Privacy and cookies

1. What personal information do we collect about you?
2. How we obtain your personal information?
3. How we use your personal information?
4. With whom do we share your personal information?
5. How do we store and protect your personal information?
6. What is our legal basis for collecting and using your personal information?
7. International transfers of your personal information
8. Your choices and privacy rights
9. How do we process personal information about children?
10. Third party services and sites
11. Changes to this privacy policy
12. Data protection officer and contact information
13. Contact us

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 both. MultiSafepay takes all necessary steps to ensure secure data processing.

In this privacy policy, MultiSafepay (MultiSafepay, we, us, our, 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 & 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 the following usage, device, and technical information:

• 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 information 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 which is necessary to provide the services you have requested or which helps us measure and improve our sites.

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?

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:

• ur 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. We set out a list of such agents, contractors, vendors, and service providers here ;
• 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 of 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 the requirements of any applicable law, regulation, code of conduct or good practice or conduct 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
• ur 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/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 will 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 (or sensitive personal information, if any) for a longer period (including after you are no longer a user of our services) 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:
• to operate, market and improve our business and minimise any disruption to the MultiSafepay Services that we may offer to you;
• to ensure the security of the MultiSafepay Services and to protect us, our staff, users and others from fraud or other criminal or similar conduct;
• to comply with codes of conduct, codes of practice and similar good conduct principles which do not have the force of law in the countries in which we operate, but are prudent for the Group to apply;
• to send you service-related communications and marketing/promotional communications about our or the Group’s products and services , to make our communications with you more relevant and personalised to you, and to make your experience of our products and services efficient and effective;
• to transfer your personal information internationally (including to Singapore, the European Economic Area, the United Kingdom, the United States, Malaysia and China) in order to accommodate our technical infrastructure and as part of our business structure, including as a result of laws and regulations applicable to us and other Affiliates and legal claims or proceedings that involve us or other Affiliates; and
• for other purposes including those 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 your 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);
• pt-out of email marketing and certain other communications. You may manage your receipt of marketing communications by clicking on the "Unsubscribe" link located on the bottom of any MultiSafepay marketing email and/or following the instructions found on any page to which the link may take you. Please note that you cannot opt out of receiving administrative, support, or transactional emails;
• request receipt or transmission to another organisation, 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 abovementioned 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 their 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. Nevertheless, 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 ( i ) these websites’ or services’ content, (ii) any use of these services or websites by you, or (iii) 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 will notify you of any substantive or material change in this Privacy Policy 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 abovementioned, 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.