passport, driver's licence or social security number);
• Contact Information, such as your address, phone number, email, or other information that permits us to contact you;
• Information related to Representatives, such as copies of government ID documents and role and relationship with the relevant Customer or partner; company registration details, such as the basic personal details of the ultimate beneficiaries and account authentication details to complete know your business or know your client checks as required by local law; financial information and tax identification information;
• Account and Transaction Details, such as the merchants you deal with, the amounts paid, details of the products and/or services purchased, payment methods and details of the payment card used to complete a transaction with a merchant, and information related to requests for chargebacks and/or refunds;
• Marketing Preferences and Communications, such as details of any marketing preferences you have given us (such as requests to receive or not receive certain types of marketing communications), and copies of communications with or about you; and
• Technical Information, such as information about the device you use to interact with us and our services (including IP address, geographical location, device type and model, screen resolution, app version, device language, device identification codes and other features/data that can be used to identify a device), and information from your visits to our websites or mobile applications, and your interactions with our emails or other communications. This includes browser history, product engagement, length of visit/usage, page views and any search term you use, IP address or other unique identifiers, browser/platform type and version, internet service provider, operating system, referral source/exit pages, device operations, session information, device ID, user agent, device logs in the event of a crash or error report, and unique identifiers saved in cookies and information associated with a cookie.

As noted above, we collect personal information which may be considered sensitive in certain jurisdictions. Specifically, if we collect your passport, your payment card information, or your financial information and tax identification information, you may have additional rights and protections with regard to such sensitive personal information under certain data protection laws.

We will indicate whether the provision of personal information is mandatory or optional. If you do not provide mandatory personal information to us, you may not be able to use the MultiSafepay Services.

2. HOW WE OBTAIN YOUR PERSONAL INFORMATION?

We collect the above personal information (including sensitive personal information, if any) from various sources, either directly from you or indirectly, as set out below.

We collect personal information directly from you when you provide it to us in connection with MultiSafepay Services. For example, we collect your personal information when you enquire about or register to use any of the MultiSafepay Services, sign an agreement with us, provide your personal information during the merchant onboarding process, log into your account to use MultiSafepay Services on our sites, or when you communicate with us via e-mail, phone, SMS, or any other electronic means.

We also receive personal information about you from the following sources:

• Customers and other third parties who support the ability to make payments and conduct transactions through MultiSafepay Services or otherwise;
• Affiliates and/or the Group;
• Suppliers providing services on our behalf;
• Banks, card associations, payment networks, acquiring institutions, and other financial institutions that we cooperate with to provide you with MultiSafepay Services;
• Third parties for fraud monitoring and prevention purposes, or other purposes required by law;
• In relation to Representatives, from the relevant Customer or partner; and
• Publicly available sources.

We may combine information that we have about you from various sources, including the information you have provided to us.

Please refer to the section How We Use Your Personal Information below for more details.

3. HOW WE USE YOUR PERSONAL INFORMATION?

We use your personal information (including sensitive personal information, if any) to provide you with MultiSafepay Services. More specifically, we may use your personal information for the following purposes:

MultiSafepay must comply with all laws and regulations applicable to the payment services industry, such as the Money Laundering and Terrorist Financing (Prevention) Act (Wwft). The categories of data we process may vary depending on your relationship with MultiSafepay.

You may have multiple relationships with MultiSafepay at the same time. These are described below.

Merchant

From a Merchant, data is processed that you provide to us and that we collect as part of the Know Your Customer (KYC) process. This concerns personal data, such as your name, date of birth, nationality, address, telephone number and e-mail address. In addition, other personal data may also be processed that is actively provided to MultiSafepay (for example in correspondence or telephone conversations), such as the e-mail address of a Merchant employee.

Customer

Of a Customer, data is processed that you provide to us when you use our services. These are personal data, such as your name, date of birth, nationality, address, telephone number and e-mail address. These data are necessary to perform our payment services and the processing of transactions.

In addition, other personal data may also be processed that is actively provided to MultiSafepay (for example in correspondence or telephone conversations).

Website user

Our website uses cookies. The use of cookies is a standard Internet technology that allows us to store certain login information. Cookies do not allow natural persons to be identified, only machines. Each visitor can set a computer to not accept cookies. If you are a visitor to our website, we process various types of information about you and your online behaviour and use cookies, unless your computer is set so that this does not take place. By information about your online behaviour, we mean location data, data about your activity on the website, your IP address, your internet browser, the device used, etc. Please refer to our cookie policy [Insert hyperlink] for further information.

4. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We share your personal information (including sensitive personal information, if any) for the purposes indicated under the section How We Use Your Personal Information above, with the following categories of recipients:

• Our Affiliates;
• Customers that provide you with products, services and other offerings on or through MultiSafepay Services;
• Any agent, contractor, vendor, or service provider that we work with in providing MultiSafepay Services;
• Service providers elected by you;
• Third parties where you have instructed us to share information with them;
• Banks, card associations, payment networks or acquiring institutions, and other financial institutions involved in processing payments and conducting transactions through MultiSafepay Services;
• Law enforcement agencies, insurers, government and regulatory or supervisory authorities or any other organizations to which we, or any of our Affiliates or service providers, are under an obligation to make disclosure under applicable law, regulation, code of conduct, good practice requirement, or commercial arrangement;
• Parties relevant to litigation proceedings and the assessment of claims or disputes, including courts;
• Individuals and entities involved in any merger, acquisition, corporate reorganization, financing, or similar transaction with us, including in the event of the sale of all or part of our assets; and
• Our own and others' professional advisors (e.g., lawyers, accountants, auditors, and trustees).

See the section How Do We Store And Protect Your Personal Information for information on how long we retain your personal information and how we try to keep your personal information secure when storing it or sharing it with others.

5. HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?

MultiSafepay attaches the highest importance to the protection of your personal data. Therefore we take all appropriate measures, both technical and organizational, to prevent unauthorized access or modification, loss, unwanted transmission and improper use. MultiSafepay uses techniques such as firewalls, monitoring of file integrity, strong authentication, alarms and encryption. In addition, various organizational measures are taken such as employee screening, strict access procedures, employee training and procedures regarding incidents and vulnerabilities.

If you are convinced that your data is not properly secured or is being processed unlawfully, please contact us at [email protected].

We keep your personal information (including sensitive personal information, if any) in accordance with our policies and for as long as it is necessary to provide you with MultiSafepay Services or other purposes as set out in this Privacy Policy. In addition, we may retain your personal information for a longer period if it is necessary to comply with laws and regulations applicable to us. The criteria we use to determine the appropriate retention periods are:

• Regulatory requirements that we are subject to;
• Whether a legal claim could be brought against us;
• Necessity of information to provide the MultiSafepay Services;
• The type, nature, and sensitivity of your personal information being processed; and
• The legal basis for processing (e.g., consent).

6. WHAT IS OUR LEGAL BASIS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION?

We collect and use your personal information on one or more legal bases set out below (and where applicable, under any other legal bases permitted under the relevant data protection legislation).

• For the performance of any contracts to which you are a party.
• To comply with legal and regulatory obligations.
• With your consent, for example when you give consent to our use of cookies in order to measure and improve our sites.
• For legitimate interests, including to operate, market and improve our business and minimise disruption to MultiSafepay Services; ensure service security and protect against fraud or other criminal conduct; comply with codes of conduct and practice; send service-related and marketing communications; transfer personal information internationally (including to Singapore, the European Economic Area, the United Kingdom, the United States, Malaysia and China) as part of technical infrastructure and business structure; and for other purposes set out in section 3.

However, in cases in which we wish to use your personal information for our legitimate interests, we carefully consider the position and do not proceed if we think your interests or fundamental rights and freedoms relating to your personal information would be prejudiced.

7. INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

We are a global business and your information may be processed outside of the country where you live. These other countries might have data protection regulations that are different from those in your country. Regardless of where your information is processed, we take measures to comply with applicable data protection laws related to such transfer.

If you are located in the EEA, or Switzerland, any transfers of your data to third countries will be in accordance with standard data protection clauses approved by the European Commission or approved under Swiss data protection laws (often called SCCs), or other lawful methods available to us under applicable law. For reference, information regarding the EU SCCs can be found here.

8. YOUR CHOICES AND PRIVACY RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

Based on the European Union's General Data Protection Regulation (AVG), Regulation (EU) 2016/679, you have the following rights. In accordance with applicable data protection and privacy laws and regulations, you may be entitled to:

• Ask us about the processing of your personal information and access it, including by asking us to provide you with a copy of your personal information;
• Request the correction and/or updating of your personal information;
• Request the deletion of your personal information;
• Request the restriction of the processing of your personal information, or object to that processing;
• Ask not to be subject to decisions based solely on automated processing (including profiling);
• Withdraw your consent to the processing of your personal information (where we process your personal information based on your consent);
• Opt out of email marketing and certain other communications via the unsubscribe link in marketing email;
• Request receipt or transmission, in a machine-readable form, of the personal information that you have provided to us where we are using your personal information based on consent or performance of a contract; and
• Complain to the relevant supervisory authority.

MultiSafepay can only grant these rights if the processing of the data is not based on a legal obligation. MultiSafepay is legally obliged to retain certain personal data, which means that we cannot always delete personal data if you request it.

9. HOW DO WE PROCESS PERSONAL INFORMATION ABOUT CHILDREN?

MultiSafepay does not intend to collect or process information about minors (under 16 years of age, Article 8 of the AVG) or vulnerable groups who visit the MultiSafepay website, even if a parent and/or guardian has given consent to visit the website. Unfortunately, MultiSafepay cannot verify the age of website visitors. Therefore, we recommend that parents and guardians closely monitor their child's online activities to prevent us from processing data from minors.

If you believe that MultiSafepay has unlawfully processed sensitive personal data, please contact us at [email protected].

10. THIRD PARTY SERVICES AND SITES

We may provide links to third party websites and services (including other online merchant sites) for your convenience and information. These services and websites may operate independently from us. Linked services and websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked services and websites.

To the extent any linked websites and services you visit are not owned or controlled by us, we are not responsible for these websites or services content, any use of these services or websites by you, or the privacy practices of these services or websites.

11. CHANGES TO THIS PRIVACY POLICY

We may change, amend or revise this Privacy Policy from time to time. We notify you of any substantive or material change through a combination of updating this webpage, sending push notifications, e-mails or letters, by phone, or by publishing announcements on our websites. You can review this Privacy Policy any time at the homepage of our websites.

Once posted on our website, the new Privacy Policy will become immediately effective unless stated otherwise.

12. DATA PROTECTION OFFICER AND CONTACT INFORMATION

MultiSafepay has appointed a Data Protection Officer (DPO). If you have any questions and/or complaints regarding your privacy, please contact our DPO. Our Data Protection Officer works for Lumen Group. The DPO can be reached by phone at 030 -889 65 75 or by email at [email protected]. In addition, the DPO can also be reached via the secure website. The DPO's responsibilities include independently monitoring and advising on the proper and careful handling of personal data.

If you have any questions about this privacy policy, wish to exercise any of your rights, or believe that your data is being misused, poorly secured, or incorrectly processed, please contact the Privacy Officer at [email protected].

13. CONTACT US

If you wish to exercise any of your rights as listed above, please contact us at [email protected]. MultiSafepay will process your request as soon as possible, but in any case within 1 month. If the request is very complex, we may extend this period by 2 months. You will be informed of this within the first month.

For security reasons and to establish the legitimacy of your request or complaint, we may ask you for proof of your identity. This may be in the form of a copy of your proof of identity (e.g. passport or identity card). You can mask your passport photo, MRZ (Machine Readable Zone, strip with numbers at the bottom of the passport), passport number and Citizen Service Number (BSN) to protect your privacy.