Privacy Notice

1. What is the purpose of this document?

This Privacy Notice describes how Paysaxas Financial Solutions Corporation and its subsidiaries, affiliates, and related entities (collectively, “Paysaxas” “we” or “us“) collect and process personal data about you as Affiliate or representative, shareholder or ultimate beneficiary owner (UBO) of the Affiliate. The term “Affiliate” means a party to the Paysaxas Affiliate Rules as described at User Agreement

Paysaxas is a “controller” in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. This privacy notice makes you aware of how and why your personal data will be used and how long it will usually be retained for. It provides you with certain information that shall be provided under the EU General Data Protection Regulation and other applicable regulations (GDPR).

2. Data protection principles

We will comply with data protection law and principles, which means that your data will be:

• used lawfully, fairly and in a transparent way.
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• relevant to the purposes we have told you about and limited only to those purposes.
• accurate and kept up to date.
• kept only as long as necessary for the purposes we have told you about.
• kept securely.

3. The kind of information we hold about you

In connection with you being Affiliate or representative of the Affiliate, we will collect, store, and use the following categories of personal information about you:

If you are an Affiliate

• the information you have provided to us in the Affiliate registration form.
• the information you have provided in the affiliate portal.
• any information you provide to us during the KYC check via the Sumsub verification platform.

If you are a representative, shareholder or of an Affiliate

• the information Affiliate provided about you in the Affiliate registration form.
• the information Affiliate provided about you in the affiliate portal.
• any information Affiliate provided about you during the KYC check via the Sumsub verification platform.

4. How is your personal information collected?

We may collect personal information about you from the following sources:

• You;
  • Sumsub KYC check provider, from which we collect the following categories of data:
  • identity document and information in it, such as (issue date, expiry date, date of birth, issuing body etc.);
  • person verification (liveness check);
  • proof of address;
  • phone number verification;
  • email verification; and
  • Time, place (country, city, IP address) and device during the connection.
• From the Affiliate, if you are representative, UBO or shareholder of the Affiliate.

5. How we will use information about you

We will use the personal information we collect about you to:

If you are an Affiliate:

• assess whether you meet the requirements of the Affiliate Rules;
• fulfill our obligations to you as an Affiliate, related to the accrual and payment of rewards;
• contact you regarding cooperation within the Affiliate Rules; and
• comply with legal or regulatory requirements.

If you are a representative of an Affiliate:

• assess whether the Affiliate meets the requirements of the Affiliate Rules;
• determine if you are authorized to represent the Affiliate;
• fulfill our obligations to the Affiliate, related to the accrual and payment of rewards;
• contact you regarding cooperation within the Affiliate Rules; and
• comply with legal or regulatory requirements.

If you are a shareholder or UBO of an Affiliate:

• assess whether the Affiliate meets the requirements of the Affiliate Rules;
• comply with legal or regulatory requirements.

6. Sumsub check

According to our Affiliate Rules we may request you to undergo a KYC verification through our provider – Subsub (https://sumsub.com). Subsub acts as the processor of your personal data, while we act as the controller. We kindly ask you to review the Privacy Notice of Subsub before undergoing the verification.

During the verification process, we may request the following documents/information from you: passport, proof of address. Additionally, Sumsub verifies your phone number and email address. We request this information to confirm your identity. Furthermore, Sumsub conducts checks to see if you appear on sanction lists, politically exposed persons (PEP) lists, and if there are any negative mentions about you in the media, if the provided phone number and email may be found suspicious or fraudulent

7. Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

8. Data sharing

Why might you share my personal information with third parties?

We will only share your personal information with the following third parties for the purposes of processing your application: our payment service providers and our sales consultancy services providers. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the EU to countries which have laws that do not provide the same level of data protection as the GDPR.

Whenever we transfer your personal data out of the EU to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• we will only transfer your personal data to countries that have been deemed by the EU to provide an adequate level of protection for personal data; or
• we may use specific standard contractual terms approved for use in the EU which give the transferred personal data the same protection as it has in the EU, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us.

9. Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our privacy manager (privacy@paysaxas.com). We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so

10. How long will you use my information for?

If you are an Affiliate:

We will retain your data for the entire period during which you are an Affiliate according to our Affiliate Rules and for 5 years after we terminate the agreement between us.

If you are a representative, shareholder, or UBO of an Affiliate:

We will retain your data for as long as you maintain such status in relation to the Affiliate, as well as for 5 years thereafter.

11. Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact privacy@paysaxas.com via email.

Right to withdraw consent When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact privacy@paysaxas.com. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

12. Cookies

We use cookies to enhance your website experience. Find out more about our Affiliate Cookie Policy at cookies policy.

13. Data privacy manager

We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data privacy manager at privacy@paysaxas.com. You have the right to make a complaint at any time to your local data protection authority