Effective: 10 June 2020
What Type Of Personal Information We Collect
While using our Service, we may ask you to provide us with personal identifiable information that can be used to contact or identify you (“Personal Information”), which may include but is not limited to:
- First name and surname
- Contact details (email, telephone number)
- Details of your identity document
- Residence address
- History of your logs and activity on the Site
- IP address, browser and operating system information, device fingerprint.
Most information we collect is provided by you directly. We could also receive some information from publicly available sources (for example, on sanctions) or from our third party vendors. We may make use of screening lists provided by data vendors, ID verification, anti-fraud and transaction monitoring services.
Please note that we will not be able to provide our Service to you if you refuse to provide us information according to our KYC/AML requirements communicated to you once you decide to apply for any of our services that require verification of identity and ongoing monitoring of activity. Please keep in mind that in some cases we may require additional details and documents for KYC/AML purposes.
How We Use The Information
Paystruct uses the information for the following purposes:
- To provide our Services to you, as an individual, or a corporate client you represent;
- To contact you about our Service;
- To comply with our legal obligations (e.g. KYC/AML requirements);
- To provide assistance in case of criminal investigation and regulatory action;
- To provide customer support or reply to your requests;
- To detect, prevent and address technical issues;
- To provide you information on our Service, news and updates;
- To resolve disputes and protect your interests or interests of other users.
Under the GDPR, the lawful bases we rely on for processing this information are:
- Your consent. You are able to withdraw your consent at any time by contacting us at email@example.com;
- We have a contractual obligation;
- We have a legal obligation to comply with AML/CTF requirements under the applicable laws and regulations, keep records for tax purposes;
- We have a legitimate interest in providing the necessary updates regarding our Service, prevent any fraudulent activity proactively and retrospectively, and contacting employees of our clients and business partners.
Who We Share Your Personal Information With
We may share this information with:
- Our affiliates, agents and representatives;
- Our contractors providing software;
- Our contractors providing us information from publicly accessible sources (for instance on sanctions);
- Our financial service providers through which we facilitate fiat currency transactions to/from our services;
- Law enforcement or regulatory agencies if required or permitted by law.
Retention Of Personal Information
We will ensure that any information we need for any purpose shall not be kept for longer than it is necessary. We retain your Personal Information just to comply with our legal obligations, resolve disputes, and protect your and our legitimate interests.
We will keep your Personal Information for a maximum period of seven (7) years upon termination of legal relationships with us.
You can always request to remove the Personal Information. But keep in mind that in certain cases we are obliged to store your information to be legally compliant.
Security Of Your Personal Information
The security of your Personal Information is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your Personal Information.
- Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your Personal Information.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your information.
- Your right to object to processing – You have the right to object to the processing of your Personal Information.
- Your right to data portability – You have the right to ask that we transfer the Personal Information n you gave us to another organisation, or to you.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at firstname.lastname@example.org if you wish to make a request.
Please note that in some cases we will not be able to fulfil your request due to our legal obligations or overriding legitimate interest. In such cases we will explain you the reasons why your request cannot be fulfilled and how you can complain.