Privacy Policy

INTRODUCTION

Please read this notice carefully to understand our policies and practices regarding your personal information and how we will treat it. For a short-form summary, please click here. California residents can find more specific information on the California Consumer Privacy Act (CCPA) and their rights in the “CCPA” section below. Contact Us details are provided at the end of the notice for feedback or any privacy enquiries you may have.

This notice applies to the companies that are part of the Paysafe Group, which use different trading names in different territories and the list of Paysafe companies that collect or process personal information according to this notice can be found at the end of this document. The reference to Paysafe (including “we”, “us” or “our”) includes those companies and all relevant group affiliates.

References to “you” in this notice are to the individual who is accessing or applying to use the Services (as defined below) either on your own account or on behalf of a business. This includes, in relation to a customer or prospective customer of Paysafe, any sole trader and any principals, including the managing and financial directors, any other directors and officers, shareholders, partners and beneficial owners of a customer, as well as any member of staff accessing or using the Services on behalf of a customer.

Paysafe is committed to protecting your privacy and will take all appropriate steps to ensure that your personal information is treated securely and will be collected, used, stored and disclosed in accordance with this notice. This notice (together with our terms of use applying to any specific services you may purchase or use) applies:

• to the website/portal features and services provided to you when you visit our websites, portals or our payment panels our clients may use on their websites;

• when you apply to use and/or use Paysafe’s products and services (including any loyalty or reward schemes, whether points-based or otherwise (“Loyalty”), as well as when you request changes to the services you are using;

• to your use of software including terminals, mobile and desktop applications provided by Paysafe; and

• to email, other electronic messages including SMS, telephone, web chat, website/portal and other communications between you and Paysafe.

Together these are all referred to in this notice as “Services”.

INFORMATION WE MAY COLLECT FROM YOU

Personal and non-personal information

We collect and process personal and non-personal information relating to you.

Personal information is information that can be used to uniquely identify a single person, either directly or indirectly.

Paysafe also collects non-personal information, or may anonymise personal information in order to make it non-personal. Non-personal information is information that does not enable a specific individual to be identified, either directly or indirectly. Paysafe may collect, create, store, use, and disclose such non-personal information for any reasonable business purpose. For example, Paysafe may use aggregated transactional information for commercial purposes, such as trend analysis and the use of data analytics to obtain learnings and insight around payment transaction patterns and usage.

To the extent that Internet Protocol (IP) addresses (or similar identifiers) are clearly defined to be personal information under any local law, and where such local law is applicable to Services, we will manage such identifiers as personal information.

Please note that Paysafe provides services to both individual consumers and businesses and this privacy notice applies to both and should be read and interpreted accordingly.

COLLECTING YOUR INFORMATION

We collect the following information through the following means:

Information you give us: we receive and store any personal information (including financial information) you provide to us including when you (or your business) enquire for or make an application for the Services; register to use and/or use any Services; upload and/or store information with us using the Services; and when you communicate with us through email, SMS, a website or portal, or the telephone or other electronic means, e.g. in the context of contacting us about your account or transactions. Such information may reference or relate to you or your customers and includes:

• Name including first name and family name, date of birth, age, email address, billing address, username, password and/or photograph, biometric information, address, occupation, nationality and country of residence, a copy of your identification, such as your driver’s license or passport, your social security number and/or other government identification or registration data;

• Card primary account number, card expiry date, CVC details (card security code), account numbers, account balances and the length of time you have maintained those accounts, bank and/or issuer details;

• Information relating to any items purchased, including the location of the purchase, the value, the time and any feedback that is given in relation to such purchase, including travel-related personal information when you or your customer are transacting for airline tickets or other travel related services;

• Information about your use of the Services, such as information about how frequently you transact with us, your average transaction volume, account balances, and the people and merchants to whom you send money and from whom you receive money;

• Points or rewards earned or redeemed in any Loyalty scheme;

• Photos and videos taken during Paysafe events you have registered for, for distribution to event participants and in our promotional materials for future events; and

• Any other information that you or your customer provide or is generated in the context of using the Services.

Information we collect about you automatically: Paysafe receives and stores certain information automatically whenever you interact with Paysafe, whether or not you open an account or undertake a transaction with us; for example by way of “cookies” or similar technology. We also obtain certain information when your web browser accesses Services or advertisements and other content provided by or on behalf of Paysafe on other web sites, or when clicking on emails. Collecting this information enables us to better understand the visitors and customers who use and interact with Paysafe, where they come from, and how they use our services. We use this information for our analytics purposes and to improve the quality and relevance of our services for our visitors and customers. This information includes:

• Technical information, including the Internet protocol (IP) address used to connect your computer or device to the Internet, your login information, browser type and version, equipment type, time zone setting, browser plug-in types and versions, operating system platform, frequency and length of visits, and what links you click on;

• Information about your visit or whether you opened an email, including your geolocation, the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the site page and any phone number used to call our customer service number.

Information collected through our applications: if you download or use mobile or desktop applications provided by Paysafe, we may receive information about your location and your device or the service you are using (including where a payment transaction takes place). Some devices allow applications to access real-time location-based information (for example GPS). Our mobile and desktop apps may collect such information from your mobile device or your computer at any time while you download or use our apps, if your device has real-time location data access enabled. Where required, we will always seek to notify you if it is our intent to collect real-time location information and, also where required by law, obtain your consent. We may use such information for regulatory purposes, our own due diligence checks, fraud and risk management, to better understand transaction patterns and to optimise your experience.

Email and Other Communications: we may receive information about you and your use of Services when we communicate with each other, including when you open messages from us and from the use of electronic identifiers (sometimes known as “device fingerprints”), for example, Internet Protocol addresses or telephone numbers.

Information from Other Sources: we may receive information about you from other sources and add it to our account information, including when you apply to use the Services. For example, we work closely with, and receive information from, third parties like business partners, banks and other financial institutions, merchants, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, government lists and databases, social media sites (including posting made by or about you or us), credit reference and fraud prevention agencies. Credit reference and fraud prevention agency use is further explained below. We may also review public comments and opinions made on social networking sites (e.g. Facebook and Twitter) to better understand our customers and our provision and development of Services.

Information about other people: if you give us information about other people, you must have informed them in advance (for example, by giving them this privacy notice) and you must ensure you have the right to do so.

WHAT WE USE YOUR PERSONAL INFORMATION FOR

We may use and share the personal information we collect for the following purposes:

• To provide our Services to you and your business, including fulfilling Paysafe’s obligations to you or to financial or other institutions in connection with the Services we provide to you (and / or your business). In this context we record and track details of transactions you (and / or your customers) carry out in relation to the Services; analyse and report on your (and / or your customers’) use of any Loyalty service; facilitate the collection or redemption of any points or other rewards currency in respect of any Loyalty programme; notify you about important changes or developments to our website or our goods and services;

• To improve and develop our business, including without limitation to optimise our websites/portals, products and services. This may include using information you insert into forms but do not submit to us, for example by using that information to optimise our website(s) and contacting you for customer services purposes in relation to that form. We can also use your personal information to develop and test new products and services including in our secure and controlled test environment, or occasionally in those of our suppliers;

• To manage and enforce our rights, terms of use or any other contracts with you (and/or your business), including to manage any circumstances where transactions, rewards or points are disputed; manage, investigate and resolve complaints; or recover debt or in relation to your insolvency;

• To manage and mitigate our credit risks and terms of business. If you apply for one of our financial products, we may assess your financial position (and / or of your business), to the extent this is provided for in the applicable terms of use. This credit check will also affect any linked parties such as directors, shareholders and principals. We can do so by receiving and sharing information from and with credit reference agencies and fraud prevention agencies. This credit check will affect also anyone with whom you have a joint account or similar financial association. If it is a joint application, and such link does not already exist, then one may be created. These links will remain until you file a “notice of disassociation” at the credit reference agencies to the extent that such disassociation is allowable. For your information, the agencies will record our enquiries which may be seen by other companies who make their own credit enquiries; and a “footprint” may be placed on your credit file, whether or not you are accepted as our customer. If you are a Director, we will seek confirmation from credit reference agencies that the residential address that you provide is the same as that held by the relevant companies’ registry (where applicable). In addition, where you take services from us, we will give information on how you manage your accounts to the credit reference agencies. If you do not repay any monies in full and on time, credit reference agencies will record the outstanding debt and may share this information with other organisations that perform checks similar to ours. Records generally remain on file at such agencies for 6 years after they are closed, whether settled by you or defaulted, although the retention period may differ across different agencies and territories. If you would like further information on our use of credit reference agencies, please contact us;

• To prevent and/or detect fraud, financial crime, manage risk and to better protect ourselves, our customers and the integrity of the financial system, it may be necessary to process and disclose sensitive personal information (sometimes known as special category personal data) including biometric data to third parties who help us in managing such risks, including identity verification. This may include software and services we use to verify your identity/age by determining whether a selfie you take matches the photo in your ID;

• During the identification process we may use a facial recognition process to compare your selfie with your uploaded ID document. During this process biometric data is generated by creating a digital map of your face in order to better compare your ID photo and your selfie picture. This helps to reduce fraud and is therefore in the substantial public interest. But any biometric information generated is immediately deleted following a match. Paysafe itself does not generally store or retain biometric data because such information is generally generated using secure third-party anti-fraud systems. If your biometric information is stored, retained, or used directly by Paysafe in any way, you will be notified at the point of collection. If you want to know more about our policies and processes in respect of your biometric data, or indeed our use of any other sensitive or special category personal data, you can reach us at the details provided in the Contact Us section;

• To prevent, detect and prosecute fraud and other crimes and abuses of the financial system, or to assist others in doing so, including non-compliance with any terms of business and which may involve the sharing of any relevant or necessary information we have collected or inferred with third parties for such purposes. Paysafe participates in anti-fraud initiatives, which involve assessing you (and/or your customers) and monitoring your transactions and/or locations, to detect patterns requiring investigations or otherwise profile and assess the likelihood of fraud occurring or non-compliance with our or other’s terms of business. We can do so utilising products and services from third parties. Besides, if you give us false or inaccurate information about you, or we identify or suspect a fraud or a crime, we may pass your information to fraud prevention agencies and organisations and to law enforcement agencies and similar bodies, and we may decide to take legal action against you;

• To contact you about your account, to alert you to potential problems, and to respond to your questions to us;

• To manage risks, such as credit and foreign exchange risks, as well as to prevent or mitigate information security risk;

• To send marketing messages, to provide you with the information on products and services you have requested or we think may be of interest to you; to obtain your views on our goods, services and our website/s; in respect of marketing, market research and similar activities, we may use your personal information for such purposes whether or not you are accepted as a customer or continue to receive Services. If you no longer wish to receive marketing or promotional information from Paysafe, you can always stop it. You can find more information on this in the section on “Your Data Protection Rights”;

• To comply with local and national laws;

• To comply with requests from law enforcement and regulatory authorities on public interest grounds or from commercial organisations with whom you have or have had dealings, to establish, exercise or defend legal claims, or to protect your vital interests or those of other persons, for example to help those authorities or other organisations in the fight against crime and terrorism; and

• To comply with card scheme rules or any terms of business.

If you provide information to be published or displayed on public areas of the website/portal or transmitted to other users of the website/portal or third parties, you understand that such information can be used by any third parties accessing the information for any purposes. This information is posted by you at your own risk and you must comply with the terms of use of such site.

DISCLOSURE OF YOUR INFORMATION

We do not disclose information which could identify you personally, to anyone except as described in this notice, as permitted or required by law, and/or for the purposes described in this notice, including:

• Within the Paysafe Group to help us provide our services and for our own internal customer relationship management, analytical and reporting purposes;

• To recipients/senders of a payment in the context of the specific relevant transaction (generally information is limited to full name and email address);

• Credit reference agencies (where permitted under any terms of use or other contract) as described above. If you would like further information on how we use credit reference agencies, please contact us;

• Fraud prevention agencies as described above, including Action Fraud, Financial Fraud Action and the Financial Fraud Bureau and other organisations who assist us in managing fraud and business risk;

• Third-Party Credit and Financial Institutions (where allowed under any terms of use or other contract), including the credit institution where the sender or recipient (and their businesses, respectively) maintain their bank account(s) and the card schemes governing the issue and use of credit, debit, charge, purchase or other payment cards, alternative payment schemes and any other financial institutions who may process payments and who are not operating under Paysafe’s control nor for whose actions or omissions Paysafe has liability;

• Where we provide services through third parties such as Banks and other organisations, we may be required to disclose your information (including any ‘know your customer’ and ‘source of wealth’ information) with such organisations in order to assist their own regulatory obligations or risk assessments;

• Third Party Service Providers, including suppliers who assist us with the provision of Services, including processing orders, fulfilling orders, processing payments, managing credit, security, sector and fraud risk, identity verification, and marketing, market research and survey activities carried out on behalf of Paysafe. Occasionally, we may utilise the services of third-party providers to assist with the provision of services that might require the use of your personal information, including for the purposes of live data testing and to which suitable security arrangements will be implemented;

• To third parties who do not act under our instructions as a service provider (but will be subject to their own legal obligations to keep data secure), in order to facilitate provision of the Services. For example, banks and organisations who facilitate the trading of your stocks, crypto currencies and other financial instruments;

• In order to prevent and/or detect fraud, financial crime, manage risk and to better protect ourselves and our customers, it may be necessary to process and disclose sensitive personal information (sometimes known as special category personal data) including biometric data to third parties who help us in managing such risks, including identity verification;

• Where we are required or permitted to do so by law, Paysafe may be required by law to pass information about you to regulatory authorities and law enforcement bodies worldwide, or we may otherwise determine that it is appropriate or necessary to do so. Such disclosures may also include requests from governmental or public authorities, or with commercial organisations with whom you may have had dealings and who are seeking to mitigate fraud or credit risk, or non-compliance with terms of business, or for the purposes of litigation or legal process, national security or where we deem it in the national or public interest or otherwise lawful to do so. Paysafe will not ordinarily challenge the serving of court or similar orders requiring disclosure;

• Business transfers. Paysafe may buy or sell business units or affiliates. In such circumstances, we may transfer or receive customer information as a business asset. Without limiting the foregoing, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners. In these circumstances we will inform the recipient that your information should be treated in accordance with the standards described in this notice; and

• With your permission, your information may also be used for other purposes for which you give your specific permission.

Except as necessary for the performance of its services and as described above/attached, Paysafe does not sell, rent, share or otherwise disclose personal information about its customers to third parties for their own third-party marketing use without meeting any necessary legal obligations (e.g. consent, opt-out, or as otherwise permitted by law). The California Consumer Privacy Act uses a very wide definition of data “sale” and California residents should read the “CCPA” section below in respect of data sale.

MONITORING

We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, quality assurance or training purposes. When visiting our offices, CCTV, access control systems and/or other monitoring systems may be in operation for security reasons and for health and safety and office management purposes.