Wally Payments s.r.o., company registration no. 06132324, with the registered office at Na hutích 690/4, Dejvice, 160 00 Praha 6, firstname.lastname@example.org, +972548800087.
Wally Payments (“Wally Payments" or “we" or “us”) care about your privacy and are committed to processing your personal information in accordance with fair information practices and applicable data protection laws.
SCOPE OF THIS PRIVACY STATEMENT
This Privacy Statement describes how Wally Payments collects, uses, protects and shares your personal information when you use our services, as well as your choices about the way your information is collected and used. Personal information means all information relating to an identified or identifiable individual.
INFORMATION WE COLLECT
When you use our payment services or contact us (collectively, the “services”), we collect personal information about you and may use it along with other information collected or generated during our relationship with you. We collect different types of personal information relating to you, which may include:
- Contact information, for example your name, postal address, e-mail address, telephone number, date of birth and national identification numbers;
- Transaction information, including your money transfers;
- Business related information that helps us provide our services to you, such as membership in our loyalty programs, use of our services, and marketing choices;
- Compliance information, including fraud prevention, identity verification, and sanction checks.
To conduct a money transfer you must provide certain information required by Wally Payments to execute the transfer and to enable us to comply with our legal obligations associated with transferring money. Failure to provide some of your personal information may affect our ability to provide our services to you. This may include information about the form of identification used to send or receive a transaction (where required by law) including the identification or a copy of the identification document, transaction activity, bank account and payment information.
When you use our online services, we also collect personal information about the domain and host from which you access the Internet, your computer’s IP address or device advertising ID, geolocation if enabled, information about your device (such as device properties, settings, applications, storage and usage information), browser and operating system software, social profile and network information, the date and time you access our websites and the address of the site from which you linked to our website when you visit us. We collect personal information on your online activity as described in the paragraph below titled “COOKIES AND INTERNET TECHNOLOGY.”
HOW WE COLLECT INFORMATION
Wally Payments collects your personal information in several ways:
- Through transaction forms and your interactions with Wally Payment partners;
- Through online forms;
- While providing customer support or consultation, using email, call centres or chat;
- Through the process of maintaining and upgrading our services;
- Through automated means such as communications protocols, e-mail communications and cookies;
In addition to the personal information we collect from you, we may also collect your personal information from the person to whom you send and/or receive money, as well as our business partners, identity verification companies, payments and fraud risk management companies, law enforcement bodies, and commercial and public data sources.
PURPOSES AND LEGAL BASES UPON WHICH WE USE YOUR PERSONAL INFORMATION
Wally Payments may use your personal information for each of the following purposes and legal bases:
We use your personal information to provide our services to you: This includes using personal information necessary for conducting payment services.
We use your personal information for legitimate business purposes: This includes using personal information to analyze and improve our products, locations, services, operations, the running of this site and your customer experience, and for measuring marketing return on investment and brand satisfaction. This may include using your information to conduct market research surveys. We may also use your personal information to provide customer services and to help protect the security and integrity of our technology, systems, and services.
We use your personal information for legal and compliance purposes: This includes using personal information needed to comply with legal and regulatory duties related to anti-money laundering and counter-terrorist financing; detection, prevention and prosecution of fraud and theft as well as preventing illegitimate or prohibited use of our services or other illegal or wrongful activity. This may also include establishing, exercising, or defending legal rights and claims of Wally Payments and others, and monitoring and reporting compliance issues. This may further include using your personal information to validate and authenticate your identity, and utilizing third parties to help us do so.
We may process your personal information based on your consent: This includes consent for receiving marketing communications, or where otherwise required by applicable law. If we request your consent, we will inform you of the intended purposes for which your information will be processed.
We will inform you when your information is required to provide the services you request, or is required by law. When performing money transfer services, we may be unable to provide you with our services unless you provide certain personal information.
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation); https://eur-lex.europa.eu/eli/reg/2016/679/oj
Wally Payments’s Website may be linked to or from third party websites. Wally Payments has not reviewed, does not control, and is not responsible for the content or privacy practices employed by websites that are linked to or from our website. Wally Payments does not assume responsibility for any of these sites, their content, or their privacy policies. Wally Payments does not endorse third party websites or make any warranties about any information, software or other products or materials you may find there, or any results that may be obtained from using them.
CONFIDENTIALITY AND SECURITY
We endeavor to maintain physical, technical and organizational safeguards that comply with applicable government laws and regulations to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. We also endeavor to restrict information access to our employees and representatives that need to know it. Despite our efforts, third parties may unlawfully intercept or access transmissions sent to us or may wrongly instruct you to disclose personal information to them while posing as Wally Payments. Personal information transferred outside the EEA to countries that the European Commission has not found to provide adequate protection will be protected by appropriate contractual clauses or other EU-approved mechanisms, as required by law. You may obtain a copy of these measures by following this link: to https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/rules-international-transfers-personal-data_en.
DISCLOSURE OF YOUR INFORMATION
If there is a reasonable need to do so for any of the purposes listed above, we may disclose your personal information including, but not limited to, your name, customer ID number, address, transaction patterns and bank account information to the following types of organizations or parties:
- Our business partners who facilitate the money transfer transaction or specific service you have requested;
- Service providers, payments processors, banking partners and data processors contracted to provide business and customer services including marketing, advertising and customer satisfaction research on our behalf;
- Service providers and data processors contracted to help us validate the accuracy of the information provided by you, and to authenticate your identity and manage risks related to security, fraud and identity.
- Third parties that you have authorized to access your account and/or your account information in order to perform services for you, such as account information service providers and payment initiation service providers.
External service providers:
- KOPEČNÝ & PARTNERS s.r.o.,, Jiráskova 25, 602 00 Brno (law firm – compliance matters)
- Ataxer s.r.o., Jiráskova 25, 602 00 Brno (accounting)
- B on line
We may transmit personal information we possess in connection with a sale or transfer of all or part of our business. We may also disclose your personal information globally, as required or permitted by applicable laws and regulations, to regulatory and financial authorities, law enforcement bodies, courts, governments or government agencies, to meet compliance and legal obligations or to assert or defend the rights and interests of Wally Payments or others.
CHOICE AND OPT-OUT
Subject to your choices and based on the contact information you provide, we may send you commercial communications about our products, which may include offers by email, telephone, post, SMS, social media and other communication or digital channels. We conduct analysis of the information we hold to better understand our customers, including profiling and/or analytics to help us customize or personalize our marketing (when you have agreed to marketing) and to tailor our products and services to help us better serve your needs and requirements. You can opt out of receiving marketing communications at any time. Please note that if you choose to withdraw your consent, you may not be able to participate in or benefit from our programs, services and initiatives for which you previously provided consent.
RETENTION OF PERSONAL INFORMATION
Your personal information will be retained in accordance with statutory periods contained in regulations applicable to financial transactions including those in anti-money laundering, anti-terrorist financing and other laws applicable to us. Otherwise, we will retain your information only as long as necessary for the specific purposes it was collected, or to resolve any query you may raise. As a general rule, we will typically keep your information for no longer than 3 years after a given transaction, unless we have a legal obligation to keep it for a longer period.
YOUR RIGHTS RELATED TO PERSONAL DATA
The General Data Protection Regulation establishes certain rights in relation to your personal data, which are listed below:
- Information: the right to be informed about that we use your personal data according to Article 15 of the GDPR.
- Rectification: the right to correct, amend or update your personal data if it is wrong or has changed
- Erasure: the right to ask us to remove your personal data from our records
- Restriction: the right to ask us to stop processing your personal data
- Objection: the right to object to data processing, if you believe that our legitimate interest might infringe upon your rights
- Access and Portability: the right to access and receive your personal data which you have shared with us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller
- Automated decision making: the right not be subject to individual decisions made solely by automated means
At any time, you are welcome to contact us in relation to these rights. However, please note that there are certain exceptions where these rights may be superseded by laws and other requirements applicable to regulated small-scale payment service providers like Wally Payments. An example of this would be the obligatory retention period, which supersedes the right to data erasure.
If you have a complaint about how Wally Payments has responded to your request under this section, or a question about how we handle your personal information, we ask that you put your inquiry in writing. We will investigate your inquiry and generally respond to you in writing within 15 days of receipt. You have also right to lodge a complaint with a supervisory authority.
You are entitled to claim your rights stated above free of charge.
SUPERVISORY AUTHORITY OF PERSONAL DATA PROTECTION
The Officer for Personal Data Protection, Pplk. Sochora 27, 170 00 Praha 7, +420 234 665 800, www.uoou.cz