“Client” means a customer of Access PaySuite Ltd.
“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to needing to log in.
“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
“User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
“Controller” shall have the meaning given to that term by GDPR.
“Processor” shall have the meaning given to that term by GDPR.
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means.
2. The Information We Collect on the Service
We collect different types of information from or through the Service. The legal basis for Access PaySuite's processing of personal data are primarily that the processing is necessary for providing the Service in accordance with Access PaySuite's Terms of Service and that the processing is carried out in Access PaySuite's legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.
2.1 User-provided Information. When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, post Client Data, interact with other users of the Service through communication or messaging capabilities, or send us customer service-related requests.
2.2 Information Collected by Clients. A Client or User may store or upload into the Service Client Data. Access PaySuite has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.
2.3 “Automatically Collected" Information. When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, “clear gifs" or “web beacons.” This “automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.
2.5 Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
3. How We Use the Information We Collect
We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:
3.1 Operations. We use the information – other than Client Data - to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the provision of payment processing services in line with Access PaySuite Terms of Service.
3.2 Improvements. We use the information to understand and analyse the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, feature, and functionality. Should this purpose require Access PaySuite to process Client Data, then the data will only be used in anonymised or aggregated form so that information concerning personal or material circumstances cannot be attributed to an identified or identifiable natural person.
3.3 Communications. We may use a Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
3.4 Cookies and Tracking Technologies. We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalise our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customised advertisements, content, and information; (iii) monitor and analyse the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service.
Cookies are never shared with third parties.
Access PaySuite uses the services of Google Analytics in order to monitor and report on the usage and performance of our website, along with the success of marketing campaigns. Data collected includes the number of visitors to the site, search phrases used to find our site, the pages viewed and amount of time spent on the site.
We firmly believe that the services offered by Google Analytics and the statistics gathered are strictly necessary for us to provide and improve our products, services and website offering. Moreover, such statistics are necessary for us to remain competitive in our chosen markets. Google Analytics’ cookies do not identify website users nor associate an IP address with any personally identifiable information.
Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
4. To Whom We Disclose Information
Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
4.1 Unrestricted Information. Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.
4.2 Service Providers. We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
4.3 Non Personally Identifiable Information. We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
4.4 Law Enforcement, Legal Process and Compliance. We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws in the European Economic Area (EEA) or other jurisdictions that we operate, in response to a judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
5. Your Choices
5.1 Access, Correction, Deletion. We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.*
Clients may update, correct, or delete Personal Data and other applicable preferences at any time by accessing the applicable area of the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service. All Data Subject Access Requests are handled within the required GDPR timelines.
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Access PaySuite's Data Protection Officer at email@example.com. You also have a right to lodge a complaint with data protection authorities.
*Please note that we have a legal right to retain Personal Data collected as part of Direct Debit service provision to comply with the Direct Debit Guarantee which allows payers unlimited time to make claims via the Direct Debit Indemnity Claim process as defined in The Service Users Guide and Rules. Under this circumstance, data will be held indefinitely to assist financial reconciliation and recompense.
5.2 Navigation Information. You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
5.3 Opting out from Commercial Communications. If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.
Users are able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by following the unsubscribe instructions contained within the email.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you may continue to receive administrative messages from us regarding the Service.
Access PaySuite has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct their query to the Client or User they deal with directly. If the Client requests Access PaySuite to remove the data, we will respond to its request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Client who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Client Data should be addressed as indicated in the “How to Contact Us” section, and include sufficient information for Access PaySuite to identify the Client or its customer or third party and the information to delete or amend.
6. Third-Party Services
The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
7. Your Privacy Rights
We will not share any Personal Data with third-parties for their direct marketing purposes to the extent prohibited by English law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.
8. Interest Based Advertising
Interest based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or their computer, smartphone or tablet, advertising based on their assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.
We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in the Access PaySuite products or services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.
These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners, which measure the effectiveness of certain advertisements; and (3) business partners, which collect information when a person views or interacts with one of their advertisements.
In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.
The information we or third party collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.
We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognise new or past visitors to our Sites; to present more personalised content; to provide more useful and relevant ads - for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalised or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.
Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.
Visitors may opt out of receiving interest based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all - of the interest-based advertising activities in which we or third parties engage.
9. Third Party Cookies
The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on this Site and on other sites across the Internet tailored to your apparent interests.
The business partners and advertising networks that serve interest-based advertisements on the Services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they may reuse this small amount of information on other sites or services.
We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Notice. Other than as discussed in this document, we have no control over these third parties.
9.1 The Following Types of Cookies Are Used in the Site:
- strictly necessary/essential cookies - These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided. These cookies don’t collect information that identifies a visitor.
- performance cookies - These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
- functionality cookies - These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
- behaviourally targeted advertising cookies - These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
9.2 The Following Cookies are Used in the Site:
The cookies set by Google Analytics are: : __ga, __gid
In order to opt out of being tracked by Google Analytics across all websites a browser add on can be found here: http://tools.google.com/dlpage/gaoptout
The cookie used by our online Chat facility is _tawkuuid
Session cookies for login and data ordering for Clients are: ASP.NET_SessionId and MSharp.Framework.UI.Grid.SortExpressions
10. Minors and Children’s Privacy
Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at firstname.lastname@example.org and request that we delete that child’s Personal Data from our systems.
Clients using the Service must strictly adhere to all GDPR compliance requirements as a Controller handling any Personal Data for children under the age of 18.
If you have any question regarding this topic, please contact us as indicated in the “How to Contact Us” section. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.
11. Data Security
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorised alteration, unauthorised disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymise Personal Data. All data is encrypted during storage.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.
If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
12. Data Retention
We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We maintain strict requirements and security controls needed for identification, storage, protection, retrieval, retention and disposal of Personal Data. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
- billing information is retained for a period of 6 years as of their provision to Access PaySuite in accordance with internal policies in relation to accounting and taxation laws
- information on legal transactions between Client and Access PaySuite is retained for a period of 6 years as of their provision to Access PaySuite in accordance with the general limitation period governing commercial contract law and our Terms of Service
Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorised persons.
14. Data Transfer
Client data will be hosted in Access PaySuite's EU data centres located in Dublin, Ireland and Frankfurt, Germany. Regardless of the database being hosted in the EU, if you choose to use the Service from other regions of the world with laws governing data collection and use, be aware that they may differ from EU law. Also, we may transfer your data to other regions or countries within the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
15. Data Controller and Data Processor
Other than for the purposes of lawfully delivering the Service and in the role of acting as a Processor for the Controller, Access PaySuite does not own, control or direct the use of any of the Client Data stored or processed by a Client or User via the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. Access PaySuite is largely unaware of the identity of the Client Data actually being stored or made available by a Client or User of the Service and does not directly access such Client Data except as authorised by the Client, or as necessary to provide the Service to the Client and its Users.
The Client or the User is the Controller under GDPR for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data. The Controller is responsible and accountable for ensuring that the lawful processing conditions required by the GDPR have been met.
Access PaySuite is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client or User nor is Access PaySuite responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.
16. Changes and Updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
17. How to Contact Us
Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at email@example.com. If you have any concerns or complaints about this Policy or your Personal Data, you may contact Access PaySuite's Data Protection Officer by email at firstname.lastname@example.org.